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Entergy Texas, Inc.'s Application to Amend its Certificate of Convenience and Necessity Undermined by Flawed RFP Process

Strategic Insights

— 2 min read

The Office of Public Utility Counsel ("OPUC") has submitted a post-hearing initial brief to the State Office of Administrative Hearings, arguing that Entergy Texas, Inc.'s ("ETI") application to amend its Certificate of Convenience and Necessity is fundamentally flawed due to the absence of a comprehensive Request for Proposals ("RFP"). This shortcoming is reflected in the estimated costs for the requested facilities, which are unreasonably high and lack the competitive discipline necessary to ensure that customers receive reliable service at the lowest reasonable cost.

Key Takeaways:

  • ETI's failure to issue a comprehensive RFP undermines the competitive process that protects consumers and ensures that the utility submits the most economical resource options that best address its capacity and energy needs.
  • The estimated costs for the requested facilities are unreasonably high, with a combined total of $655.4 million for the Segno and Votaw Solar Facilities, which have a nameplate rated capacity of 170 MW and 141 MW, respectively.
  • The projected cost per MW based on accredited capacity is high for the Renewable Portfolio, with an estimated cost of $835 per kilowatt (kW) for Segno and $1,145 per kW for Votaw.
  • ETI's proposal lacks the competitive discipline necessary to ensure that its customers receive reliable service at the lowest reasonable cost, and the utility's self-build resource proposals do not incentivize the most economical resource option or diligent estimation of costs.
  • The Commission has consistently considered the factor of probable improvement of service or lowering of cost to consumers when determining if a CCN application is in the public interest.
  • OPUC recommends certain regulatory commitments to protect customers if the Public Utility Commission of Texas decides to approve this request.

Statistics:

  • The Enterprise Texas, Inc. Application to Amend its Certificate of Convenience and Necessity to Construct Generation Facilities in Lamb County, Texas and Lea County, New Mexico; for Good-Cause Exceptions; and for Related Relief, Docket No. 55255, Order on Rehearing at FoF 103-113, (Nov. 21, 2024) reports that the estimated costs for the Segno and Votaw Solar Facilities are $351.6 million and $303.8 million, respectively, for a combined total of $655.4 million.
  • The average projected summer accredited capacities for the first nine years of the Renewable Portfolio's operation are 213 MW and 141 MW, respectively.
  • The projected cost per MW based on accredited capacity is $835 per kilowatt (kW) for Segno and $1,145 per kW for Votaw.

Sources:

  • Entergy Texas, Inc.'s Application to Amend its Certificate of Convenience and Necessity to Construct Generation Facilities in Lamb County, Texas and Lea County, New Mexico; for Good-Cause Exceptions; and for Related Relief, Docket No. 55255, Order on Rehearing at FoF 103-113 (Nov. 21, 2024).
  • Entergy Texas, Inc.'s Application to Amend its Certificate of Convenience and Necessity, filed on May 19, 2025.
  • Direct Testimony of Evan D. Evans, OPUC Ex. 1 at 21:5-8.
  • ETI Ex. 1 at 5.
  • ETI Ex. 1 at 4.
  • OPUC Ex. 1 at 21:11-14.
  • OPUC Ex. 4.

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