OGE · 10-Q · 2026Q1 · Full report

Good Neighbor FIP / Cross-State Ozone

OGE ENERGY CORP. · 2026-04-29 · Importance 71 · Surprise 60

The EPA finalized a Good Neighbor Federal Implementation Plan (FIP) impacting 23 states, including Oklahoma, that revises interstate NOx emissions budgets for electric generating units beginning in 2023. OG&E estimated in mid-2023 that compliance costs could range from $2.4 billion to $2.8 billion, including $100 million to $300 million of costs in the first 12 to 18 months after the FIP takes effect. OG&E is evaluating compliance options (allowances, SCR systems, fuel switching, retire/replace) and submitted its 2024 IRP to the OCC and APSC to evaluate alternatives. The rule and related SIP disapprovals are subject to active litigation and regulatory reconsideration (Supreme Court stay June 2024; D.C. Circuit abeyance April 2025; EPA Phase 1 reconsideration Jan 2026), so timing and recoverability of costs remain uncertain.

Key facts

• OG&E cannot determine the exact cost of compliance with the Good Neighbor FIP due to uncertainty surrounding SIP disapproval and FIP implementation and stated it plans to seek recovery of necessary environmental expenditures but cannot guarantee approval or timely recovery of all such expenditures.
• In January 2026, the EPA proposed its 'Phase 1' reconsideration of SIP disapprovals for several states but did not include the disapproved Oklahoma SIP in Phase 1, indicating Oklahoma would be addressed in a separate action.