12/5/25 Details of Toxics from the Moss Landing battery Fire

12/3/25 Recording of a good webinar on BESS

11/30/25 Older Article with lots of good basic details

Mark Jacobson from a county presentation

Lots of information and answers to public questions July 1 2025

New safeguards

SB283 (Laird) and NFPA 855

From Brian Roeder of Never Again Moss Landing 7/19/25

Risks

The B.E.S.S. risk: Profits are earned at the risk of public safety:

The risks of squeezing in every last drop of juice the BESS operator can collect

 An example of how corruption breeds within the B.E.S.S. industry can be seen in the management of the charge and discharge of the batteries in these B.E.S.S. facilities. Battery degradation and age can be tracked by its State of Health (SoH), which can be a measure of battery wear and tear. Once batteries degrade, they can pose heat and fire safety risks.  To avoid rapid degradation, manufacturers typically warrant that these batteries must be charged and discharged at levels below100% of capacity, leaving a buffer to avoid over-charging or too deep a discharge that can add extra heat to the battery and degrade it over time.

To maximize battery lifespan, large-scale B.E.S.S. facilities often operate within a narrower State of Charge (SoC) window (e.g., 10% to 90%, rather than 0% to 100%) to avoid the extreme ends of charge, which are more stressful for lithium-ion batteries. The precise window would be determined by the battery manufacturer and operator’s operational strategy, balancing performance with longevity.  If these parameters are incorrectly set or managed, a disaster such as Vistra’s can result.

Over time, exceeding these parameters damages battery parts, which can cause overheating or short circuits that subsequently cause the release of toxic gases, hot spot formation, and potential thermal runaway in the batteries. Thermal runaway can occur shortly into the battery’s projected lifespan.  While we do not yet know the cause of the Vistra disaster, their B.E.S.S.  was supposed to last 20 years.  It burned in less than five.

The impetus for over-charging and over-discharging these industrial scale batteries is obscene profits.  Exceeding SoC parameters by even a few percentages under the guise of meeting grid demand translates into tens of millions of dollars in net profits each day.  That is the fuel that feeds corruption. And the corruption is the under-regulation and over-use of these battery facilities.

Regulations

California has regulatory oversight of the BESS industry, and recent actions by the California Public Utilities Commission (CPUC) and other state agencies indicate a growing focus on safety and performance, which can indirectly relate to battery rates of charge and discharge: (C-rates).

While there may not be a single regulation that says, “this BESS must operate at a specific C-rate,” the regulatory framework, especially after recent fires, is moving toward comprehensive oversight that directly and indirectly impacts C-rates.  

NAML’s POSITION IS THAT REGULATORS MUST ACT MORE QUICKLY AND AGGRESSIVELY TO REQUIRE THAT C-RATES BECOME TRANSPARENT, REAL-TIME, AND INDEPENDENTLY MONITORED.  

WE HAVE COINED THIS CONCEPT AS “TRIM”

WHAT STATE REGULATORS ARE DOING FALLS FAR SHORT OF THE TRIM MODEL:

CPUC General Order (GO) 167-C: In early 2025, the CPUC adopted a major revision to General Order 167 to establish new maintenance, operation, and safety standards for all BESS facilities in California. This was a direct response to recent fires, including the one at Moss Landing.

  • How it Relates to C-Rates: GO 167-C requires BESS owners to create and submit comprehensive maintenance and operations plans. These plans must include details on how the system will be operated safely, which can include managing charging and discharging rates to prevent stress on the batteries. While not a direct C-rate limit, it indirectly addresses this metric through requirements and records that the CPUC’s Safety and Enforcement Division (SED) has the authority to audit, inspect, and investigate to ensure operators are complying with their approved plans. Failure to adhere to the plan can result in violations and sanctions from the CPUC.
  • Emergency Response and Reporting: GO 167-C also mandates that BESS facilities have an emergency response plan. A key part of these plans is understanding the risks of thermal runaway, which is heavily influenced by the C-rate at which batteries are charged and discharged.
  • Safety and Standards Organizations: California’s regulatory framework heavily relies on and enforces national and international standards.
    • NFPA 855: The National Fire Protection Association’s standard for the installation of stationary energy storage systems is a key part of the California Fire Code. NFPA 855 includes requirements for fire suppression systems, thermal management, and physical separation between battery containers. These standards are designed to mitigate the risks associated with high C-rate operations and the potential for thermal runaway.
    • UL 9540: This is a safety standard for BESS and is often a requirement for facilities to be approved for grid interconnection. It governs the design, testing, and operation of BESS and includes fire safety and thermal runaway testing. The C-rate is acritical parameter in these tests.
  • The California Independent System Operator (CAISO) also has a form of “oversight” related to C-rates, though it’s through market mechanisms rather than safety regulations.  This approach is called “Market Bidding”.  BESS operators bid into CAISO’s market, and their bids include the system’s capacity, duration, and other technical parameters. This indirectly reflects the system’s C-rate. A 4-hour system (high C-rate) is dispatched differently than a longer-duration 8-hour system (lower C-rate). CAISO’s rules determine how these systems are used to provide grid services.

The Moss Landing disaster has spurred California’s regulators to be more proactive in this area, shifting from a more hands-off approach to a more direct oversight model that mandates comprehensive safety and operational planning.

HOWEVER,…

TRIM IS NOT THE CURRENT APPROACH.  IT MUST BE.