# APSC Docket 26-001-U — REDACTED Application and Minimum Filing Requirement Schedules (Doc. 47) The full REDACTED Application of [[Entergy Arkansas]] in the base rate case, filed 2026-02-27. **Despite the production-folder name "schedule-h," this is the comprehensive 2,476-page filing** — the Application narrative, the Cost of Service Study Summary (Schedule G), the rate-class revenue tables (Schedules H-1 through H-5), the proposed tariffs (Schedule H-10), and the supporting Minimum Filing Requirement Schedules A-1 through G-5.1, plus the test-year balance sheet, depreciation workpapers, cost-of-capital schedules, and the line-item Construction Work in Progress schedule (B-8). The headline rate-case ask is unchanged from the surface production: an **overall 1.92% / $44.6M increase**, with no rate change for Residential or Lighting and the bulk absorbed by Small General Service (8.12%) and a modest increase to Large General Service (1.21%). **But this production exposes line-item evidence that the rate-base includes transmission and storage projects explicitly named for the data-center sites under investigation — and that the base rate case is the proceeding deciding the depreciation rates of the GAJA Rider plants' transmission assets.** ## What's inside (by volume) The production is 9 PDFs corresponding to 9 volumes of the filing: - [[26-001-U Doc 47 Volume 1 Application and Schedules A-B]] — Vol. 1 (129 p.). The Application narrative (Schedule A-1) plus Schedule B-1 through B-10 (test-year and pro forma plant in service, accumulated depreciation, plant additions, and the line-item Schedule B-8 Construction Work in Progress). - [[26-001-U Doc 47 Volume 2 Schedules C]] — Vol. 2 (77 p.). Schedules C-1 through C-12. Statement of Utility Operating Income — rate-class revenue breakdowns at test year vs pro forma. - [[26-001-U Doc 47 Volume 3 Schedules D]] — Vol. 3 (72 p.). Schedules D-1.1 through D-7. Cost of Capital — the basis for the 9.90% ROE ask. - [[26-001-U Doc 47 Volume 4 Schedules E]] — Vol. 4 (433 p.). Schedules E-1 through E-17. Balance sheet, capital structure, deferred income taxes, plant ledgers. - [[26-001-U Doc 47 Volume 5 Schedules F]] — Vol. 5 (317 p.). Schedules F-1.1, F-1.2, F-1.3. Depreciation Information by FERC account. - [[26-001-U Doc 47 Volume 6 Schedules G]] — Vol. 6 (205 p.). Schedules G-1 through G-5.1. **The Cost of Service Study summary** — total company, retail, by rate class (Residential, Small General Service, Large General Service, Lighting, Wholesale). This is the schedule [[Class Cost of Service Study|Klucher's testimony]] builds on. - [[26-001-U Doc 47 Volume 7 Schedules H-1 to H-5]] — Vol. 7 (83 p.). Schedules H-1 through H-5. Summary of revenues by rate class — present vs proposed rates. **The arithmetic of the $44.6M rate-design proposal.** - [[26-001-U Doc 47 Volume 8 Schedule H-10 Proposed Tariffs]] — Vol. 8 (579 p.). Schedule H-10. The full clean-text book of proposed tariffs (Schedule of Rates and Terms of Service). - [[26-001-U Doc 47 Volume 9 Schedule H-10 Revision-Marked Tariffs]] — Vol. 9 (581 p.). Schedule H-10. The full redline (revision-marked) version of the same tariffs. ## Headline findings beyond what the surface production captured ### Data-center transmission projects in the rate-base CWIP [[26-001-U Doc 47 Volume 1 Application and Schedules A-B|Schedule B-8 (Volume 1)]] catalogs every individual project funding the test-year Construction Work in Progress. Buried in the 36-page transmission-and-production list are **line items explicitly named for the data-center sites under investigation**: | Line | Function | Project name | CWIP amount (test year) | Site | |---|---|---|---|---| | 485 | Transmission Plant | Gum Springs Land Acquisition | $50,361 | [[Project Pulse]] / [[DC Devco]] (Clark County) | | 492 | Transmission Plant | Avaio Digital Ctr-Instl 115kV | $283 | [[AVAIO Digital Partners|AVAIO Project Leo]] (Pulaski) | | 497 | Transmission Plant | Gum Springs: Bld 115kV SS | $485,601 | [[Project Pulse]] / [[DC Devco]] (Clark County) | | 505 | Transmission Plant | Gum Springs: Bld 115kV SwSub | $13,435 | [[Project Pulse]] / [[DC Devco]] (Clark County) | | 524 | Transmission Plant | Avaio Digital Partner LR Data | ($309) | [[AVAIO Digital Partners|AVAIO Project Leo]] | | 397 | Production Other | EAL West Memphis – BESS Install | $80,050 | [[Google LLC|Google Project Pyramid]] vicinity | | 404 | Production Other | EAL West Memphis – BESS Install | ($78,452) | (adjustment / placed in service) | | 396 | Production Other | Arkansas Cypress Solar North | $192,530 | [[Arkansas Cypress]] (GAJA Rider plant) | The transmission-plant items for AVAIO and Gum Springs are **explicitly named** for the data-center customers they serve, but their cost is being recovered through the base rate case's standard rate classes — not from the data-center customers themselves under a special contract. **This is direct line-item evidence that the public rate base embeds the cost of building transmission to serve hyperscale data centers**, even as the data-center revenue side stays sealed inside special-contract filings. ### The GAJA Rider plants' transmission assets are decided here, too Application Item 12(f) requests: "Approving the depreciation rates for the [[Ironwood]] CT, [[Arkansas Cypress|Cypress Solar and Battery]], and [[Jefferson Power Station]], **including the transmission assets for all three**, consistent with the recommendations of [witness Dane A. Watson]." The Schedule F (depreciation) workpapers therefore contain the depreciation parameters that determine the cost of those plants' transmission infrastructure flowing into all-customer rates. ### The mitigation logic — Residential gets a 0% increase The Application discloses (Item 10) that the strict cost-of-service result would have **Residential and Lighting customers paying more** ("the Residential and Lighting rate classes have a revenue sufficiency, i.e., Rate Schedule Revenue Requirement equals or exceeds Present Rate Schedule Revenues") and **Small / Large General Service paying less** (their present revenues already exceed their cost requirement). EAL is proposing the opposite of strict cost-of-service: hold Residential and Lighting at 0% and reallocate the Residential / Lighting surplus to Small General Service. The Schedule H-1 numbers — Residential 0%, Lighting 0%, SGS 8.12%, LGS 1.21% — are political mitigation, not strict cost-causation. ### The 9.90% ROE ask is below Entergy's own expert's recommendation Application Item 1: "[EAL] is making elections in this case that keep the rate effect low such as a return on equity ('ROE') of 9.90 percent, which is **lower than the ROE recommended by EAL's expert witness Adrien McKenzie**." So the requested 9.9% is itself an EAL-mitigated number; the witness recommended higher. ### Customer count detail Application Item 5: "As of December 31, 2025, the Company provided retail electrical service subject to the jurisdiction of the Commission to over 735,000 customers. Of these customers, **612,857 were residential, 100,900 were commercial, 23,702 were industrial and 949 were public agencies, institutions, or others.**" The 738,836 number used in [[Generating Arkansas Jobs Act (GAJA) rider|GAJA Rider]] disclosures is the rounded total of these. ### New witnesses surfaced by this filing The Application names the testimony filed concurrently. Witnesses with at least one substantive role: - **[[Adrien M. McKenzie]]** — ROE expert (recommended above the 9.9% Entergy is asking for) - **Ellen Lapson** — capital structure / financial integrity - **[[Dane A. Watson]]** — depreciation expert (sponsors the depreciation rates for Ironwood / Cypress / Jefferson + their transmission) - **[[Amy L. Morris]]** — capital additions / formula rate plan continuation - **[[Sarah Harcus]]** — pro forma adjustments, regulatory asset for rate-case costs - **[[Jay A. Lewis]]** — projected test period / formula rate plan history - **[[Jana K. Law]]** — Senior Counsel, Entergy Services, LLC (case attorney of record) - [[Matthew S. Klucher]] — cost of service / mitigation approach (already anchored) - [[Laura R. Landreaux]] — CEO direct (already anchored) - [[Caroline McNeal]] — rate-design tariff changes (already anchored) - [[J. David Palmer]] — depreciation / tariff withdrawal / filing-requirement relief (already anchored) Person pages for the new witnesses are deferred to a future ingest of their direct testimony filings. ## Procedural details - Notice of Intent filed: **2025-12-19** (last rate case was 15-015-U; ten-year FRP term ending). - Current authorized retail revenue requirement: **$1,277,230,243** (per the docket cover sheet; from Order in 15-015-U; total revenue requirement including riders is higher). - Retail revenue requirement requested: **$1,997,481,780**. - Proposed new and revised rate schedules to be effective with the first billing cycle of January 2027. ## People and orgs mentioned - [[Entergy Arkansas]] — applicant - [[Arkansas Public Service Commission]] — decisional authority - [[AVAIO Digital Partners]] — named in CWIP transmission line items - [[Google LLC]] — implicated via West Memphis BESS - [[DC Devco]] / [[Project Pulse]] — implicated via Gum Springs entries - [[Matthew S. Klucher]], [[Laura R. Landreaux]], [[Caroline McNeal]], [[J. David Palmer]] - New witnesses: Adrien M. McKenzie, Ellen Lapson, Dane A. Watson, Amy L. Morris, Sarah Harcus, Jay A. Lewis, Jana K. Law ## Concepts invoked - [[Cost-of-service study]] - [[Strategic Investment]] (depreciation of the GAJA Rider plants' transmission assets) - [[Generating Arkansas Jobs Act (GAJA) rider]] - Average and Excess Four Coincident Peak (A&E 4CP) cost-allocation methodology (Act 725) — not yet a wiki concept - Formula Rate Plan / Rider FRP — concept not yet anchored as a page ## Open questions / follow-ups - The Schedule G-1 column-by-class detail of the rate-base, revenue, and expense allocation deserves a deeper extraction — the Volume 6 schedule is the foundation of every cost-causation argument. - Schedule H-2 (Volume 7) shows the detailed per-tariff-component analysis (customer charge, energy charge, demand charge) at present vs proposed rates — opens the question of whether the demand charge on Large General Service captures any of the data-center load. - The CWIP line items for Avaio Digital Ctr and Gum Springs are **tiny relative to the actual transmission scope needed** for 1-GW data centers — the $283 / $13,435 / $485,601 are early test-year CWIP, not the full project commitments. The full project costs may appear in CECPN filings or in confidential workpapers. - The withdrawal of Rider PCA (Production Cost Allocation Rider) and the implied increase to Rider ECR is a tariff change worth detailing in [[Caroline McNeal]]'s testimony. - The proposed Formula Rate Plan 2.0 (FRP-2) — the renewal of the formula rate plan — is referenced but its terms are in [[Caroline McNeal]]'s testimony and Schedule H-10. - 25-043-R — the General Service Rules rulemaking — is referenced. Status?