# 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 was the central disputed question of [[psc/docket-26-008-tf-2026-05-22/_overview|Docket 26-008-TF]] — resolved in Entergy's favor by [[Order No. 7 Approving the GAJA Annual Update|Order No. 7]] (2026-06-04)**, which found "Ironwood qualifies as a strategic investment under Ark. Code Ann. § 23-4-1303(10)" (p. 22). The disputed-recovery amount — approximately **$33.9 million** of the rider's revenue requirement (revised to $109,977,691) — stays in the rider and on customer bills. ## 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). **Resolved 2026-06-04: [[Order No. 7 Approving the GAJA Annual Update|Order No. 7]]** held no prior designation finding is required for a § 23-4-1304(w) transition facility and made the § 23-4-1303(10) qualification finding itself (T002 status: `resolved-via-Order-No-7`). - [[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; AVAIO's ESA description gives "November 2028" — its mandatory curtailment (MISO LMR Type 1) runs "until the Ironwood CT is online" | [[Ironwood REDACTED Application]]; [[AVAIO Tier 4 Equivalent Email to the Commerce Secretary]] | | Installed capacity (MW) | **Net 446 MW** | [[Ironwood REDACTED Application]] | | Total cost | **$700,167,388 estimated** against a **$542,336,000 Commission benchmark** (Tier-1, per Entergy's Order No. 6 report; Order No. 9 separately establishes a "benchmark project cost of $1,216/kW" found "reasonable and in the public interest" at Ordering ¶8) | [[Entergy Order No. 6 Response]]; [[docket-24-072-u-order-9-2026-05-24/_overview|Ironwood Order No. 9 CECPN Grant]] | | 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 ruled on the strategic-investment question on 2026-06-04 ([[Order No. 7 Approving the GAJA Annual Update|Order No. 7]], in Entergy's favor); [[APSC General Staff]] disputed the rider inclusion; all 738,836 retail customers bear the cost, which 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 was resolved 2026-06-04 by [[Order No. 7 Approving the GAJA Annual Update|Order No. 7]] in [[psc/docket-26-008-tf-2026-05-22/_overview|26-008-TF]]: the Commission held that no prior designation finding is required for a § 23-4-1304(w) transition facility and made the § 23-4-1303(10) qualification finding itself inside the order — mooting, without adjudicating, the D002/D004 question of whether Order No. 9's UFEEPA findings could count as designation. T002 status is `resolved-via-Order-No-7` — see [[T002 - Ironwood Strategic Investment Designation Requirement]] for the full tension record and twice-dialecticized analysis.