Integrated System Plan

I'd like to see more emphasis and integration of energy efficiency into OPPD's ISP and operations. Also, OPPD still doesn't see to realize that renewable energy is both environmentally-friendly and the cheapest way to generate electricity. Third, I'd like OPPD to establish milestones or interim goals for reducing carbon on the way to their “net-zero by 2050” target. Finally, I want OPPD to add to the ISP that OPPD will follow through on their commitment to refuel/downsize the North Omaha Station.

As detailed in MEEA's comments, better modeling and incorporation of energy efficiency and DSM would improve the ISP. It is surprising to see yellow dots for capital costs for distributed solar and distributed storage as the capital cost for OPPD for those should be low. Ideally OPPD would offer some incentives to encourage these, but should cost less than building utility scale solar or other resources. So would expect capital cost to be green. Distributed solar provides energy where it is used, reducing the need for transmission and distribution infrastructure. It does not make sense that distributed solar is red for energy generation. While OPPD would not receive capacity accreditation for distributed solar, it would reduce peak energy demand and provide energy very close to the energy demand for the customer-owner and neighbors. The full benefits of distributed solar should be considered.
In terms of the projected fuel costs into the future, the flat projections for coal and gas seem overly optimistic. As there are fewer users of coal with coal plant closures, the costs will rise. Currently the costs of gas have fluctuated over the last five years significantly with the Russia-Ukraine war, winter storm Uri, and winter storm Fern going from less than $5 per million Btu to $10 or more (Henry hub prices from EIA). The fluctuations in the last few years have cost consumers billions in extra costs. These need to be considereMore on this from IEEFA: https://ieefa.org/sites/default/files/2026-05/The%20Misguided%20Gas%20Stampede%20-%2005132026.pdf
Environmental Justice has been absent from all of the information I have seen on the ISP so far. OPPD should also consider the commitment to Environmental Justice and how new potential resources impact customer-owners of OPPD, especially those who have been historically most impacted by OPPD coal plants and other resources. Are there resources which lower costs for customer-owners, reduce peak, and generate system benefits? How can those resources be incentivized over those that just cause costs and pollution for customers?

I also remind OPPD of its promise to the community surrounding the North Omaha station. Give a high priority to shutting down the North Omaha coal plant! Demand side management, including energy efficiency, needs more attention as a low-cost means of delaying or avoiding new energy generation. An effective program of on-bill financing would help.

Re: Midwest Energy Efficiency Alliance (MEEA) Comments on OPPD’s Integrated System Plan Workshop #2

Introduction

Thank you for the opportunity to submit comments on Omaha Public Power District’s (OPPD) Integrated System Planning (ISP) process. The following comments will focus on the elements addressing the role of demand side management (DSM) in electric resource planning.

The Midwest Energy Efficiency Alliance (MEEA) is a member-based, nonprofit organization promoting energy efficiency to optimize energy generation, reduce consumption, create jobs and decrease carbon emissions in all Midwest communities. Our members include energy efficiency-related businesses, manufacturers, local governments, utilities, academic institutions, researchers and advocacy groups. MEEA engages in energy efficiency policy and programs in 13 Midwest states, including Nebraska, where 44 of our 170+ members are headquartered or operating.

Energy Efficiency and Demand Side Management

We appreciate the opportunity to highlight the benefits of energy efficiency (EE) in resource planning. Energy efficiency and other DSM tools will become even more important as conversations around demand continue to intensify. Nebraska, like many Midwestern states, will need to find creative solutions to this increased demand while preserving energy affordability. DSM includes traditional EE, like efficient appliances and building weatherization (home insulation and air sealing), in addition to demand responsive strategies, which focus on reducing energy use during times of peak demand when the grid is most strained. By reducing the energy load at peak times, a utility can stave off the need to build additional generation, saving money for customers. When energy efficiency and demand solutions work together in tandem, they are at their most impactful. Virtual Power Plants (VPPs) are a perfect example of where energy efficiency meets demand response to create a smarter and more reliable grid.

VPPs are emerging across the energy sector as an innovative, affordable and common-sense energy solution. VPPs allow a power provider to optimize the operation of distributed energy resources (DERs) to meet energy needs at high demand times. By pooling DERs, utilities can treat these resources as dispatchable and count on them in times of need. In 2023, the Brattle Group conducted a study to evaluate the real reliability, cost savings and additional benefits of using VPPs to meet resource adequacy needs. Brattle found that VPPs that leverage residential load flexibility can perform as reliably as traditional energy resources, at only roughly 40% to 60% of the cost of alternative options. As demand soars across the country, VPPs and other DERs will become imperative for managing an increasingly strained energy system. OPPD’s investment in advanced metering infrastructure is a valuable first step in unlocking the potential of VPPs.

MEEA appreciates the consideration of DSM technologies throughout OPPD’s ISP process, as it is critical to invest in these technologies and integrate them into OPPD’s energy system. DSM technologies are the most affordable, available and dispatchable energy options on the market, offering massive benefits to both OPPD’s energy system and customer-owners. Below, we offer a few recommendations to ensure that OPPD unlocks the full potential of DSM technologies.

Demand Side Management in Integrated Planning

OPPD’s Integrated System Planning approach to resource planning is an important process for meeting the power district’s future energy and capacity needs. Across the Midwest, states have adopted a variety of policies for resource planning, typically through integrated resource planning (IRP) which is analogous to OPPD’s ISP. IRPs use load forecasting and resource optimization scenarios to create a least-cost/lowest-risk plan for meeting future customer needs. All IRPs, however, are not created equal. IRPs that call for more cost-effective EE tend to include the following additional features:

• Using up to date energy efficiency and demand response market potential studies as the basis for evaluating demand-side resource options.
• Creating scenarios/sensitivities for load forecasting around expanded DSM, for example high avoided cost or technological development scenarios that increase the value or adoption rates of demand-side resources.
• Including demand-side resources as selectable resources that can compete fairly on a cost basis in capacity expansion models, rather than just “baking in” expected energy efficiency into load forecasts.

We will discuss some recommendations about these points in the next section. We also make recommendations related to:

• Comparison of generation with supply-side resources
• Valuing attributes of DSM resources
• Compatibility of DSM with advanced transmission technologies

OPPD Integrated System Plan

As the OPPD team finalizes the resource technology and future scenarios to include in ISP modeling, MEEA offers a few points for consideration.

Market Potential Study & Scenario Development

Based on OPPD staff’s ISP Workshop #2 presentation, it is not clear how DSM tools are being valued or incorporated into the resource planning framework. While staff clarified that OPPD conducted a potential study for the expansion of demand response and energy efficiency programs, that study has not been shared widely. Stakeholders should have access to potential studies to be able to assess whether identified DSM potential is truly being assessed by the ISP.
While it is good to see that OPPD created several DSM scenarios, we would like to see more detail on what the inputs and assumptions are for these scenarios. As presented, the “moderate growth” and “high growth” DSM potential scenarios do not provide sufficient detail needed to analyze OPPD’s pathways. As the two scenarios show, the “moderate growth DSM potential” pathway does not include any new energy efficiency from 2026 – 2050, leaving this least-cost resource behind in OPPD’s energy future. Because of its impact on the whole utility system, energy efficiency benefits every customer-owner, whether a household is receiving a direct rebate or not. It is unclear from the information presented why there is only EE in the “high growth case DSM potential” scenario, while DR and supply-side DERs are included in both.

It does not make sense to exclude EE from any of the load growth scenarios because it is complementary to the other technologies. The year-round savings across the entire demand curve from structural EE can be extremely complementary to DR, rate structures and supply-side DERs. A 2022 study from Berkeley Lab finds that ”net system costs decline when both EE and DR are added to the system regardless of the type of EE package or DR” and that “existing EE controls (e.g., smart thermostat) and envelope technologies and measures can enhance the capabilities and value of DR (e.g., by enabling load shifting by changing the magnitude and timing of heating/cooling consumption).”

DSM as Selectable Resource

While using demand-side resources as load-modifying resources in forecasting is a traditional and acceptable practice in IRPs, there is movement regionally and nationally toward including DSM as a selectable resource in capacity expansion modeling. States and utilities in the Midwest, especially Indiana, Michigan and Minnesota, have a decade or more experience creating demand-side bundles for inclusion in their modeling, often using the same models that OPPD and its consultants are using. Even if existing/planned resources are used to modify load forecasts, modeling can identify other additional resources that should be considered. The achievable, or even economic, opportunity from potential studies can be used to create bundles of demand-side resources with similar load shapes and characteristics that can compete alongside supply-side resources in capacity expansion modeling to select the DSM resources for the preferred plan, rather than limiting the plan to existing resources and those already identified in short-term energy efficiency planning cycles.

Giving demand-side resources the opportunity to compete on cost and characteristics against supply-side resources can provide a more optimized, lower cost preferred plan than would be achieved through only modeling supply-side resources to meet future capacity needs.

Comparison of Generation and Demand-Side Resources

Throughout the ISP Workshop #2 presentation, OPPD staff presented resource and model considerations that limited analysis to generation-side resources. For instance, in resource adequacy discussions, OPPD staff only described the impact that generation-side assets have on resource adequacy scenarios, failing to consider the impact of DSM assets on resource adequacy. Energy efficiency and demand response are proven cost-effective methods to reduce a utility’s peak demand, which the Southwest Power Pool’s accredited capacity planning reserve margin is based on. Investing in DSM to reduce the growth in demand is a critical component in building a resilient energy system, especially with the emergence of large loads.

During OPPD staff’s discussion of candidate resource costs, and the calculation of levelized costs of energy and summer capacity, staff did not include DSM as a candidate resource in their analysis. Energy efficiency is the least cost energy resource, a fact that has remained true especially as fuel costs have risen in the last year. By excluding demand side management from this comparative analysis, staff fail to see the benefit of DSM and its competitive nature with generation-side resources. Staff should include energy efficiency as the cost of saved energy, expressed as a dollar per megawatt hour ($/MWh) when presenting a comparative analysis of resources.

Undervalued Attributes of DSM

When assigning candidate resource attributes, staff undervalued the impact of DSM technologies in multiple categories. Staff categorized the impact of DSM on “operational flexibility” and “utility scale timing” as “neutral or mid-range.” This categorization fails to recognize innovation in DSM technologies over the last decade. OPPD’s investment in advanced metering infrastructure allows the utility to establish demand response programs and virtual power plants that can be dispatched instantaneously to reduce grid strain across the system or in critically affected areas. Common demand response programs and rate structures such as time of use rates and critical peak pricing are proven models to increase the flexibility of the grid at high load times. DSM programs shed or shift peak load at critical times, and we do not feel staff has adequately valued this temporal component of DSM.

Additionally, staff also categorized the DSM impact on capacity accreditation as “neutral or mid-range” – however, the more that DSM can be used to provide a reduction of OPPD’s peak electric load and thus, its resource adequacy requirements, the more benefit it will provide to the overall energy system, and associated capacity accreditation concerns.

Energy Efficiency Meets Transmission

As OPPD develops a final modeling framework, we encourage staff to consider advanced transmission technologies (ATTs) alongside traditional transmission and distribution upgrades, allowing OPPD to make the most cost-effective resource decisions and ensure energy reliability. While energy efficiency, demand response and bundled distributed energy resources can help OPPD use its generation more efficiently, ATTs can help OPPD use its transmission and distribution resources more efficiently and effectively, delaying or preventing more expensive and extensive upgrades. ATTs allow utilities to reduce energy loss along transmission lines and ensure that customer-owners are getting the most out of infrastructure investments. ATTs encompass a broad array of technologies, including dynamic line rating, power flow control and topology optimization. These technologies work together to create cost savings and increase flexibility and resiliency far faster than traditional grid expansion. While traditional transmission upgrades unlock additional capacity, they can take years to build and prove costly to ratepayers across the transmission system. ATTs, on the other hand, can be deployed in months and often pay for themselves in less than a year. Like our comments above on energy efficiency, we would encourage OPPD to consider how it can better utilize its existing resources and use them more efficiently, whether that’s generation, transmission or distribution, before selecting more expensive upgrades.

Conclusion

Demand side management resources, including energy efficiency, demand response and virtual power plants are critical investments now more than ever. Integrated System Planning can lead to higher rates of energy efficiency adoption and guide the development of DSM programs to meet identified resource priorities. While the ISP process and DSM program development process differ, the results of each can inform and complement the other.

With today’s unprecedented electric demand growth, it is imperative to plan for an affordable, resilient and sustainable energy system.

Thank you for the opportunity to comment. If you have any questions on these comments or would like to discuss energy efficiency policy further, please reach out to MEEA’s Nebraska state lead, Clara Stein, at cstein@mwalliance.org.

Sincerely,

Paige Knutsen
Executive Director, MEEA

These comments reflect the views of the Midwest Energy Efficiency Alliance – a Regional Energy Efficiency Organization – and not the organization’s members or individual entities represented on our board of directors.

I echo several comments here in asking OPPD to prioritize the ISP’s continued assumption that the North Omaha Station will be shut down. This is incredibly important for the well-being of North Omaha in particular and our entire community.

Also, please continue to set interim goals for reducing carbon on the way to OPPD's stated “net-zero by 2050” target.

Finally I want to upvote Sunshine's comment yet again as I don't think I can state it more effectively:
"I encourage OPPD to use green energy such as wind and solar as much as possible. They are not only cleaner and safer then most other energy sources but they are cost effective. The future will demand huge amounts of energy and we need to have plans in place to protect our environment and water with clean energy. Obtaining this energy from within our state will also help our economy at a time when our citizens can use economic help."

I can only echo Sunshine's comments because they so succinct and match exactly what i have to say:

I encourage OPPD to use green energy such as wind and solar as much as possible. They are not only cleaner and safer then most other energy sources but they are cost effective. The future will demand huge amounts of energy and we need to have plans in place to protect our environment and water with clean energy. Obtaining this energy from within our state will also help our economy at a time when our citizens can use economic help.

I also agree that the North Omaha Station needs to be shut down.

And David Begley is a lawyer paid by Amazon to make such idiotic comments as he does.

Thank you for the opportunity to provide input on OPPD's Integrated System Plan.

My highest priority is reducing greenhouse gas emissions while maintaining a reliable electric system. Climate change is already contributing to more extreme weather, and I believe OPPD should continue moving toward cleaner energy sources and technologies that reduce emissions over time.

Reliability is also extremely important, especially during heat waves, winter storms, and other extreme weather events. I encourage OPPD to prioritize investments that strengthen the grid and reduce outages, particularly in lower-income neighborhoods where residents may have fewer resources to cope with power interruptions.

I would also like OPPD to consider creating an income-based assistance program, such as a Percentage of Income Payment Plan, for households that struggle to afford their electric bills. Many lower-income families do not have the financial means to install rooftop solar panels or make major energy-efficiency upgrades, yet they can be disproportionately affected by rising energy costs. An income-based payment option could help ensure that electricity remains affordable for all customers while OPPD continues to invest in a cleaner energy future.

In summary, I encourage OPPD to prioritize:

Reducing greenhouse gas emissions.
Maintaining and improving reliability during extreme weather.
Ensuring that lower-income households can afford essential electric service through income-based assistance programs.

Thank you for considering my comments.

I encourage OPPD to use green energy such as wind and solar as much as possible. They are not only cleaner and safer then most other energy sources but they are cost effective. The future will demand huge amounts of energy and we need to have plans in place to protect our environment and water with clean energy. Obtaining this energy from within our state will also help our economy at a time when our citizens can use economic help.

I highly doubt OPPD's LCOE is accurate; especially if it is based on Lazard's numbers.

Does the LCOE for solar and wind energy include transmission costs? The costs to build a second and reliable power source to back up intermittent solar and wind.

And what about the projected useful life for solar and wind energy? Lazard used incorrect numbers for the useful life of solar and wind compared to natgas, nuclear and coal. And, finally, solar and wind energy use many more acres than natgas. Just look at the footprint of Standing Bear Station and Turtle Creek compared to Burt and Saunders County.

CAGW is the biggest scam in the history of the world.

I would like to see more solar and wind energy as well as having higher fees for high utility users. I would also like OPPD make it easier for customers to get residential solar and advocate for solar in our state, including balcony solar. It would be great if OPPD could offer incentives for residents who use solar since they are helping ease the burden on the grid. I would like to see the coal plant shut down for good and a reduction in the use of natural gas.

As an OPPD customer, my expectations of the ISP include:
1. Committing to reducing relinance on combustion based energy source that drive destructive trends in a) the global climate and b) the cardiovascular health of our community
2. Assessing the emerging regulatory framework for new nuclear technologies so that OPPD can invest in long term nuclear generation as soon as possible

As an Omaha resident, I want to share my strong support for the ISP’s continued commitment to refueling and shutting down the North Omaha Station—moving away from coal there is vital for our community's health. While the "net-zero by 2050" target is great, I encourage OPPD to establish clear interim carbon-reduction milestones to keep us on track. Finally, we should leverage the massive tech presence here: I encourage OPPD to look for ways data centers can pay for new resources in exchange for faster interconnection, and I support SPP's CHILLS-HILLGA program if those companies are willing to fund bringing new renewable energy directly to Nebraska. Thank you to the planning committee for keeping our grid forward-thinking!

Please prioritize clean energy sources, which are also cheaper and healthier for people and other organisms on our planet. I spent the money to invest in rooftop solar for my home, contributing to the stability of the grid , so the least OPPD can do is provide a better energy future.

I am a residential customer of OPPD. I would like to advocate for keeping customer rates low by ensuring that all high utilizers, such as data centers, pay equal, if not greater rates than residential customers, as well as 100% of infrastructure costs. Ensure no data center is able to build their own power plant and connect it to public power grid. I would also like to advocate for some minor decentralization of power generation by having OPPD advocate in state legislature for options like plug-in balcony solar and other generation methods that do not involve high installation costs. Even better if OPPD can help partially subsidize plug-in balcony solar.

I would like to commend OPPD for seeking input on this ISP. Planning for the future grid capacity and reliability is critical for the continued economic growth of the region. For generation mix, in my opinion I think OPPD needs to consider a balanced approach to the types of generation constructed. Natural gas is an excellent option for the short term and can supply needed capacity. Natural gas prices are currently low and supply looks to be plentiful for the near-term, however with these gas turbines being installed at an increasing rate all over the country, it seems that cost will escalate in the future. Wind and solar, though perhaps a little more expensive in the near term, would provide long-term stability for generation capacity as well as price stability. Small modular reactors also need to be considered as technology improves.

In determining the mix, I think there needs to be a balance of creating capacity to meet needs but also considering rates so that increases can be kept as low as possible. One of our advantages for economic growth is our low cost of power compared to other parts of the country. Maintaining this competitive advantage is important. However, demand for power is increasing exponentially and we need to add generation to power these businesses which create jobs and grow our economy. OPPD needs to look at aggressive growth scenarios and determine the most cost-effective way to address this growth. If we have the power available, we will see good projects attracted to our area. Thank you for the opportunity to provide my thoughts.

Feedback received prior to this post are from the first workshop. Feedback received after are from Workshop 2.

I appreciate OPPD's efforts to communicate with the public, but I wish that you would tell us when the peak times of day (and year) are, so that those of us with all-electric homes and cars could shift our demand to the off-peak times. You know who your big customers are. You know our email addresses and phone numbers. What is stopping you from communicating this information? Why promote smart thermostats instead of simply telling us when we need to use less power?

A majority of the current OPPD Board and a few activists who show up here in the comments and at the various OPPD meetings are of the opinion that CAGW is a threat to human existence and that carbon dioxide endangers human health. Now that the EPA has repealed the designation that carbon dioxide is a pollutant, it is about time for OPPD to get on board.

If the Board continues with its Net Zero policy, rates will continue to climb. That's because -contrary to the narrative spun out by the Left and Wall Street - solar and wind are the most expensive forms of energy. That's also why electricity is so much more expensive in Europe and California.

The Board's hypocrisy is so blatant. It wants to close the coal-fired units at North Omaha but keep Nebraska City Station open. Per tollfromcoal.org, NCS "kills" more people than NOS. The fact is, however, that neither are a health threat to people.

David D. Begley
Customer-owner

I would love if OPPD focuses more on the environment in upcoming years. Renewable energy is better for the environment and the economy and should be a crucial part of OPPD's future. As a young person who is concerned about climate change, I hope to see OPPD moving away from fossil fuels.

I love to see solar and battery storage already coming online! I’d love to see the timeline for renewables move even faster. Climate change isn’t slowing down, so our clean energy transition shouldn’t either. I hope the environment is a top priority throughout this process. As a high schooler, my generation is the one inheriting these decisions. I’d like to believe that OPPD has this in mind, and they could show it by expanding renewable generation.