OGE Energy : Direct Testimony of John Laws
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. ยง 286(C) AND RIDER COST RECOVERY )
Direct Testimony of
John P. Laws on behalf of
Oklahoma Gas and Electric Company
May 19, 2025
Direct Testimony of John P. Laws Page 1 of 9
John P. Laws
Direct Testimony
Q. Please state your name and business address.
A. My name is John P. Laws. My business address is 321 North Harvey, Oklahoma City,
Oklahoma 73102.
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Q. Please summarize your professional qualifications and educational background.
A. I have over 25 years of experience in executive leadership, with a proven track record in
corporate strategy, corporate finance, and corporate development to include negotiations
with counterparties on matters such as strategic commercial contract arrangements, asset
portfolio construction, capital formation and mergers and acquisitions.
Previously, I served in the Cabinet of Governor J. Kevin Stitt as Secretary of Budget
and State Chief Financial Officer. In this capacity, I advised Governor Stitt and his
administration on state policy, fiscal strategy, and legislative matters among other duties.
Prior to that role, I was employed by Enable Midstream Partners, LP, and its
predecessors, where I held several leadership positions, most recently as Executive Vice
President, Chief Financial Officer, and Treasurer. In that role, my responsibilities included
overseeing finance, treasury, accounting, external reporting, internal audit, investor
relations, and risk management functions.
Prior to Enable Midstream, I served as Director of Corporate Development at OGE
Energy Corp. In that role, I evaluated strategic alternatives for certain assets, developed
business strategies and negotiated asset acquisitions, including the OU Spirit wind
generation facility and the Redbud combined-cycle gas-fired power plant.
Earlier in my career, I had experience as a principal investor with Hunt Private
Equity Group, Inc., a Dallas, TX-based private equity firm, where I originated, evaluated,
and executed leveraged buyout and growth capital investment opportunities on behalf of
the firm. I began my career with Arthur Andersen LLP, where my duties included
performing valuation analyses for public and privately-held business interests.
I earned a Master of Business Administration from the McCombs School of
Business at The University of Texas at Austin and a Bachelor of Business Administration
in Finance from the University of Oklahoma.
Q. By whom are you employed and in what capacity?
A. I am retained by Oklahoma Gas and Electric Company ("OG&E" or "Company") as a
consultant. In my role as a consultant, I have assisted and advised OG&E with certain
elements of the 2024 All Source RFP process, specifically contract negotiations for
resources that were selected for further negotiations. I am also assisting the Company with
evaluating the terms pursuant to which new, extra-large load prospective customers may
be served.
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Q. Have you testified previously before this Commission?
A. No, I have not. 11
Q. What is the purpose of your testimony?
A. The purpose of my testimony is to describe the situation OG&E is facing today regarding
resource adequacy, certain considerations related to the addition of new, extra-large load
customers to the OG&E system, and a discussion of those considerations as it relates to
certain customers seeking service from OG&E. In addition, I will discuss the real-world
implications of the IRP and RFP processes today and explain why it would benefit all
stakeholders to evaluate some improvements in the future. 19
UNPRECEDENTED LOAD GROWTH AND CAPACITY NEEDS
Q. Please describe the situation OG&E is facing today regarding resource adequacy and
A. Based on OG&E's 2024 IRP and confirmed by the updated 2025 IRP Update Draft, OG&E
has significant generation capacity needs in the near term as well as the long-term planning
horizon. This is a continuation of a trend that was previously demonstrated in the OG&E's
2021 IRP. As described by Company witness Riley, OG&E is working to address its
capacity needs as quickly and efficiently as possible; however, SPP requirements continue
to evolve and unprecedented potential load growth from new, extra-large load customers
are expected to push OG&E's capacity requirements even higher. These developments
limit the effectiveness of short-term capacity purchases to satisfy what are emerging as
long-term resource adequacy requirements.
Later, I will highlight how OG&E is working with one extra-large load customer
("Customer X") that is included in the Company's current capacity need and one new,
prospective extra-large load customer ("Customer Y") that is not included in the
Company's current need for capacity as illustrative examples of these new customer
profiles. It is imperative that the Commission understands the weight and complexity of
OG&E's decisions with respect to serving these new customers, but also the potential
benefits that the new load growth presents to OG&E's customers and the state of
Oklahoma. OG&E makes each decision with the long-term benefits to its customers in
mind, and this case is no different. As OG&E steps into unprecedented new demand
growth from extra-large load customers, it must work to protect existing customers and
preserve a sustainable business model for the long-term benefit of all stakeholders. 12
Q. Does OG&E continually assess additional prospective loads that are interested in
A. Yes. The Company fields service requests from a wide variety of customers. OG&E is
experiencing an incredible shift in the size of the large loads requesting service in
Oklahoma, specifically from OG&E. As I understand, in the past, prospective customers
looking to locate in Oklahoma have been 50 MW or less with very limited exceptions.
These loads mainly were in the manufacturing and oil and gas industries.
The changes in recent prospective loads are unprecedented; both in the sheer size
and the volume of requests. In the last several years, I understand OG&E has seen requests
for loads in the hundreds or even thousands of MWs for a single customer. It is important
to note these prospective customers come from a variety of industries such as
manufacturing, refineries, federal, data centers, and crypto currency. Even if one industry
type slows down, the Company has other industries that still require additional resources
to serve.
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Q. What are the challenges to providing service to these prospective customers?
A. Due to the size and quantity of prospective customers as well as the Company's current
generation portfolio and capacity levels, it is difficult for OG&E to finalize agreements
with new large customers when it does not have line of sight to large generation capacity
additions. OG&E needs to partner with the Commission to expedite and facilitate
approvals of new generating capacity so that OG&E can meet this unprecedented load
growth. Without Commission approval on the Company's vision of how it should
approach these unprecedented loads, economic development in Oklahoma (and the job
growth and tax revenues that comes with it) could be expected to be hindered by delays in
the ability to provide electric service. 7
Q. What do extra-large load customers seek when they inquire about taking service from
A. Given that OG&E has some of the most competitive energy prices in the country as well
as a reputation for safe and reliable operations, its service area screens favorably for new
prospective large load customers relative to other energy markets. Following that initial
screening, the most important questions from prospective large loads looking to locate to
Oklahoma are when OG&E can serve them and at what cost. Some customers express a
need for power immediately, and some have ramp up schedules that OG&E can work with
to deliver the needed power over time. The Company is now having conversations with
potential new loads that could translate to a level of incremental electric demand that is
unprecedented for OG&E - loads it does not currently have the capacity to serve. This
leads to very much a "Chicken and Egg" problem - OG&E needs the capacity to bring the
load to Oklahoma, and it has historically needed the load to justify the need for capacity. 21
Q. Please further explain the "Chicken and Egg" scenario OG&E is facing.
A. The state of Oklahoma has been attracting new business investment that brings with it
large, new electric load. With OG&E being short on capacity, these new potential
customers will require significant generation and transmission investment as well as other
long-term financial commitments for the Company to provide electric service. Again,
OG&E needs commitments from prospective large load customers to acquire additional
capacity to serve them. On the other hand, prospective large load customers will not
commit to taking service from OG&E until it can demonstrate that it has, or will have, the
capacity to be able to serve them in a timely manner and the cost of service is reasonably
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.