The Arkansas Public Service Commission on May 29 rejected a May 1 request from Entergy Arkansas Inc. (EAI) to delay the filing of the utility’s next integrated resource plan (IRP) until certain power generation issues are worked out, including clean-air mandates affecting its coal-fired capacity.
The May 1 motion requested that the commission grant a one-year extension – beyond the currently-required Oct. 31, 2015 date – for EAI to file its next IRP.
EAI stated that several current and pending proceedings, which will be completed by the end of 2015, will greatly influence EAI’s incremental capacity needs and the supply-side and demand-side resources that may be available to address those needs. EAI said the resolution of these proceedings will provide a sounder foundation for EAI’s next IRP.
The first of these proceedings is an expected filing of a transitional energy efficiency program plan that will largely reflect the programs and budgets that EAI plans to include in its multi-year energy efficiency (EE) plan filing on June 1, 2016. EAI states that if this plan is approved by December 2015, then EAI will better understand the level of energy and demand savings that can be anticipated from the EE programs and therefore be better able to evaluate its energy and capacity needs.
EAI also identified two supply-side proceedings in which it currently seeks approval of the acquisition of long-term resources:
- a docket concerning acquisition of the 495-MW Power Block 2 of the gas-fired Union Power Station in El Dorado, Arkansas; and
- a docket concerning a long-term purchase power agreement (PPA) associated with an 81-MW solar energy project to be located near Stuttgart, Ark.
Because EAI requests commission decisions in these two dockets before the end of 2015, EAI will have more certainty in 2016 regarding its long-term portfolio of supply-side resources.
EAI also expects clarification later in 2015 of several environmental regulations that will materially influence the IRP. EAI indicates that a Federal Implementation Plan (FIP) relating to Regional Haze requirements for the coal-fired White Bluff Steam Electric Station, the coal-fired Independence Steam Electric Station and the gas-fired Lake Catherine power plant will be issued by Dec. 15, 2015. EAI also expects that in the summer of 2015, EPA will issue its final Clean Power Plan establishing carbon dioxide standards for existing sources pursuant to the Clean Air Act section 111(d).
EAI indicates that the State of Arkansas is under a deadline of Sept. 15 to provide to the U.S. EPA a proposed attainment designation for the one-hour sulfur dioxide (S02) National Ambient Air Quality Standard (NAAQS) for the areas around White Bluff and Independence. EAI also expects the EPA to issue a final revised ozone NAAQS by Oct. 1, 2015. EAI states that having more clarity on these rules will help inform reasonable assumptions regarding the operations and costs of EAI’s fossil-fueled generating units, particularly White Bluff, and potentially, Independence.
Said the commission in its May 29 decision rejecting the delay request: “In this case, the pending rate case and pending resource decisions do not provide good cause to delay the IRP because the decisions should be consistent with integrated resource planning, the IRP should further illuminate those decisions, and EAI chose the timing of those requested decisions. Further, delaying an IRP on this basis could set the precedent that utilities might seek a delay of future IRPs on the basis of various pending requests.
“Neither EAI nor the Commission can control the timing of new EPA rules. Even after issuance, such rules may be embroiled in litigation for months or years. It is in part because of such significant, but non-controllable contingencies that the IRP Guidelines require anticipation and exploration of a range of outcomes addressing exactly such contingencies. Further, the Commission is concerned that short timeframes for regulatory compliance could preclude the full examination of alternatives contemplated in the IRP Guidelines, thereby narrowing the range of reasonable responses.
“The Commission thus concludes that the short timeframe predicted for finalization of various EPA requirements is as much a reason to maintain the regular planning schedule as to delay it. Despite the greater clarity that may appear after certain regulatory deadlines this year, EAI has not filed a long-range IRP since 2009, and the IRP Guidelines allow for updates to reflect changed circumstances. These factors lean against a finding of good cause.”