BACKGROUND West Memphis Utilities (WMU) is a municipal power utility serving the City of West Memphis.  The utility provides electric, water, wastewater, and fiber services to approximately 10,000 customers, and is governed by a 7-person board with oversight from the West Memphis City Council.  The General Manager reports directly to the mayor, and all other utility employees report to the GM.  The City Council approves the MWU’s budget and rates, otherwise, it is not involved in the operation of the utility. The city has a peak load of about 80 MW.  WMU owns 1% positions in Units 1 & 2 of the Independence Power Plant and Units 1 & 2 of the White Bluff Power plant.  MWU’s share of the coal plant production is about 32 MW.  In addition to this generation su