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Int roduc t i on


n August 2017 the NPPD/DEQ Environmental

Partnership will have completed 17 years

of activities related to sustaining Nebraska’s

quality environment and providing our citizens

with a reliable source of electricity. Reflecting on

the activities of the last 17 years, two issues have

been consistent in their importance – change and

communication. Change because it escalates every

year, which renders communication critical to our

organizations’ ability to successfully meet our


As stated in the Partnership Agreement,

“This DEQ/NPPD partnership is rooted in a deep

commitment to capitalize on the strengths of both

organizations for the benefit of all Nebraska citizens.”

A partnership between a member of the regulated

community and the associated regulatory agency

is unique. However, the benefits of developing a

better understanding of the ramifications of changing

regulations and grasping the implications of a

changing power production portfolio provide both

organizations a more comprehensive understanding

of each organization’s challenges. Since the inception

of the partnership, NDEQ and NPPD have focused

on activities and issues that will, first, benefit

all Nebraskans and second, better prepare our

respective organizations to meet the challenges that

are presented to us. The partnership has provided a

means to examine our challenges in a manner that

“brings more minds to the table.”

The benefits of such an approach are evident

in the activities related to the federal regulation

of coal combustion residuals (CCR). Early in the

associated regulatory development process our

organizations discussed the changes and developed

a comprehensive understanding of the ramifications

of a potential rule-making. From the beginning, our

mutual position was that Nebraska had a program

that ensured environmental protection. Through a

long progression of federal actions consideration

was given to treating CCR as hazardous waste.

This would have resulted in substantially increased

regulatory requirements and costs, with little

environmental benefit.

After several months, and much effort devoted

to the CCR issue, we wound up not far from

where we started from a regulatory standpoint.

The communication between our organizations

that occurred over this time frame allowed both

organizations to comment and participate in the rule-

making process in an effective manner.

The following report examines the activities of

the partnership over 2016. As has been the case in the

past, three partnership meetings were held, as well as

the annual Power Summit. If the reader would like to

attend a Partnership meeting contact Chris Ahlstrom,

NPPD, (402-563-5855) or Tricia Scott, NDEQ, (402-

471-6974) for information.


to Address Emerging Issues

One of the primary reasons for creating the Environmental Partnership was to make efficient use

of available resources from both organizations. Over the past year, the number of issues related

to energy and the environment has grown rapidly.

To stay abreast of these issues, a standing item called “Emerging Issues” is on each agenda, and

discussions concerning those topics are held at each Partnership meeting. The following represents a

sampling of issues NPPD and NDEQ discuss on a regular basis:

• Clean Power Plan

• New Source Review

• Regional haze

• Revisions to National Ambient

Air Quality Standards

(i.e., Ozone)

• Climate change

• NPPD’s R-Line Project

• Mercury

• Cross State Air Pollution rule

• Carbon sequestration

• Clean Water Act,

parts 316 (a) & (b)

• Regulatory developments/


• Kansas Wildfires

• Nebraska Legislative Updates

• Economic development and

associated environmental


• Coal Combustion Residual

(CCR) Rule

• Steam Electric Effluent