# Attorney General Testimony on the GAJA Rider The Direct Testimony of [[Greg R. Meyer]], a public-utility regulation consultant with Brubaker & Associates, Inc., testifying for the [[Office of the Arkansas Attorney General]] (Doc. 63, filed 2026-04-14) in [[Entergy Arkansas]]'s [[psc/docket-26-008-tf-2026-05-22/_overview|Docket 26-008-TF]]. It is the ratepayer advocate's critique of the [[GAJA Rider 2026 Annual Update]] — and it argues Entergy is overcharging customers for the cost of financing the new generation. ## What's inside Two files: `26-008-TF_63_1.pdf` (Meyer's testimony, 11 pp) and `26-008-TF_63_2.pdf` (the appendix and verification, 4 pp). Meyer addresses only one issue — the capital structure used to set the return on Construction Work in Progress. ## What the GAJA rider does, per the Attorney General > "GAJA was an act signed into law by Arkansas Governor Sarah Huckabee Sanders on March 20, 2025. Its purpose was to establish a mechanism for Arkansas utilities to recover the costs of new generation infrastructure outside of a general rate proceeding. It was designed to incentivize utility construction of 'strategic investments.'" (p. 5) Meyer notes the statute lets the Commission authorize recovery "between rate cases, including allowing a return on CWIP" (pp. 5–6). ## The Attorney General's objection — the financing cost is overstated Meyer's core argument is that Entergy used an unreasonably low short-term-debt balance, inflating the return charged to customers on $1.24 billion of CWIP: > "However, the Company has relied on an extremely low short-term debt balance from the Company's last Formula Rate Plan that will overstate the return for CWIP assets." (p. 6) > "First, in the Company's authorized ROR calculation in Docket No. 16-036-FR, only $61,596 of short-term debt is included. For a formula rate plan, where CWIP is excluded from rate base, this makes sense. However, when financing $1.24 billion of CWIP, and including it in rate base for purposes of this rider, merely including $61,600 of lower-cost short-term debt is unreasonable." (p. 7) Meyer frames it as a captive-customer protection issue — "Customers have no choice in their utility provider and should be protected from inflated costs" (p. 8) — and points out that Entergy's parent, Entergy Corporation, carries roughly $658 million of short-term debt that lower-cost financing could draw on (p. 8). He argues the return on CWIP "would generally mirror the AFUDC rate, because customers are essentially covering the financing upfront" (pp. 8–9). His recommendation: "the Commission should mandate that EAL procure lower-cost, short-term debt to finance these strategic investments" (p. 10). He states the resulting savings cannot be precisely quantified on the record (p. 9). Like the Entergy and Staff filings, the Attorney General's testimony treats the cost as falling on retail ratepayers generally; it does not argue that data-center or large new-load customers should bear the new-generation cost. ## People and orgs mentioned - [[Greg R. Meyer]] — consultant, Brubaker & Associates, Inc.; the witness. - [[Office of the Arkansas Attorney General]] — Meyer's client; Attorney General Tim Griffin. - [[Entergy Arkansas]] — the applicant utility. - [[Matthew R. Morey]] — Entergy witness whose filing Meyer reviews. - Entergy Corporation — Entergy Arkansas's parent. (Plain-text mention.) ## Concepts invoked - [[Generating Arkansas Jobs Act (GAJA) rider]] — Meyer's testimony concerns the return on CWIP the rider allows. ## Events documented - [[2026-04 APSC Staff and Attorney General Contest the GAJA Rider]]. ## Cross-references - [[GAJA Rider 2026 Annual Update]] — the Entergy filing being contested. - [[APSC Staff Testimony on the GAJA Rider]] — the Commission Staff's parallel critique. - [[Entergy Rebuttal Testimony on the GAJA Rider]] — Entergy rejects the short-term-debt argument. ## Open questions / follow-ups - Meyer says the customer savings from his recommendation are unquantifiable on the current record; the eventual Commission order resolves the dispute.