EO-2025-0235

The docket discusses multiple financial and timeline risks and concerns related to Ameren Missouri's resource planning:

Financial Risks:
- There is significant uncertainty regarding the addition of large new loads, especially data centers. If Ameren Missouri builds or buys new generation facilities assuming high data center load, but that load does not materialize, fixed costs will be spread over a smaller base, leading to higher levelized rates for customers. This could negatively affect affordability 1.
- Conversely, under-building generation could result in resource adequacy concerns, potentially risking reliability. Over-building can lead to unnecessary costs, again increasing rates and impacting affordability 1, 1.
- The calculation of levelized rates depends on the total revenue requirement divided by total load; if projected loads (like those from data centers) do not occur, levelized rates will be higher, creating a mismatch between forecasted and actual customer costs 1.

Timeline Risks and Concerns:
- The company has seen a rapid increase in potential data center interest, with up to 3 GW of aggregate potential peak demand and 1.8 GW under signed construction contracts. However, these loads are not yet guaranteed to materialize, adding significant uncertainty to planning timelines 1.
- The company is adjusting its resource plan in response to recent changes in energy efficiency program expectations and large potential new loads, highlighting the need for timely and flexible updates to its planning process 1, 2.
- Ameren Missouri is currently conducting further studies (e.g., a new demand-side resource market potential study and analysis of the GBX line) with deadlines such as October 1, 2025 for certain filings, but some stakeholders have expressed concerns that these analyses should have been completed or engaged with sooner 3.

In summary, the primary risks are:
- Financial: Over- or under-building generation due to uncertain load forecasts, leading to affordability or reliability problems.
- Timeline: Uncertain timing of new loads and the need for rapid adaptation of plans, with critical studies and analyses still underway or pending.

The main stakeholders identified in this docket are:

- Ameren Missouri (the utility making the resource planning filings)
- Grain Belt Express LLC (GBX), and its parent Invenergy Renewables, LLC (a developer and potential vendor of renewable projects)
- Missouri Public Service Commission (MPSC, the regulator)
- Various intervenors (not detailed by name in the excerpts, but generally includes parties that intervene in IRP dockets)
- State agencies (such as the Commission staff, Office of the Public Counsel, Division of Energy)
- Non-state agency entities and their employees (potentially including commercial parties, advocates, or consultants)

Stakeholder Positions:

Ameren Missouri:
- Defends its resource planning process and the sufficiency of its analysis under current IRP rules.
- Is not opposed to considering GBX/Invenergy projects if they prove beneficial in ongoing/planned analyses.
- Cautions against both under-building (risking reliability) and over-building (risking affordability).
- Has some concerns about reliance on certain demand savings projections, as previously questioned by the Commission and stakeholders 1, 1.

Grain Belt Express LLC (GBX) / Invenergy Renewables:
- Argues that Ameren Missouri should more thoroughly analyze and consider the GBX HVDC transmission line and associated renewable projects from Kansas.
- Claims these resources could serve Missouri’s needs better than other options.
- Seeks more immediate and detailed evaluation of its projects in Ameren’s planning process 2, 2.

Missouri Public Service Commission (MPSC) Staff:
- Expresses caution regarding Ameren’s reliance on certain winter demand savings projections, noting previous concerns about the reliability of these figures for resource planning.
- Does not make formal recommendations in the cited memorandum but urges careful planning to avoid both resource adequacy and affordability issues 1, 1.

Other Intervenors:
- Not explicitly named or their positions detailed in the provided excerpts.
- The excerpts suggest that most intervenors are not potential vendors, unlike GBX, which is noted as unique in this regard 2, 2.

Summary of Proposals and Support/Opposition:

- Proposal to Rely on Demand Savings Projections: Ameren Missouri has revised its outlook due to concerns raised by MPSC and stakeholders; staff remain cautious about continuing to rely on these projections 1, 1.
- Proposal to Explicitly Consider GBX/Invenergy Projects: GBX is strongly supportive; Ameren Missouri is not opposed but maintains such analysis is not required in the triennial IRP filing and is being done as part of a separate agreement. Staff and Commission have not taken a position for or against, but clarify that IRP rules do not require evaluation of specific vendor projects at this stage 2, 2, 2.

In sum:
- Ameren Missouri and GBX/Invenergy have differing views on how and when specific renewable projects should be considered.
- MPSC staff urge caution in resource planning, particularly regarding demand savings assumptions.
- No explicit opposition or support from other stakeholders is described in the excerpts.

Key events and submissions in this proceeding include:

- February 28, 2025: Ameren Missouri filed its notice of change in preferred resource plan (2025 PRP report) and a motion for protective order with the Missouri Public Service Commission (PSC) 1, 1, 1, 2.
- March 14, 2025: The PSC granted Ameren Missouri’s motion for protective order regarding highly confidential resource cost information 1, 3, 3, 3.
- May 14, 2025: PSC staff filed a memorandum with comments and concerns on Ameren Missouri’s notice of change in preferred resource plan 1, 1, 1, 1, 1, 1.
- May 27, 2025: Grain Belt Express filed a motion referring to deficiencies in Ameren’s 2025 PRP and requested the commission address those issues, incorporating arguments from the prior 2023 IRP proceeding 4.
- May 30, 2025: Grain Belt Express highlighted procedural issues regarding service of notice and requested the commission add parties from the 2023 triennial IRP to the current proceeding 5.
- June 6, 2025: Ameren Missouri responded to filings by Grain Belt Express, acknowledged violations of certain notice requirements, and discussed ongoing and future filings, including an upcoming analysis related to Grain Belt Express and a new triennial IRP to be filed in about 16 months (around fall 2026). Ameren also confirmed work was underway on the required analysis and scheduled further discussions for June 2025 6, 7, 6, 6.

Additionally, Ameren Missouri has started work on a new triennial IRP (expected to be filed about 16 months from June 2025) and is expected to file a specific analysis regarding the Grain Belt Express project before the end of 2025 6.

The docket identifies two primary areas of growth:

1. Data Center and Large Load Additions
- Ameren Missouri has seen significant growth in interest from potential data center customers, with aggregate potential peak demand of approximately 3 GW and signed construction contracts totaling 1.8 GW. Projections indicate large load additions (including data centers) are expected to add 500 MW to 2 GW of demand by 2032, and potentially 2.5–3.5 GW by 2040 1, 2.
- Key considerations:
- There is significant uncertainty regarding the timing and actualization of these load additions, as further steps such as tariff approvals remain.
- Ameren Missouri has developed contingency plans for a range of load growth scenarios, from as low as 500 MW to as high as 3.5 GW by 2040.
- A major risk is over-building generation resources if anticipated data center loads do not materialize, which could result in higher levelized rates (costs spread over less load) and affordability concerns. Conversely, under-building could create resource adequacy concerns if loads do materialize 1.

2. Changes in Company-Sponsored Energy Efficiency Programs (MEEIA)
- After the MPSC approved a stipulation that reduced program budgets to about $50 million annually, expected winter peak demand savings from energy efficiency programs have been substantially lowered—by about 300 MW by 2032 and 700 MW by 2043 compared to previous projections 1, 2.
- Key considerations:
- The reduction in expected demand savings reflects concerns from the MPSC and stakeholders about the reliability of energy efficiency savings for resource planning.
- Continued reliance on potentially overstated savings could exacerbate the risk of resource inadequacy or affordability issues if actual savings fall short of projections.
- Ameren Missouri is initiating a new demand-side resource market potential study to improve future forecasts and planning 1.

In summary, the docket’s main areas of growth are new large loads (especially data centers) and the evolving effectiveness of energy efficiency programs, each presenting significant planning uncertainties and risks relating to both adequacy and affordability of electric service.

This docket concerns Ameren Missouri's notice of a change in its Preferred Resource Plan (PRP), specifically as it relates to resource planning, demand savings assumptions, and the handling of commercially sensitive information. Key points include:

- Ameren Missouri filed to change its preferred resource plan, which affects the utility's future generation mix and resource adequacy planning. This filing triggered a request for a protective order to allow certain information to be designated as "highly confidential" and restrict its access, especially due to commercial sensitivities around generation costs and vendor pricing 1, 1.
- The company reduced its assumptions for winter peak demand savings by 300 MW by 2032 and 700 MW by 2043 compared to prior planning, due to concerns from the Missouri Public Service Commission (MPSC) and stakeholders about the reliability of those savings for resource planning. This adjustment stemmed from skepticism about relying on high levels of demand-side management savings, particularly those assumed in previous IRPs (Integrated Resource Plans) 2, 2, 2.
- The levelized rate calculations in the PRP depend on the total load and revenue requirement forecasts. Staff cautioned that if actual load is lower than anticipated but generation is increased, ratepayers could face higher rates, raising affordability concerns 2.
- The docket also addresses interventions and the handling of parties, with clarification that the IRP process is not intended to authorize or require utilities to buy from any particular vendor, and that evaluation of specific projects occurs during the implementation phase, not in the IRP itself 3, 3.
- Ameren Missouri is conducting further analysis on the value of resources delivered via the Grain Belt Express (GBX) high-voltage direct current line, as agreed in a previous stipulation. The results are expected in an upcoming annual IRP update, and additional resource needs will be addressed in future filings 3, 3.

In summary, this docket is about Ameren Missouri's updated resource plan, revised demand savings expectations, and procedural and confidentiality measures in handling sensitive planning information and stakeholder interventions.