ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION
 

STANDARDS FOR BEVERAGE VENDING MACHINES
 

TABLE OF CONTENTS
 

EA.1 INTRODUCTION .......................................................................................................... 1
 

EA.2 METHODOLOGY ......................................................................................................... 1
 

EA.3 RESULTS ....................................................................................................................... 3
 

REFERENCES ............................................................................................................................... 4
 

EA­i

EERE-2006-STD-0125 COMMENT 22
EA­ii

EERE-2006-STD-0125 COMMENT 22
       

       

                         

                            

                       

                   

                          

                            

                              

                          

             

                   

                             

                      

                            

                               

                                      

                       

                       

                        

                            

                             

           

                       

                             

                      

                            

                             

                             

                        

                            

                       

                                                

                             

                       

                                  

                                

                                       

                      

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION
 

STANDARDS FOR BEVERAGE VENDING MACHINES
 

EA.1 INTRODUCTION

The U.S. Department of Energy (DOE) will conduct an environmental assessment as part

of the Notice of Public Rulemaking for beverage vending machines. DOE will assess the

impacts of proposed energy conservation standards for beverage vending machines on certain

environmental indicators using a variant of the U.S. DOE/Energy Information Administration

(EIA)’s National Energy Modeling System (NEMS).a DOE/EIA uses NEMS to produce the EIA

2007 Annual Energy Outlook (AEO2007).1 DOE will use a variant known as NEMS­BT to

provide key inputs to the analysis. Results of the environmental analysis are similar to those

provided in AEO2007. DOE anticipates that the primary environmental effects will be reduced

power plant emissions resulting from reduced electricity consumption.

DOE intends the environmental assessment to provide emissions results to policymakers

and interveners, and to fulfill requirements that the environmental effects of all new Federal rules

be properly quantified and considered. The environmental assessment considers three pollutants

(sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury (Hg)) as well as carbon emissions.

The only form of carbon emissions tracked by NEMS­BT is of carbon dioxide (CO2), so the

carbon discussed in this report is only in the form of CO2. For each of the standard levels, DOE

will calculate total emissions using NEMS­BT, with external analysis used as needed.

DOE will conduct the environmental assessment as a policy deviation from the

AEO2007, using the same basic set of assumptions. For example, the emissions characteristics

of an electricity generating plant will be exactly those used in AEO2007. The NEMS reference

case and alternative growth scenarios are as described in the utility impact analysis (chapter 13

of the Technical Support Document (TSD)).

EA.2 METHODOLOGY

The NEMS­BT tracks carbon emissions using a detailed carbon module; this approach

provides good results because of its broad coverage of all sectors and inclusion of interactive

effects. Past experience with carbon results from NEMS suggests that the NEMS­generated

emissions estimates are somewhat lower than estimates based on simple average factors. One of

the reasons for this divergence is that NEMS tends to predict that conservation measures will

slow generating capacity growth in future years, and new generating capacity is expected to be

more efficient than existing capacity. On the whole, NEMS­BT provides carbon emissions

results of reasonable accuracy, at a level consistent with other published Federal results. In

addition to providing estimates of quantitative impacts of beverage vending machine standards

a For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000,

DOE/EIA­0581(2000), March 2000. EIA approves use of the name NEMS to describe only an official version of

the model without any modification to code or data. Because this analysis entails some minor code modifications

and the model is run under various policy scenarios that are variations on EIA assumptions, we refer to it as

NEMS­BT (BT is DOE’s Building Technologies Program). NEMS­BT was previously called NEMS­BRS.

EA­1

EERE-2006-STD-0125 COMMENT 22
                             

          

                         

                                

                              

                          

                              

                               

               

                           

                                     

                              

                              

                               

                             

                                

                       

                                 

                            

                     

                              

                               

                               

        

                       

                                   

                         

                            

                          

                                

                             

                           

                              

                         

                             

     

                             

                             

                          

                                                

             

                          

on carbon emissions, DOE will consider the use of monetary values to represent the potential

value of such emissions reductions.

The NEMS­BT model reports the two airborne pollutant emissions that DOE has reported

in past analyses, SO2 and NOx. The Clean Air Act Amendments of 1990 set an SO2 emissions

cap on all large power plants. The attainment of this target, however, is flexible among

generators through the use of emissions allowances and tradable permits. The NEMS­BT model

includes a module for SO2 allowance trading and delivers a forecast of SO2 allowance prices.

Accurate simulation of SO2 trading tends to imply that physical emissions effects will be zero, as

long as emissions are at the ceiling.

However, there may be an SO2 economic benefit from energy conservation, in the form

of a lower SO2 allowance price as a result of additional allowances from this rule, and if it is

large enough to be calculable by NEMS­BT, DOE will report this value. The NEMS­BT model

also has an algorithm for estimating NOx emissions from power generation. The impact of these

emissions, however, will be affected by the Clean Air Interstate Rule (CAIR) issued by the U.S.

Environmental Protection Agency on March 10, 2005. (70 FR 25162 (May 12, 2005). CAIR

will permanently cap emissions of NOx in 28 eastern States and the District of Columbia. As

with SO2 emissions, a cap on NOx emissions means that equipment energy conservation

standards are not likely to have a physical effect on NOx emissions in States covered by the

CAIR caps. Therefore, while the emissions cap may mean that physical emissions reductions in

those States will not result from standards, standards could produce an environmental­related

economic benefit in the form of lower prices for emissions allowance credits. However, as with

SO2 allowance prices, DOE does not plan to monetize this benefit for those States because the

impact on the NOx allowance price from any single energy conservation standard is likely to be

small and highly uncertain.

With regard to mercury emissions, NEMS­BT has an algorithm for estimating these

emissions from power generation, and, as it has done in the past, DOE is able to report an

estimate of the physical quantity of mercury emissions reductions associated with an energy

conservation standard. DOE assumed that these emissions would be subject to EPA’s Clean Air

Mercury Ruleb (CAMR), which would permanently cap emissions of mercury for new and

existing coal­fired plants in all States by 2010. Similar to SO2 and NOx, DOE assumed that

under such a system, energy conservation standards would result in no physical effect on these

emissions, but would be expected to result in an environmental­related economic benefit in the

form of a lower price for emissions allowance credits. DOE’s plan for addressing analysis does

not include monetizing the benefits of reduced mercury emissions, because DOE considered that

valuation of such impact from any single energy conservation standard would likely be small and

highly uncertain.

On February 8, 2008, the U.S. Court of Appeals for the District of Columbia Circuit

(D.C. Circuit) issued its decision in State of New Jersey, et al. v. Environmental Protection

Agencyc

, in which the Court, among other actions, vacated the CAMR referenced above.

b 70 FR 28606 (May 18, 2005)
 c No. 05­1097, 2008 WL 341338, at *1 (D.C. Cir. Feb. 8, 2008).
 

EA­2

EERE-2006-STD-0125 COMMENT 22
                             

                     

                             

                         

                                

                         

               

                           

                              

                            

                               

   

Accordingly, DOE is considering whether changes are needed to its plan for addressing the issue

of mercury emissions in light of the D.C. Circuit’s decision.

With regard to particulates, these emissions are a special case because they arise not only

from direct emissions, but also from complex atmospheric chemical reactions that result from

NOx and SO2 emissions. DOE does not intend to analyze or report on the particulate emissions

from power plants because of the highly complex and uncertain relationship between particulate

emissions and particulate concentrations that impact air quality.

EA.3 RESULTS

The results of the environmental analysis are similar to a complete NEMS run, as

published in the AEO2007. These include power sector emissions for SO2, NOx, and carbon, and

SO2 prices, in five­year forecasted increments extrapolated to the year 2042. DOE reports the

outcome of the analysis for each trial standard level as a deviation from the AEO2007 reference

case results.

EA­3

EERE-2006-STD-0125 COMMENT 22
                        

   

REFERENCES
 

1. EIA (Energy Information Administration). 2007. Annual Energy Outlook 2007. EIA,

Washington, D.C., DOE/EIA­0554 (2007).

EA­4

EERE-2006-STD-0125 COMMENT 22