# Ironwood Ironwood is a natural-gas combustion turbine generating resource of [[Entergy Arkansas]], one of three new resources whose construction cost flows into the 2026 [[Generating Arkansas Jobs Act (GAJA) rider]]. **Its inclusion is the central disputed question of [[psc/docket-26-008-tf-2026-05-22/_overview|Docket 26-008-TF]].** The disputed-recovery amount is approximately **$33.9 million** of the rider's $110.4M revenue requirement. ## How it appears in the corpus - **CECPN docket:** [[psc/docket-24-072-u-ironwood-2026-05-22/_overview|24-072-U]] (Certificate of Environmental Compatibility and Public Need). Application filed by Entergy Arkansas on **2024-11-01** — *before* Act 373 (the Generating Arkansas Jobs Act) was passed. The order granting the CECPN is Order No. 9 (Doc. 152, 2025-04-18), retrieved and ingested 2026-05-24 — see [[docket-24-072-u-order-9-2026-05-24/_overview|Ironwood Order No. 9 CECPN Grant]]. The original 2026-05-22 ingest covered a curated subset of the docket (the redacted Application, intervention/procedural Orders 1–5); the substantive direct/rebuttal testimony of Cunningham, Fielder, Cullipher, Ruiz, and Morris remain not retrieved. - **Strategic-investment dispute** ([[psc/docket-26-008-tf-2026-05-22/_overview|26-008-TF]]) — pressure-tested via the [[T002 - Ironwood Strategic Investment Designation Requirement|T002]] tension and twice-dialecticized ([[D002 Synthesis]], [[D004 Synthesis]] — both 2026-05-24). Current status: `bracketed-because-Commission-ruling-pending` (the corpus is complete; the question is committed to the Commission's interpretive judgment). - [[APSC Staff Testimony on the GAJA Rider|Staff (Mark Herring)]] argues Ironwood was never separately designated a "Strategic Investment" by the Commission and should be excluded from rider recovery. Excluding it cuts the rider's 2026 revenue requirement by ~$33.9M (from $110.4M to ~$76.5M). - [[Palmer Rebuttal on Ironwood|Entergy (J. David Palmer)]] argues § 23-4-1304(w) (the pre-Act 373 transition provision) makes Ironwood eligible without a separate strategic-investment finding, because its CECPN application was filed before Act 373; and that the Commission already recognized EAL's designation in Docket 25-049-TF Order No. 4 by directing bill-impact calculations. - [[D004 Synthesis|D004]] narrowed the live disagreement to a question of *minimum content* (what must an order say to count as a Strategic Investment designation?) rather than *categorical exclusion* (UFEEPA findings categorically cannot count) — [[Cypress Order No. 4 CECPN Approval]] demonstrates designation **can** ride inside a CECPN order; the question is whether Order No. 9's silence on the framework is dispositive. - **Filings cited but not retrieved:** - 24-072-U direct and rebuttal testimony of Cunningham, Fielder, Cullipher, Ruiz, and Morris (Entergy witnesses) — referenced in [[docket-24-072-u-order-9-2026-05-24/_overview|Order No. 9]] but their underlying testimony not separately ingested - 24-072-U Notice of Intent to Include in GAJA Rider, filed 2025-09-23 (per [[Palmer Rebuttal on Ironwood|Palmer]]) - 25-049-TF Order No. 4 (Palmer's "prior Commission recognition" anchor) — 25-049-TF docket not ingested at all - 26-008-TF hearing transcript (Doc. 74, 2026-04-29) — held physically at Commission Secretary's office via Veritext ## What is known, and what is not, from the public record | Field | Value in corpus | Source | |---|---|---| | Resource type | Natural-gas combustion turbine (simple-cycle); also designated **Lake Catherine Unit 5 (LC5)** | [[GAJA Rider 2026 Annual Update]]; [[Ironwood REDACTED Application]] | | CECPN docket | 24-072-U | [[GAJA Rider 2026 Annual Update]] | | CECPN application filing date | 2024-11-01 | [[Palmer Rebuttal on Ironwood]] | | Projected in-service date | 2028 Q4 | [[Ironwood REDACTED Application]] | | Installed capacity (MW) | **Net 446 MW** | [[Ironwood REDACTED Application]] | | Approved total cost | **Not in corpus** (Order No. 9 establishes a "benchmark project cost of $1,216/kW" found "reasonable and in the public interest" at Ordering ¶8, but full project cost depends on financing record) | [Ironwood Order No. 9](../sources/psc/docket-24-072-u-order-9-2026-05-24/_overview.md) | | 2026 rider revenue requirement share | ~$33.9M (per Staff exclusion analysis) | [[APSC Staff Testimony on the GAJA Rider]] | | Stated justification | **Federal consent-decree deactivation of LC4** (522 MW, in service 1970) by 2027-12-31 — *not* a data-center load justification | [[Ironwood REDACTED Application]] | | Site location | Lake Catherine facility, Hot Spring County (on EAL-owned property) | [[Ironwood REDACTED Application]] | ## Stakeholders [[Entergy Arkansas]] owns it; the [[Arkansas Public Service Commission]] approved the CECPN and will rule on the strategic-investment question; [[APSC General Staff]] disputes the rider inclusion; all 738,836 retail customers bear the cost if it remains in the rider. ## Notes The 2026-05-22 ingest of Docket 24-072-U filled the resource-specs gaps (capacity, site, in-service date) from the redacted Application and resolved the data-center-justification question: **the Application invokes the federal consent decree on LC4, not hyperscale load growth**, as the stated need. The 2026-05-24 retrieval of Order No. 9 closes the CECPN-grant gap — the order is now in the corpus at [[docket-24-072-u-order-9-2026-05-24/_overview|Ironwood Order No. 9 CECPN Grant]]. Crucially, Order No. 9 makes substantive findings on reliability and dispatchable generation but never invokes the Strategic Investment framework — Palmer's pp. 20, 25-26, 44, 53 citations to the order rely on UFEEPA findings the antithesis position ([[D004 Antithesis]]) argues cannot retroactively count as Act 373 designation findings. The substantive dispute is now bracketed pending the Commission's substantive ruling in [[psc/docket-26-008-tf-2026-05-22/_overview|26-008-TF]] — see [[T002 - Ironwood Strategic Investment Designation Requirement]] for the full tension record and twice-dialecticized analysis.