BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ) OKLAHOMA GAS AND ELECTRIC COMPANY ) SEEKING A DECLARATORY ORDER FINDING ) DOCKET NO. 17-030-U ITS MUSTANG GENERATION PLANT ) MODERNIZATION PLAN IS CONSISTENT WITH ) THE PUBLIC INTEREST ) APPLICATION FOR DECLARATORY ORDER COMES NOW Oklahoma Gas and Electric Company (herein OG&E or Company ) and hereby files its application ( Application ) seeking declaratory order from the Arkansas Public Service Commission ( Commission ) finding that OG&E s decision to construct a natural gas-fired combustion turbine generation ( CT ) facility in the State of Oklahoma is consistent with the public interest. In support of this Application, OG&E states as follows: 1. OG&E is an investor-owned corporation organized under the laws of the State of Oklahoma. It is duly qualified to conduct business in the State of Arkansas as a foreign corporation. The Company is a public utility as defined by Ark. Code Ann. 23-1-101, et seq., and as such, is subject to the jurisdiction of the Commission. Its principal place of business is located at 321 North Harvey Avenue, Oklahoma City, Oklahoma 73102. A copy of the Company s Articles of Incorporation was filed with the Commission in Docket No. 15-034-U on May 8, 2015 and is incorporated herein by reference. 2. In the States of Oklahoma and Arkansas, OG&E engages in a general electric utility business of selling electric power and energy to its customers in its 1
Commission designated service area. OG&E s property consists of facilities for the generation, transmission and distribution of electric power and energy to its customers. OG&E provides electric service to approximately 811,000 total retail customers, of which approximately 65,800 are located in Arkansas. 3. OG&E is filing this Application pursuant to the Commission s authority enumerated in Ark. Code Ann. 23-2-301 and Rule 3.09 of the Commission s Rules of Practice and Procedure. Ark. Code Ann. 23-2-301 states that the Commission is vested with the power and jurisdiction, and it is made its duty, to supervise and regulate every public utility defined in 23-1-101 and to do all things, whether specifically designated in this act, that may be necessary or expedient in the exercise of such power and jurisdiction, or in the discharge of its duty. Therefore, pursuant to the Commission s power and jurisdiction enumerated in Ark. Code Ann. 23-2-301, the Company files this Application seeking the Commission s declaratory ruling and order finding that the OG&E Mustang Generation Plant Modernization Plan (as described below) is consistent with the public interest. 4. The Mustang Generation Plant Modernization Plan (the Modernization Plan ), in part, consists of the retirement of OG&E s existing gas-fired steam generation units located at its Mustang plant near the Company s major load center, Oklahoma City. Two of these units were retired at the end of 2015, and the Modernization Plan calls for the retirement of the remaining two units at the end of 2017. The Modernization Plan also calls for the replacement of the capacity of the current steam units with seven (7) natural gas-fired, quick start, combustion turbines ( CTs ) at the existing site. 2
5. All of the Company s existing Mustang steam units were brought into service in the 1950s and these units are some of the oldest steam generating units of their type and size operating in the United States. All of the Mustang steam units are well beyond the average life for these types of units. The retirement of the old Mustang steam units, and their replacement with the new quick start natural gas-fired CTs, allows OG&E to take advantage of a well-established Mustang plant site, with existing infrastructure in place, and to provide reliability benefits to OG&E s transmission system and the Southwest Power Pool. The selection of quick start CTs also complement the increasing wind resources on OG&E s system and the CTs will be better able to respond to the Southwest Power Pool Integrated Marketplace ( SPP IM ) market signals due to their capability to have multiple starts per day, and to also come off-line quickly when not needed. 6. Pursuant to Rule 3.04 of the Commission s Rules of Practice and Procedure, the following individuals should be placed on the official service as the persons authorized to receive notice on behalf of Oklahoma Gas and Electric Company: Lawrence E. Chisenhall, Jr. Barber Law Firm PLLC 425 W. Capitol Avenue, Ste. 3400 Little Rock, AR 72201 Phone: 501.372.6175 Fax: 501.375.2802 Email: LChisenhall@barberlawfirm.com Donald Rowlett Oklahoma Gas and Electric Company 321 North Harvey Avenue Oklahoma City, OK 73102 Phone: 405-553-3604 Email: Rowletdr@oge.com 3
WHEREFORE, for the above-stated reasons, Oklahoma Gas and Electric Company respectfully requests that the Commission issue its Declaratory Order finding that the Mustang Generation Plant Modernization Plan is consistent with the public interest, and for all other appropriate relief. Respectfully submitted, William Humes Senior Attorney OG&E ENERGY CORP. AND BARBER LAW FIRM PLLC 425 West Capitol Avenue, Ste. 3400 Little Rock, Arkansas 72201 Phone: (501) 372-6175 Fax: (501) 375-2802 By: /s/ Lawrence E. Chisenhall, Jr. Lawrence E. Chisenhall, Jr. (#74023) ATTORNEYS FOR OKLAHOMA GAS AND ELECTRIC COMPANY 4
CERTIFICATE OF SERVICE I, Lawrence E. Chisenhall, Jr., do hereby certify that I have served a copy of the foregoing instrument upon all parties of record via electronic mail this 15th day of August, 2017. _/s/ Lawrence E. Chisenhall Lawrence E. Chisenhall, Jr. 5