OGE Energy : Direct Testimony of Kimber Shoop

Published: 2025-05-19 16:43:06 ET OGE

Published on 05/19/2025 at 16:43

IN THE MATTER OF THE APPLICATION OF )

OKLAHOMA GAS AND ELECTRIC COMPANY ) Case No. PUD2025-000038 FOR COMMISSION PREAPPROVAL OF NEW )

GENERATION CAPACITY PURSUANT TO ) 17 O.S. § 286(C) AND RIDER COST RECOVERY )

Direct Testimony of

Kimber L. Shoop on behalf of

Oklahoma Gas and Electric Company

May 19, 2025

Direct Testimony of Kimber L. Shoop Page 1 of 21

Kimber L. Shoop

Direct Testimony

Please state your name and business address.

My name is Kimber L. Shoop. My business address is 321 North Harvey, Oklahoma City,

Oklahoma 73102.

By whom are you employed and in what capacity?

I am employed by Oklahoma Gas and Electric Company ("OG&E" or "Company") as the

Director of Regulatory Affairs.

Please summarize your educational background and professional qualifications.

I earned a Bachelor of Arts degree in Government from the University of Virginia (1996)

and a Juris Doctorate from the University of Oklahoma College of Law (2002). I am a

member of the Oklahoma Bar Association, the Arkansas Bar Association, and the District

of Columbia Bar Association. After law school, I practiced law in Washington D.C. until

accepting the position of Senior Attorney at OG&E in 2006. In 2015, I was named

Managing Director of Law at OG&E. In 2017, I left OG&E to establish a private law

practice in Edmond, Oklahoma and continued to perform work for OG&E. In 2020, I

returned to OG&E as Director of Regulatory Policy and Planning before being named

Director of Regulatory Affairs in 2022.

Have you testified previously before this Commission?

Yes, I have.

INTRODUCTION

What is the purpose of your testimony?

The purpose of my testimony is to support the Company's request for relief in this

Application, which includes a request for Commission pre-approval of selected projects

from OG&E's 2024 All Source RFP. My testimony first provides some context for how

the selected projects fit into the Company's requirements for necessary generating capacity

to ensure reliable operations for our customers. Next, I discuss how OG&E identified the

projects requested for approval in this case, provide an overview of how and why resources

were selected from OG&E's 2024 All Source RFP, and describe the selected projects and

the timing of when they will come on-line. I also discuss the statutory basis for the

Company's request for pre-approval of the projects (i.e., 17 O.S. § 286(C)) and provide an

overview of the costs of the projects, the rider recovery requested in this case and the

estimated customer impact of adding these resources to OG&E's generation mix. Finally,

I introduce the other witnesses in this Case and the subject matter of their testimonies. 8

Q. Please explain in general terms what this case is about.

A. OG&E is in a situation where it must acquire additional generation capacity to meet

growing load and reserve requirements. As discussed by OG&E witness Kelly Riley,

OG&E's 2024 Integrated Resource Plan ("2024 IRP") showed a significant capacity need

and this need has only grown since its issuance last year. Below is a table that shows the

growing need by year under the 2024 IRP and the most recent need: 15

Table 1: Comparison of Need Between 2024 IRP and 2025 IRP Update Draft

Planning Source

2028

2029

2030

2024 IRP

1,096 MW

1,136 MW

1,215 MW

2025 IRP Update

1,083 MW

1,349 MW

1,647 MW

Last year, following the identification of capacity needs contained in the 2024 IRP,

the Company issued an all-source request for proposals ("2024 All Source RFP") to

identify capacity options available to OG&E as it meets that growing need. The projects

selected are the result of extensive analyses to determine what combination of resources

are the lowest reasonable costs to customers, are available when OG&E needs the capacity,

maintains a fuel diverse portfolio, and provides reliability and resiliency benefits to both

OG&E and the Southwest Power Pool, Inc. ("SPP"). The selected "Projects" (described

below) will add needed generation capacity through a balanced portfolio of renewable and

thermal resources and will include both the purchase of capacity from new and existing

generating resources through Capacity Purchase Agreements ("CPAs") and the

construction of new, incremental natural gas generation.

OG&E is asking the Commission, pursuant to 17 O.S. § 286(C), to affirm the

Company's need for generating capacity and approve the selected Projects as the lowest

reasonable cost options given the Company's capacity need, other reasonable alternatives

considered in the 2024 All Source RFP, the quantitative and qualitative RFP evaluation

criteria, and the Company's timing requirements for adding new capacity. 6

Q. Can you generally describe OG&E's 2024 All Source RFP?

A. OG&E's 2024 All Source RFP was very robust. The Company received 200 bids from 24

participating entities at 58 sites. The bids included a mix of Power Purchase Agreements

("PPAs"), Capacity Purchase Agreements ("CPAs"), and Purchase Sale Agreements

("PSAs"). OG&E also participated in the RFP through affiliate bids submitted in

conjunction with joint venture partners Sargent & Lundy, an engineering and design

company, and TIC - The Industrial Company, an industrial construction company.

After receiving and conducting threshold evaluations for RFP compliance, OG&E

analyzed and ranked the conforming bids by their qualitative and quantitative attributes as

set out in the RFP. The Company selected seven winners and began negotiations with

these selected bidders. Through the course of negotiations, several bidders either withdrew

from the RFP or significantly increased their bid pricing. These negotiations were

complicated by evolving tariff risk, supply chain issues, tax credit uncertainty, and high

demand for capacity, all of which made negotiations difficult. OG&E is still negotiating

with several bidders but has finalized contracts with three of the bidders and is requesting

pre-approval for those projects. 23

Q. Can you describe the projects OG&E is requesting pre-approval for in this case?

A. The three projects selected through the 2024 All Source RFP that OG&E is requesting for

pre-approval in this case (collectively, the "Projects") include:

Black Kettle Battery CPA ("Black Kettle CPA") - a new Battery Energy Storage

System ("BESS") project located near Woodward, Oklahoma. The project is

expected to reach commercial operation by June 1, 2027, and will be located on

OG&E's transmission system. OG&E selected the 20-year, 95 MW CPA offered

into the All Source RFP by Plus Power.

Kiamichi CPA ("Kiamichi CPA") - The Kiamichi CPA secures a portion of the

total capacity from an existing 1,200 MW natural gas combined cycle plant located

in Pittsburg County, Oklahoma from 2029 to 2034. The five-year CPA effective

4 June 1, 2029, to March 31, 2034, includes 300 MW for the first two years, growing

to 450 MW in the latter three years.

Horseshoe Lake Units 13 & 14 ("HL 13 & 14") - two new natural gas combustion

turbines ("CT") with a total capacity of 448 MW that will be constructed at

OG&E's existing Horseshoe Lake facility.

Q. Will these contracts satisfy the Company's capacity need?

A. No. Below is a breakdown of the need under the 2025 IRP update after the Projects are

added to the system over the next five years. As you can see, the Projects for which OG&E

seeks pre-approval in this proceeding are a critical step in addressing OG&E's significant

needs.

Chart 1: Adjusted Need by Year

OG&E will continue to negotiate with other bidders and explore other options for new

capacity over and above the Projects in this application.

Disclaimer

OGE Energy Corporation published this content on May 19, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 19, 2025 at 20:42 UTC.