While our Hill Country Energy Sub-Regional Planning Commission has had difficulty getting state agencies like Public Utilities Commission of Texas (PUCT) to attend a coordination planning meeting, we have, I believe, been quite effective in making our positions known and in pushing back against Battery Energy Storage Systems (BESS) (also known as EESF). Our latest act was to review PUCT’s proposed rules on EESF and both request a public hearing and we submitted detailed comments on their proposed rules. The following is from the executive summary of our letter to the PUCT. The entire document is attached below.
“The HCESRPC strongly opposes the PUCT’s proposed rules regarding EESF. We believe that EESFs introduce significant safety, environmental, cybersecurity, economic, and reliability risks while offering minimal benefit to Texas ratepayers or the electric grid. We emphasize that EESFs do not generate electricity, are net consumers of power, and provide only short duration discharge capability—“limited to only 2–3 hours” — making them ineffective during extended outages.
The document further highlights the dangers associated with lithium ion battery technology, citing “thermal runaway, fires and explosions,” and noting that such fires “cannot be controlled nor extinguished” and release “extremely toxic and harmful chemicals” into the environment. HCESRPC has serious concerns about siting these facilities in the Texas Hill Country, an area “prone to frequent severe drought and to rapidly spreading wildland fires,” where rural volunteer fire departments lack the resources to manage large scale battery fires. The commission also points to the absence of adequate regulatory oversight, insufficient disposal rules, and the lack of required cybersecurity protections—particularly given that many systems use components “made in China” and are remotely operated.
Economically, the HCESRPC argues that EESFs depress nearby property values, create no long term local jobs, and provide only limited tax benefits. Meanwhile, the proposed rules would allow utilities to pass EESF costs—including guaranteed returns—to Texas ratepayers “without a single megawatt of new power being generated.” The document asserts that this approach “does nothing to fix the actual problem” of grid reliability and instead increases electricity costs for Texans.
The HCESRPC concludes that Texas should prioritize new dispatchable natural gas or nuclear generation located near major demand centers, rather than investing billions in EESFs. The commission warns that the proposed rules “add unwarranted risk to Texas citizens’ safety, health and welfare” and stem from policy decisions and market altering federal subsidies driven by “the former administration’s false climate crisis narrative.”