Energy storage facilities will likely use the same battery chemistry most commonly used in electric vehicles today (lithium-ion). These battery chemistries have been known to catch fire. Once burning, water does not extinguish the fires; they must burn out on their own, which can take hours or days, depending on the scale.

Because of the extreme risks of lithium-ion fires that cannot be easily extinguished, small energy storage facilities should be forbidden in forested areas, mountain ridgelines or remote areas where these fires may easily become uncontrolled due to wind. The risk far outweighs the benefit.

The Proposed Small Energy Storage Facilities Permit by Rule should include an aspect of environmental safety which ensures catastrophic accidents at these facilities don't cause devastating environmental harm (forest fires and water pollution being merely two of many possibilities). And if by chance devastating environmental harm does occur from a facility, there needs to be a stated penalty equal to or greater than the total harm done.