Generation

As a stakeholder who has spent some time understanding the challenges of reaching net zero by 2050, I believe your modeling, which has only gone out as far as 2032, does not adequately provide a roadmap to your stakeholders, as well as to the board and executive team, current and future, as to how you will achieve net zero by 2050. In short, how can you get to where you want to go without a map? Your recent history doesn’t instill confidence in OPPD being able to achieve net zero by 2050 as evidenced by the fact that OPPD is building new fossil fuel infrastructure before fulfilling commitments to renewables and energy efficiency.

At the last board meeting I shared that I believe there needs to be additional interim metrics included in SD-7. What gets measured gets done. The 2026 closing of NOS is the first metric, and is rightfully included in SD-7. There are 24 more years in the countdown. What is the next trigger (metric) for a downturn in emissions? How many of you reading this will still be with OPPD in 5, 10, 15, or even 25 years? You’ve done the first step by acknowledging the need to work to net zero by 2050, for which I sincerely applaud you, but now you need to put the mechanisms in place so that your vision succeeds.

Growth in our community needs to be strategic. The likes of Google, Amazon, Facebook are only going to continue to see opportunity in locating data centres in Nebraska, as our energy is relatively cheap. OPPD’s ability to service growth, with the current (actual) renewable resource mix, is going to get more and more expensive if renewables don’t become a larger piece of the pie. I believe it would be beneficial for the board to be more involved in this process and have a say in approving large scale projects, on a project by project basis, rather than a blanket doubling of generation capacity, with no details of budgets or timelines.

Lastly, it appears from the 2.5GW increase OPPD management is seeking, with only 30 days from recommendation to approval, that you are not allowing the board time for due diligence or the public, for comment. Proposing such a large increase in generation capacity with such a short timeframe for board approval makes me wonder whether the executive team is really seeking qualitative board participation or just a rubber stamp. OPPD stakeholders will live with the ramifications of executive decisions long after the executive team is gone. I believe you should allow more time to allow the board to gather information and communicate with their constituents. The board must partake in crafting a resolution that accurately aligns with the wants of the stakeholders who elected them.

By reporting on stated decarbonization benchmarks as well as allowing more time for feedback, OPPD will be acting more like the public utility that it is.

I am very concerned about any incremental fossil fuel burning to meet our energy needs. That is the easiest thing to do of course, but it's a terrible idea to react to climate change-driven extreme weather events by burning more fossil fuels. You are only making the problem worse in the long-run. It is very disappointing to see OPPD not making progress at the pace it needs to for net-zero carbon commitments. This was even a topic in recent elections and it appears that some are not following through on campaign statements.

Also, while I understand that data centers provide jobs and tax revenue, these are large corporations that have Net Zero commitments. They most certainly should be expecting their energy to come from renewable energy sources, not fossil fuels. And if they are living up to their publicly stated commitments, then they should be supporting OPPD only using renewable energy for incremental requirements.

Please reject this proposal and shift your reliance to renewable energy sources.

Why doesn't OPPD have a separate rate class for data centers? Data centers have little in common with the industrial and commercial classes. Moreover, I doubt the industrial and commercial classes are demanding high cost and unreliable solar and wind energy. The data centers are the only class of customers that want to virtue signal. Moreover, Facebook and Google are two of the most profitable companies on the planet. Make them pay for their virtue signaling.

The OPPD Board needs to be equitable and fair to all customer classes.

David D. Begley
Customer-owner

OPPD's *estimate* of a 10% rate increase is based upon a pro forma. OPPD is a political subdivision of the State of Nebraska. This pro forma should be released to the public. I'm especially interested in the number associated with the cost of carbon capture for the natural gas plants at North Omaha, Standing Bear and Turtle Creek.

David D. Begley
Customer-owner

Per the OWH story of May 26, 2023, Google and Facebook are the customers demanding net zero carbon power; not residential customers. Moreover, the data centers are the ones growing the most and creating the most demand for new electricity.

OPPD already has different rate classes for different customers. Why in the world are residential customer-owners footing the bill and subsidizing the corporate fat cats at Google and Facebook? How in the world is this *equitable* or fair?

Don't crucify OPPD residential ratepayers on a cross of wind turbine blades!

Nebraska is the Cornhusker State; not the Chinese solar panel state!

As one of your constituents, I write to STRONGLY OPPOSE this OPPD plan. It has come to my attention that as much as 2/3rds of the growth in demand cited in the plan is coming from not from new households, but from new and/or expanding data centers, which are, in most cases, allegedly pledged to be "carbon-neutral" by 2030. There is something very fishy (greenwashing) going on here! In addition, OPPD continues to ramp up fossil-fuel burning projects while putting wind, solar, and other renewable options on the back burner, despite promises to the contrary. With fossil fuel burning plants debt-financed for 30 years and constructed into the early 2030s, their expected use will extend beyond the 2050 net zero commitment.

Like the keeping online of the North Omaha Power plant after its promised decommission, this is yet another instance of OPPD ignoring the will of its constituents and thinking short term instead of long term. OPPD cites more extreme weather events as part of the reason for needing to expand its energy capacity. Think about what is CAUSING this increase in extreme weather events? This is insanity. You cannot address a problem by continuing to do the very thing that is causing the problem.

I urge the OPPD board to VOTE NO on this short-sighted proposal, and to take a broader perspective on Omaha's energy usage and needs with a clear eye to actually meeting the 2050 net zero commitment goal--not fudging the numbers as needed to make it look as if you will in order to make the key players feel better about themselves and the damage they are causing for future generations. OPPD will claim--as they did with the prolongation of the North Omaha plant--that there is simply no other way. Somehow that justification is always accepted when it comes from power players and moneyed (short-term) interests, but not when it comes from constituents. We must do everything we can to protect our environment and our future now, even if it causes some short-term headaches, like limiting power on peak usage days, or forcing data centers to make good on their pledges for carbon neutrality. In this instance, if we wish for our grandchildren to inhabit a livable city, there really is no other way.

Jacob Rump
Omaha

I am highly concerned about the Near Term Generation Proposal, announced May 16. With thermal energy sources included in the proposal, it seems quite certain that OPPD's energy portfolio will generate increased greenhouse gas emissions. This of course will make it even more difficult to achieve 2050 Net Zero carbon emissions as detailed in SD-7. This Near Term Generation Proposal should not be approved by the board until OPPD can demonstrate how it plans to also reduce emissions to reach Net Zero status. This demonstration should include a plan to measure and report on progress towards that goal on a regular basis between now and 2050.

I request that the Board rejects the current version of the Near Term Generation Proposal. I understand the need to increase load capacity, but it appears that this proposal will increase carbon emissions and make it even more difficult to achieve 2050 Net Zero carbon emissions as detailed in SD-7. If that's an incorrect interpretation, please make provide interim metrics that show how OPPD will execute against the Net Zero 2050 goal. Otherwise, please make revisions to the Near Term Generation Proposal to include less fossil fuel use and more renewables to keep OPPD on track to meet Net Zero 2050. Both goals - increased load capacity AND reduced carbon emissions - can be achieved. Thank you.
TBS

The Near Term Generation Proposal appears to be ignoring the emissions reduction goal as detailed in your Pathway to Decarbonization and set out in Strategic Directive-7. I request that this proposal should be reworked to include a significant increase in renewables to keep OPPD on track to reach the net zero 2050 target and to counteract the additional emissions that will result from the increase in gas and fuel oil.

The current Near Term Generation Proposal will make meeting OPPD'S 2050 net zero decarbonization goal nearly impossible. This plan takes OPPD off trajectory to meet net zero by 2050. Is OPPD ignoring their own Power With Purpose Study? OPPD needs to be held accountable to their own committed goals. What are the interim metrics to getting to net zero by 2050? It seems OPPD needs to back to the drawing board and come up with a way to show how they are going to decrease emissions. JHG

This Near Term Generation Proposal is not adequate to meet the environmental goals ratepayer-owners and voters support as shown through Board elections since 2016. OPPD has an environmental goal of Net Zero by 2050 and Power with Purpose studied how to get to that goal in an economic manner.

OPPD’s 2021 Integrated Resource Plan indicated that the pathways to Decarbonization highlight a minimum incremental investment in 1,100MW of solar, 500 MW of wind, and 150 MW of energy storage resources by 2030.

The numbers proposed in the Near Term Generation Proposal are 1,000-1,500 MW of renewables total and ‘Up to 125MW’ of storage. These fall short of the “minimum” incremental investment planned during the Power with Purpose study. Additionally, the duel fuel combustion turbine of 600-950 MW will add emissions.

These proposals are not acceptable in my opinion. There needs to be a balance between rates and environmental impact. As of 2022 ended, OPPD rates were 19.4% to 28.8% below the national average. Emissions should also be 19.4% to 28.8% below the national average. OPPD is nowhere near 20% below the national average in emissions. In fact, every measure I see OPPD is ABOVE the national average in emissions and ranked in the bottom half of states for environmental impacts.

Please make revisions to include less fossil fuel build out and more renewables to keep OPPD on track to meet Net Zero 2050 targets. There must be a balance between environmental impacts and rates. Please include the costs to our community in your analysis if needed – flooding, drought, health impacts via air quality and heat related illness some of the costs that our community will bear from more fossil fuel generation. These emissions are not free to our ratepayer owners and voters.

A study by Brattle Group (who did the study supporting OPPD raising the residential fixed fee) just published a study on Virtual Power Plants (aggregations of customer-owned resources, which could include EVs, energy storage, rooftop solar, smart thermostats, and appliances that can be turned off at peak times) and how Virtual Power Plants (VPP) can help us meet resource adequacy needs at a much lower cost and with more societal benefits than building new gas plants. Why does this plan from OPPD only include 30 MW of demand response and no plan for a virtual power plant?

Key takeaways from the VPP study:
- Real reliability: A VPP leveraging commercially-proven residential load flexibility technologies could perform as reliably as conventional resources
- Cost savings: The net cost to the utility of providing resource adequacy from a VPP is roughly 40–60% of the cost of the alternative options; 60 GW of VPP deployment could meet future US resource adequacy needs at $15–$35 billion less than the cost of the alternative options over the ensuing decade
- Additional benefits: 60 GW of VPP could provide over $20 billion in additional societal benefits – such as those related to emissions and resilience – over ten years
https://www.brattle.com/insights-events/publications/real-reliability-the-value-of-virtual-power/

This proposal calls for 50-75% of solar and wind. Before that is built, a county will have to approve. That's a giant IF. If the counties don't approve of the projects, the entire plan collapses.

That's a giant risk. OPPD needs to hedge that possibility. I will tell the Board how to hedge on May 18, 2023.

David D. Begley
Customer-owner

A plan that is more expensive and less efficient than just building a new nuclear plant. The OPPD management team is not working to make our power generation clean and reliable and is instead selling us out by investing in unproven and inferior technologies. Get a clue OPPD-nuclear works!

FAQ, "While exact numbers are yet to be determined, increases could range from 2.5 to 3% each year from 2027 to 2030, totaling 10-11% by 2030."

I want to see that pro forma. I think it is very wrong. My question: What if this estimate is wrong? What if rates go up by 30% by 2030? 50%? That's a big miss. And who pays if this estimate is wrong? OPPD's customer-owners.

Considering the current price of natgas, any additional generation should be with a new natgas plant. Think about putting it at Ft. Calhoun. I have one caveat to this recommendation. How much it will cost to build a new natgas plant if the EPA can force OPPD to use unworkable carbon capture technology? It has never worked!

Additionally, from what I've seen about the increase in prices for solar panels and interconnect costs, the supply-demand equation for solar favors the sellers. The ChiComs have a monopoly on the supply of solar panels. That means higher prices. I think your estimate is very low.

David D. Begley
Customer-owner

OPPD appears to be on track to spend over $2b by 2030 on solar, wind and storage. I'll remind you that E3, Inc. said it would be necessary to spend at least $28b by 2050 to achieve net zero carbon. OPPD has only $1b in revenue. You just borrowed $420m in September 2022.

The number one duty the elected directors of OPPD owe to its customer-owners is to produce and distribute reliable and inexpensive electricity. Solar and wind are unreliable and expensive. I emphasize the word "duty." This is serious business and $2b in capex is twice your current revenue.

A problem you've ignored is the local opposition to more wind and solar in Nebraska.

The Center for the American Experiment has concluded that if Minnesota and Wisconsin achieve net zero carbon, it will triple electric rates and cause blackouts in the winter. I'm confident we'd see the same result in Nebraska. This, frankly, would be a disaster for Nebraska and people will die.

The directors must put aside their magical thinking about wind, solar and batteries and focus on the *cruel neutrality* of what net zero carbon means. It means that Nebraskans would see triple electric rates and it would do nothing to save the planet. Go bother China and India about their coal-fired power plants if OPPD wants to lower temps in 2100.

On Thursday, I will be presenting a proposed resolution to the Board that would be in the best interests of OPPD customer-owners. It is completely the opposite of this plan. Here's a hint. OPPD will spend $650 million on Standing Bear and Turtle Creek Stations and the EPA wants to force you to spend millions more and they aren't even on-line yet.

David D. Begley
Customer-owner

BTW, news out today. Interconnect costs have gone up 400% and the delays are much worse than first thought.

It's apparent to me that OPPD needs to permanently continue to use all forms of existing electricity generation for the next 10 years, which includes generation of electricity using coal. You've mentioned growth and supply chain headwinds that will impact new renewal sources. We are susceptible to extreme weather conditions in Midwest and must have "hardened" generation of electricity that is not exposed and susceptible to major damage from tornadoes, hail, and extreme winter storms. It would be nice to know the recovery time if, for example, a major solar farm is damaged from a catastrophic hail storm and tornado. We cannot have people suffer in their homes during hottest or coldest times of the year. Renewable forms of electricity generation are fine, but it's no consolation for lack of electricity or brown-out situations that could take place due to increased reliance on solar or wind generation. California is experiencing this issue now with insufficient capacity and higher rates for their ratepayers. Industrial battery technology is the capacity OPPD projects, what is the contingency plan if the technology is not available? Also, OPPD mentions the rate increases that will be required, this will affect everyone and raise costs for everything that requires electricity. Companies will pass the additional costs on to their customers.

Comments regarding near term generation recommendation will be posted here