# J. David Palmer J. David Palmer is Vice President, Regulatory Affairs at [[Entergy Arkansas]] — Entergy's senior regulatory officer in Arkansas. He represents the Company on rate-case and rider matters before the [[Arkansas Public Service Commission]] and signs the Company's confidentiality affidavits. ## Role and affiliations Palmer joined Entergy Arkansas in 2001 at the System Operations Center in Pine Bluff as an engineer with North American Electric Reliability Corporation Certified System Operator certification. He has a Bachelor of Science in Electrical Engineering and an MBA from Mississippi State University (2001 and 2006), and is a Registered Professional Engineer in Arkansas. He moved to EAL's Distribution Operations Center in Little Rock in 2002, became an Area Line Supervisor in 2008, moved to Regulatory Affairs in 2012, was promoted to Manager (2014), Director (2017), and to his current position as Vice President in 2022. (Source: [[Palmer Rebuttal on Ironwood]] at pp. 2–3.) His listed prior testimony in regulatory dockets: Docket Nos. 16-027-R, 20-052-U, 87-166-TF, 16-036-FR, **25-055-P**, and 26-001-U. ## Appearances in the corpus - [[GAJA Rider 2026 Annual Update]] — signed the transmittal letter and Certificate of Service (Doc. 36, 2026-03-06). - [[Entergy CEO Direct Testimony]] — signed the Certificate of Service (Doc. 48, 2026-02-27). - [[Entergy Rebuttal Testimony on the GAJA Rider]] — Morey's rebuttal notes that Palmer separately addresses the APSC Staff's recommendation to exclude the Ironwood combustion turbine from GAJA Rider recovery. - [[Order No. 2 Interim Protective Order]] — Palmer signed the supporting Affidavit (EAL Exhibit A) on which Hunt's order rests; the protective order "specifically relies on the attestations included in EAL's Motion, and more importantly, the Affidavit filed by EAL witness Palmer." - **[[Palmer Rebuttal on Ironwood]]** — Doc. 68 in the GAJA Rider docket, filed 2026-04-20. The Company's substantive answer to [[APSC Staff Testimony on the GAJA Rider|Mark Herring]]'s Ironwood-exclusion recommendation. Argues that Ironwood meets the Strategic Investment definition under § 23-4-1303(10)(A)/(B)(i); that § 23-4-1304(w) makes pre-Act 373 CECPN applications (Ironwood's was filed 2024-11-01) eligible without a separate strategic-investment finding; that § 23-4-1304(f)(1)'s "at the election" language makes utility election the operative step; and that the Commission already recognized EAL's designation in Docket 25-049-TF Order No. 4 by directing bill-impact calculations on 2025-09-24. ## Role in T001 and T002 dialectics Palmer's testimony anchors the Statement A (utility) position in two of the wiki's three filed tensions: - **[[T001 - CIAC Classification of Google Generation Payments|T001]]** — [[Palmer Direct on the Google SRC]] is one of the Tier-1 sources cited by [[D001 Thesis]] for the Staff–EAL stipulation's "other form of payment" position on Google's generation-related payments under § 23-4-1304(x)(2)(B). - **[[T002 - Ironwood Strategic Investment Designation Requirement|T002]]** — [[Palmer Rebuttal on Ironwood]] is the primary anchor for both [[D002 Thesis]] and [[D004 Thesis]]. Notably, the antithesis in both dialectics pulled the § 23-4-1303(10)(A) chapeau text from p. 4 of Palmer's own rebuttal — and used it against his "per se inclusion" argument under (10)(B)(i)'s 100 MW threshold. The dialectic surfaced this as a construction-canon problem visible in the thesis's own primary source: Palmer's "election + transition" reading renders the (10)(A) chapeau's approval-pathway-plus-purposes-prong requirement surplusage. ## Notes Palmer's own direct testimony in the base rate case (Doc. 49 of 26-001-U) is referenced but was not retrieved this session.