Strategic Directive 7: Environmental Stewardship (2024)

SD-7 will be significantly improved by recognizing the principle of Environmental Justice in your decision making. This should include just treatment considering both harms and benefits. The actual implementation of this principle requires establishing more supporting metrics, carrying out those measurements, and making adjustments if OPPD falls short of interim goals. It is particularly important that energy and air pollution burdens of lower income customer-owners is recognized in billing practices and the availability of energy conservation measures.

The same is true in considering climate change. It is good that this is recognized as a significant issue requiring net zero carbon emissions by no later than 2050. While the means for achieving this rely to some extent on future technologies, there is a need for more interim metrics than a single goal in 2027. It is apparent that the carbon emissions trajectory is already diverging from the goal by the addition of energy-hungry industries attracted by disproportionately low rates, at the cost of system resilience and higher backup power requirements. This needs to be addressed quickly, or the other customers of OPPD will be forced into more drastic decisions later. Delay in considering this issue until sometime after the 2026 IRP is not an adequate response.

Climate change resilience will require an ability to operate through an increasingly harsh environment with at least the current probability of severe storms, along with a rising probability of severe heat waves and precipitation extremes. The ability to obtain cooling water for generation during extreme fluctuations in Missouri River level combined with periods of extreme temperature needs to be explicitly considered when adding new generation sources, and also supporting existing ones.

Dear OPPD Board of Directors,
Thank you for the addition of the environmental justice language into SD-7. I'd also encourage the addition of measurable interim goals towards your 2050 net zero carbon goal. Without interim goals, the implementation will continue to get pushed further into the future where unknown future events can delay implementation beyond 2050. There should be interim goals every 5 years from 2030-2050.

I can salute SD7 on sustainability for a focus on Environmental Justice. Actually following through with this is a big change from OPPDs past behavior.
However, by declining to include decarbonization metrics, OPPD is setting up a situation that lacks any measure of accountability. Even if these are not met, as is often the case, we can have a better idea of what is needed and how OPPD is failing in its decarbonization goals. The problems will not go away; only responsibility for dealing with them will be hidden.
The focus on providing “green” energy for large industrial users, like data centers, takes away the utility’s ability to devise effective programs to reduce bills for low income households. These, while necessary for customers well being, are not as exciting as shiny new customers providing services to other large corporations.
Please re-center the “public” in the Omaha Public Power District.

Dear OPPD Board of Directors,

Thank you for the addition of language supporting environmental justice in the policy revisions to SD-7: Environmental Stewardship. I would appreciate further reassurance, in the form of measurable action, that the current OPPD Board is genuinely committed to putting the principles of environmental justice into action. For example, the revised document cites this definition from the EPA: “The EPA defines Environmental Justice as the fair treatment and meaningful involvement of all people, regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” I have strong concerns that this fair treatment and equal respect is not currently being extended to the people of North Omaha, who continue to suffer ill health effects tied to the operation of a coal-fired power plant. A recent article in the Washington Post confirms what many of us have long expected: that keeping such environmentally harmful forms of energy online is happening due to OPPD’s working to serve the needs of major tech companies such a Meta and Google, NOT to serve the people of Omaha. So while the language in the revised document is a start, a genuine commitment to following through on that language would be appreciated.

I strongly support, along with other commenters, the setting of interim metrics PRIOR to 2050, rather than relying on vague, unproven and unprovable promises that future technologies will somehow solve the problem of climate change. It makes no sense to continue to delay reductions based on such vague promises, and the people of North Omaha—already disadvantaged and at a higher risk for a wide variety of health issues due to the current coal plant—will bear the brunt of these decisions being made for the benefit of those who can most afford it. Instead of sacrificing our clean air for the benefit of private companies, make clear to those companies that the health and wellbeing of the people of Omaha is not for sale!

One meaningful move in the right direction would be more transparency in data reporting, including EJ metrics, and a concrete plan for regularly communicating these metrics with ALL members of the Omaha community, not just city “power players” and company heads.

The costs of continued delays to reduction in reliance on fossil fuels are building up by the day. Precise interim metrics would be a first step in the process of weaning ourselves off the addiction to fossil fuels and to false promises from companies who routinely put profits above people.

Sincerely,
Jacob Rump

Dear OPPD board of directors,

I'm very happy to see the addition of language supporting environmental justice. Beyond recognition, I would also appreciate learning how that language of support translates to meaningful action. Data reporting should therefore include EJ metrics, and ideally be communicated in public fora.

Reading over prior comments, I also wholeheartedly support the setting of interim metrics PRIOR to 2050. Relying on future tech presumes efficacy and cost efficiency gains no one today can guarantee. Further delaying reductions for these or other reasons (especially an IRP process that has no history of capturing actual energy development/demand) will entail significant costs born by this community (and of course others).

Please reconsider establishing clear interim metrics.

Sincerely,
Adam Sundberg

Dear OPPD Board of Directors,

Thank you for your continued attention to environmental stewardship in your leadership of our public power district. Generating reliable, affordable and clean energy for our city and region remains of utmost importance.

I am glad to see the addition of one interim metric (and a plan to add more in the future) towards the goal of net zero emissions by 2050. I support this and wish for it to be included in the final policy revision. I will continue to push for accountability towards this end goal and additional interim metrics, in future SD-7 revisions.

Thank you as well for adding the principle of Environmental Justice to your decision-making process.

Sincerely,
Kevin Fitzgerald

Dear OPPD,

Please include the following considerations for SD-7:

* Set Interim Goals: 2027 (41-51% net reduction in carbon dioxide equivalent), 2035 (65-75% net reduction in CO2e), 2040 (85-95% net reduction in CO2e) toward their current 2050 to achieve Net Zero Carbon.

* Engage customers and stakeholders to develop and provide incentives that promote energy efficiency, customer generation and mitigate the environmental and social impacts of fossil fuel combustion, particularly within vulnerable communities.

* Harden our critical infrastructure in order to adapt to the effects of climate change. The International Energy Agency reports that tripling global renewable energy and doubling energy efficiency by 2050 is within reach, but only with much greater global investment starting now.

* Work to efficiently comply with all applicable environmental laws and regulations.

* Communicate the environmental and public health impacts of climate change as we serve our communities.

* Collect data on our environmental performance and communicate progress periodically to the board and community.

* Work to improve our use of raw materials, energy and water used in operations and provision of our services, and strive to reduce the emissions, discharges and wastes that we generate with a commitment to continuous improvement.

Thank you for the work you have already done to address climate change; now, we must do more.

Warmly,
Genevieve Williams

On behalf of the Midwest Energy Efficiency Alliance (MEEA), a nonprofit nonpartisan regional member-based organization promoting energy efficiency to optimize energy generation, reduce consumption, enhance energy affordability and decrease carbon emissions in all Midwest communities, I would like to thank the OPPD Board of Directors for this opportunity to comment on Strategic Directive 7 Revisions.

MEEA strongly supports the Board’s inclusion of language acknowledging OPPD’s commitment to the efficient use of energy and the importance of environmental justice in District decision making. As stated in previous comments to the Board of Directors (MEEA’s June Comments), energy efficiency is a critical tool to reach net zero carbon equivalent emissions by 2050 and OPPD’s customer-owners would benefit greatly from the expansion of residential, commercial and industrial energy efficiency programming. Energy efficiency and environmental justice are implicitly tied together, as disadvantaged communities experience greater burdens from high energy bills, as well as the brunt of long-term climate impacts and day-to-day pollution. One-way OPPD can further environmental justice is by investing in low-income energy efficiency programs to relieve high and severe energy burden (MEEA’s September Comments), while helping steward healthier, and more resilient, homes.

MEEA encourages OPPD to determine explicit interim metrics for carbon reductions and energy efficiency programming – and clear commitments as to how invested resources will contribute to environmental justice priorities. MEEA recommends OPPD include energy burden reduction goals/metrics for OPPD’s low-income customer-owners to assist in tracking environmental justice progress. Interim goals would benefit OPPD in meeting both long-term emission reduction goals and the Board’s commitment to communicate data-driven progress clearly and periodically to OPPD’s customer-owners.

Once again, MEEA applauds the progress that these revisions represent and the commitment that the Board continues to demonstrate towards the OPPD customer-owners. Thank you for this opportunity to participate in the public process.

Paige Knutsen,
Executive Director
Midwest Energy Efficiency Alliance

Omaha Public Power District. This is a public utility that answers to its citizens. The current board is selling the clean air we enjoy to the Silicon Valley billionaires. Data Centers, and A.I. warehouses are not the economic windfall that the board believes it is. never forget that this board is selling the clean air that we benefit from today. Tragedy of that commons, If they don't sell the clean air in Omaha, maybe Lincoln will sell off their clean air first. This is the best opportunity to do something that will benefit that people of Omaha and the earth. The proposed red lining in the SD-7 document is shameful and reflects a lack of accountability. Do the right thing.

I am absolutely in support of adjustments to climate change and changing to sustainable energy and including environmental justice--the quicker the better.

I would like to share my support for clean energy and environmental justice goals. Omaha can be an example for other communities if we get this right. Let’s lead the way.

I think the document should state that oppd will be transparent about its goals and reporting on carbon emissions

I also think oppd should state concrete goals , or figures, on its planned reduction in carbon emissions over the next few years, at least as a goal

While there is some uncertainty in those targets, it could be expressed as a target range , with an optimistic target, and a target that is lower but has more confidence in achieving that goal

I would like to express my support for the inclusion of environmental justice in the revisions to the policy. This is an important step in creating a community that is resilient to climate change. Beyond striving toward the just treatment and meaningful involvement all people, I would like encourage OPPD to implement another key component of environmental justice, which is ensuring the equitable distribution of benefits from policies as well as equitable distribution of environmental risks.

Furthermore, it would be great to include regular reporting metrics on how environmental justice goals are being measured and achieved throughout the policy's period. This will increase transparency and trust.

I strongly support the proposed new language addressing Environmental Justice. Environmental justice is important to center in policy decisions for OPPD. Climate change impacts marginalized members of communities first and worst. And we need to be sure that costs for decarbonization and energy is paid most by people with the means to pay, rather than onto low-income households. There are a few improvements I would like to see, though. First, I would urge you to require reporting on environmental justice outcomes as part of environmental performance, which is already mandated by SD7. There is no reason to withhold environmental justice outcomes and progress from the public. Second, I would like greater emphasis in terms of emphasizing fair distribution of both harms and benefits. Reference in discussion of environmental justice of “just treatment regarding both harms and benefits” would be helpful. The American Public Power Association’s 2024 White Paper on the components of Environmental Justice as defined by the EPA may be helpful to make sure OPPD is not missing key considerations of environmental justice. Finally, I’d like to see OPPD set strong interim metrics. We need to reduce emissions much faster for human health and in line with climate science. I have a young child and I am deeply concerned for his health, his future in Omaha, and his whole generation’s future trajectory given the climate emergency. Rapid decarbonization is an urgent concern for my family. The more we delay, the more it negatively impacts our health and our planet. Please be brave in taking action.

As a former biologist and health care provider, and current certified Nebraska Master Naturalist, I thank you for the opportunity to comment:
Please set Interim Goals (or Short Term Goals in the medical world) so that OPPD and the public knows that progress is being made, rather than a surprise at the end that very little happened.
Engage customers and stakeholders to develop and provide incentives that promote energy efficiency, customer generation and mitigate the environmental and social impacts of fossil fuel combustion, particularly within vulnerable communities. As an example, my family made the decision a few years ago to install solar panels on our roof. We do save money from OPPD buying back the extra power generated. Most of our other appliances are electric so that we can utilize the cleaner energy that electricity provides.
Harden our critical infrastructure in order to adapt to the effects of climate change. Contrary to some who have their heads buried in the sand (which will get too hot), we need to start now (yesterday) to adapt to what is already happening. As the saying goes, the best time to plant a tree is twenty years ago.
Work to efficiently comply with all applicable environmental laws and regulations. This shouldn't have to be said, but I guess it does.
Communicate the environmental and public health impacts of climate change as we serve our communities. This also shouldn't have to be said, but apparently not everyone gets it.
Collect data on our environmental performance and communicate progress periodically to the board and community.
Work to improve our use of raw materials, energy and water used in operations and provision of our services, and strive to reduce the emissions, discharges and wastes that we generate with a commitment to continuous improvement.

There is nothing more "common sense" than wanting to protect our biosphere so that human and non-human life can survive.

No surprise about the Sierra Club's comment. It is just another example of Begley's Axiom, "The Left is never satisfied."

On behalf of the Nebraska Sierra Club and our over 2000 members and supporters in OPPD's territory, I wish to express our appreciation that environmental justice was added to SD-7. Forty percent of NDEEs $307 million climate action grant and the Center for Rural Affairs' $62 million grant are set aside for traditionally underserved of which the largest population in Nebraska reside in OPPD’s District, specifically North and South Omaha. It is only logical that Environmental Justice should be included and measured.

At the same time we are disappointed that OPPD has not set aggressive goals for energy efficiency and distributed energy resources. SD-7 should have measurable interim goals towards your 2050 net zero carbon goal. As the saying goes: “what gets measured gets done.” Conversely, what doesn't get measured doesn't get done. As I indicated in my comments at the all committee meetings and at the board meetings, at the very least OPPD can set goals for DERs. As the U.S. Dept. of Energy states: "DERs can help agencies meet goals and mandates, deliver cost and energy savings, and provide environmental benefits." SMUD who served as a model for OPPD’s creation of Strategic Directives has a report entitled “Integrated DER Management Enables to Meet Aggressive Clean Energy Goals.” This can serve as one of many models that other utilities have.

In addition, reference should be made to the seeking of the vast amount of federal funding that could help to advance energy efficiency and clean energy incentives.

David E. Corbin, PhD
Energy Committe Chair
Nebraska Sierra Club

As I've told the Board at least a dozen times, SD-7 is unlawful as it is contra to OPPD's statutory duty to produce only low cost and reliable power. Wind and solar are neither.

The real tragedy here is not that the world is going to burn up in 2100 (it's not), but that OPPD is missing out on a gigantic economic opportunity as I detailed in my comments at the September 19th meeting.

There is a growing demand for electricity. Data centers and AI are driving that demand. Most other utilities are foolishly adding more intermittent and costly wind and solar to their grids. That's an inadequate and unstable supply. If OPPD built a 3,000 MW gas-fired power plant in Washington or Burt Counties, the Omaha area would see an economic boon.

Transmission is golden. The high-powered lines out of the former Ft. Calhoun station are empty. Fill them up! Transmission costs $1.5m per mile.

Larry Ellison, chairman and founder of Oracle, recently said he's employing utility executives who are looking to site an Oracle data center that can meet its needs. He thinks the US could need 1,000 data centers that would each consume up to 800 MW. Data centers, of course, need power 24/7/365. Solar doesn't cut it. I also understand that 27 different bit coin miners are looking at Nebraska.

Right now Northern Virginia is the home of the most data centers. Why not Omaha? Answer: Because the Board is fixated on net zero.

More electricity means more revenue for OPPD. That also means that the OPPD executives would also get big pay raises.

I've also told the Board multiple times that the Center of the American Experiment modeled net zero in WI and MN and the result was triple electric rates and black outs in January. CA and Germany have been pursuing net zero for many years and that's why they have electric rates that are triple OPPD's.

If there such a thing as political malpractice, the OPPD Board would be sued into bankruptcy.

As to the new "environmental justice" addition, to say this is ridiculous is an understatement. It has nothing to do with producing low cost and reliable power. With this SD-7 amendment, the Board has become a liberal parody.

David D. Begley

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