## 2010 Primary Sulfur Dioxide (SO 2 

## )

National Ambient Air Quality Standard (NAAQS)

Technical Analyses and Information Supporting the Designation Recommendation for Oklahoma

OG&E’s Public Statements on Commitments to Meet EPA’s

Regional Haze FIP Requirements
Muskogee Generating Station: Conversion of Units 4 & 5 to Natural Gas Sooner Generating Station: Installation of Dry Scrubber s on Units 1 & 2

As Provided by Usha

- Maria Turner
, Director of Corporate Environmental

Oklahoma Gas and Electric Company

On July 7 , 20151



### OG&E’s Public Statements on the Conversion of Muskogee Units 4 & 5 to Natural Gas.

The U.S Environmental Protection Agency ( EPA) finalized requirements for certain coal

- fired units in Oklahoma under the Regional Haze program on December 28, 2011 1 . In that rule, EPA
took final ac tion in disapproving the 2010 State Implementation Plan (SIP) limit for sulfur dioxide ( SO 2 ) and established new limits ( rolling, 30

- day SO 2 emission limit of 0.06 lbs/mmBtu ) under a Federal Implementation Plan ( FIP ) for these units in Oklahoma including 4 owned and operated by OG&E: Muskogee units 4 & 5; S ooner units 1 & 2.

To comply with the Oklahoma Regional Haze FIP, OG&E plans to install Dry, Flue Gas Desulfurization systems (commonly called dry “scrubbers”) along with baghouse/fabric filter technology, on Sooner Units 1 and 2. While installing that same technology at Mus kogee Units 4 and 5 would meet the FIP’s SO 2 emission limits, OG&E plans to convert the boilers at Muskogee Units 4 and 5 from utilizing low sulfur coal to utilizing natural gas exclusively and will
meet the SO 2 limits by ceasing the combustion of sulfur

- c ontaining coal at these two units. 2

OG&E has made this commitment to gas conversion on Muskogee Units 4 & 5 in several public documents including:

1. 10Q filing before the Securi ties Exchange Commission (SEC) 3

.

“ On August 6, 2014, OG& E filed an application with the OCC for approval of its plan to comply with EPA’s MATS and Regional Haze FIP while serving the best long

- term interests of customers in light of future environmental uncertainties. The application seeks approval of the envir onmental compliance plan and for a recovery mechanism for
the associated costs. The environmental compliance plan includes installing dry scrubbers at Sooner Units 1 and 2 and the conversion of Muskogee Units 4 and 5 to natural gas. ”

2. Integrated Resource Planning 2014 Update 4 filing with the Oklahoma Corporation Commission (OCC) :

1 Federal Register. Vol. 76, No. 249. Wednesday, December 28, 2011 p 81728
2 Direct Testimony of Usha

- Maria Turner before the OCC, page 5. Available at http://imaging.occeweb.com/AP/CaseFiles/occ5129575.pdf

3 2 nd quarter 2014 10Q

. Com mission File Number: 1

- 12 579; August 7 th 2014

. The Company reiterated this plan in the subsequent quarterly SEC 10Q filings as well as in the annual 10K filed with the SEC on February 26, 2015. All filings available at http://phx.corporate

- ir.net/phoenix.zhtml?c=106374&p=irol

- sec

. 4 Integrated Resource Plan (IRP)

– 2014 Update; page 5. Filed August 6, 2014 with the OCC. Available at http://phx.corporate

- ir.net/phoenix.zhtml?c=106374&p=irol

- utilityreg2

“ OG&E takes very seriously its responsibility to provide reliable, reasonably priced power produced in an environmentally responsible way. This IRP reflects OG&E’s plan to meet fe deral mandates in a way that minimizes the impact on customers. Unfortunately, all alternatives available to the Company increase customer costs. After carefully considering all these factors, OG&E has decided to convert two coal

- fired units at the Muskoge e Power Plant to natural gas, add scrubbers to the coal

- fired units at the Sooner power plant, and other pollution control equipment ...”

3. Testimony of Usha

- Maria Turner filed before the Oklahoma Corporation Commission (OCC) cause number PUD 201400229 5

OG&E p lans to convert Muskogee units 4 & 5 to natural g as before the deadline of January 4,
2019 and OG&E plans to submit the permit application to the Oklahoma DEQ closer in time to
the need. Prior to the start of operation of these units on natural gas, the p ipeline supply to the facility has to be expanded in order to run these two units on solely natural gas.

5 Supra at 2