Entergy Texas’ Application for the Orange County Gas Plant

Sierra Club
Project completed October 2022

Synapse provided expert support to the Sierra Club in reviewing Entergy Texas’s application for the Orange County Advanced Power Station, a 1 GW Combined Cycle Gas plant. Our testimony and analysis focused on whether Entergy has adequately supported its application with robust modeling and reasonable procurement process, to demonstrate that the proposed gas plant is the least cost option relative to alternatives. 

We found that the financial savings that Entergy Texas claimed the project would deliver were based on a faulty baseline and relied heavily on assumptions around aggressive industrial load growth in the region and that the plant would be a large supplier of market energy. We also found that, contrary to Entergy Texas’ claims, the gas plant would be “clean” because it is replacing a less efficient unit. In fact, the unit would substantially increase emissions relative to alternatives. We also found that the RFP process that resulted in the selection of the plant was limited and narrow in scope, and did not truly test the market for competitive alternatives.

We recommend that the Commission deny Entergy Texas’ application for the plant and require Entergy to issue an all-source RFP for replacement resources. Entergy Texas should then be required to perform optimized capacity expansion modeling with the results of the RFP to select the most economic portfolio of replacement resources.