15 -i CHAPTER 15. ENVIRONMENTAL IMPACTS ANALYSIS

TABLE OF CONTENTS
15.1 INTRODUCTION ......................................................................................................... 15-1
15.2 AIR EMISSIONS ANALYS IS ...................................................................................... 15-1
15.2.1 Air Emissions Descriptions .......................................................................... 15-1
15.2.2 Global Climate Change ................................................................................ 15-5
15.2.3 Analytical Methods for Air Emissions ........................................................ 15-9
15.2.4 Effects o n Power Plant Emissions ............................................................... 15-9
15.2.5 Effects on Upstream Fuel

- Cycle Emissions .............................................. 15-14
15.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND
CULTURAL RESOURCES ........................................................................................ 15-15
15.4 SOCIOECONOMIC IMPACT S .................................................................................. 15-15
15.5 ENVIRONMENTAL JUSTIC E IMPACTS ................................................................ 15-15
15.6 NOISE AND AESTHETICS ....................................................................................... 15-15
15.7 SUMMARY OF ENVIRONME NTAL IMPACTS ..................................................... 15-16

LIST OF TABLES

Table 15.2.1 Reduction in Cumulative Energy-Related Emissions of CO 2 from 2014 through 2043 from Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards ......................................................................... 15-8
Table 15.2.2 Power Sector Emissions Forecast from AEO2010 Reference Case ................. 15-10
Table 15.2.3 Power Sector Emissions Impacts Forecasts for Clothes Dryer TSLs .............. 15-11
Table 15.2.4 Power Sector Emissions Impact Forecasts for Room Air Conditioner TSLs .. 15-12
Table 15.2.5 Household Emissions Impact Forecasts for Clothes Dryer TSLs .................... 15-13
Table 15.2.6 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct
Power Plant Combustion Emissions ................................................................ 15-14
Table 15.7.1 Cumulative Emissions Re ductions Under Clothes Dryer and Room Air
Conditioner TSLs* ........................................................................................... 15-1615 -1 CHAPTER 15. ENVIRONMENTAL IMPACTS ANALYSIS

15.1 INTRODUCTION

This chapter describes potential environmental effects that may result from amended energy conservation standards for residential clothes dryers and room air conditioners. The U.S. Department of Energy (DOE)’s energy conservation standards are not site -specific, and would apply to all 50 States and U.S. territories. Therefore, none of the standards would impact land uses, cause any direct disturbance to the land, or directly affect biological resources in any one

area.

All of the trial standard levels (T SLs) are expected to reduce energy consumption in comparison to the base case. These changes in energy consumption are the primary drivers in analyzing environm ental effects. The estimates of energy savings that serve as inputs to t he environmental impacts analysis can be found in the utility impact analysis in chapter 1 4 of this technical support document (TSD).

The primary impact of the TSLs is on air emissions resulting from power plant operations. Therefore, much of this chapter describes the air emi ssions analysis, and t he latter part of the chapter describes potential impacts to other environmental resources. For clothes dryers there are some household emissions resulting from natural gas usage.

15.2 AIR EMISSIONS ANALYS IS

A primary focus of the environ mental analysis is the impact on air emissions of amended energy conservation standards for residential clothes dryers and room air conditioner products. The outcomes of the environmental analysis are largely driven by changes in power plant types and quan tities of electricity generated under each of the alternatives. Changes in electricity generation are described in the utility impact analysis in chapter 1 4.

15.2.1 Air Emissions Descriptions

For each of the TSLs, DOE calculated total power

- sector emissions b ased on output from

t he NEMS

- BT model (see chapter 1 4 for description of the model). This analysis considers three pollutants: sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), and mercury (Hg). An air pollutant is any substance in the air that can cause harm to humans or the environment. Pollutants may be
natural or man -made (i.e., anthropogenic) and may take the form of solid particles (i.e., particulates or particulate matter), liquid droplets, or gases. a This analysis also considers carbon dioxide (CO 2 ).

a More information on air pollution characteristics and regulations is available on the U.S. Environment Protection Agent (EPA)’s website at www.epa.gov.15 -2 Sulfur Dioxide. Sulfur dioxide, or SO 2 , belongs to the family of sulfur oxide gases (SOx). These gases dissolve easily in water. Sulfur is prevalent in all raw materials, including crude oil, coal, and ore that contains common metals like aluminum, copper, zinc, lead, and iron. SOx gases are formed when fuel containing sulfur, such as coal and oil, is burned, and when gasoline is extracted from oil, or metals are extracted from ore. SO 2 dissolves in water vapor to form acid, and interacts with other gases and particles in the air to form sulfates and other products that can be harmful to people and their environment. 1

SO 2 emissions from affected Electric Generating Units (EGUs) are subject to nationwide and regional emissions cap and trading programs, and DOE has determined that these programs create uncertainty about the standards’ impact on SO 2 emissions. The attainment of emissions caps is typically flexible among EGUs and is enforced through the use of emissions allowances and tradable permits. Under existing EPA regulations, any excess SO 2 emissions allowances resulting from the lowe r electricity demand caused by the imposition of an efficiency standard could be used to permit offsetting increases in SO 2 emissions by any regulated EGU. However, if the standard resulted in a permanent increase in the quantity of unused emissions allowa nces, there would be an overall reduction in SO 2 emissions from the standards. While there remains some uncertainty about the ultimate effects of efficiency standards on SO 2 emissions covered by the existing cap and trade system, the NEMS

- BT modeling system that DOE uses to forecast emissions reductions currently indicates that no physical reductions in power sector emissions
would occur for SO 2

.

Nitrogen Oxides. Nitrogen oxides
, or NO X , is the generic term for a group of highly reactive gases, all of which contain nitrogen and oxygen in varying amounts. Many of the nitrogen oxides are colorless and odorless. However, one common pollutant, nitrogen dioxide (NO 2 ), along with particles in the air can often be seen as a reddish -brown layer over many urban
areas. NO 2 is the specific form of NO X reported in this document. NO X is one of the main ingredients involved in the formation of ground-level ozone, which can trigger serious respiratory problems. It can contribute to the formation of acid rain, and can impair visibility in areas such as national parks. NO X also contributes to the formation of fine particles that can impair human health. 1

Nitrogen oxides form when fossil fuel is burned at high temperatures, as in a combustion process. The primary manmade sources of NO X are motor vehicles, electric utilities, and other industrial, commercial, and residential sources that burn fossil fuels. NO X can also be formed naturally. Electric utilities account for about 22 percent of NO X emissions in the United States. 2

There is a cap on NO
x emissions in 28 eastern states and the District of Columbia. All these States and D.C. have elected to reduce their NOx emissions by participating in cap

- and

trade programs for EGUs. Therefore, energy conservation standards for clothes dryers and room
air conditioners may have little or no physical effect on these emissions in the 28 eastern states and the D.C. for the same reasons that they may have little or no physical effect on NO X emissions.15 -3 DOE is using the NEMS

- BT to estimate NOx emissions reductions from possible standards in the states where emissions are not capped.

Mercury. Coal -fired power plants emit mercury (Hg) found in coal during the burning process. While coal -fired power plants are the largest remaining source of human- generated Hg emissions in the United States, they contribute very little to the global Hg pool or to

contamination of U.S. waters. 1 U.S. coal- fired power plants emit Hg in three different forms: oxidized Hg (likely to deposit within the United States ); elemental Hg, which can travel thousands of miles before depositing to land and water; and Hg that is in particulate form. Atmospheric Hg is then deposited on land, lakes, rivers, and estuaries through rain, snow, and dry deposition. Once there, it can transform into methylmercury and accumulate in fish tissue through bioaccumulation.

Americans are exposed to methylmercury primarily by eating contaminated fish. Because the developing fetus is the most sensitive to the toxic effects of methylmercury, women of childbearing age are regarded as the population of greatest concern. Children exposed to methylmercury before birth may be at increased risk of poor performance on neurobehavioral tasks, such as those measuring attention, fine motor function, language skills, visual- spatial abilities, and verbal memory. 3

Carbon Dioxide. Carbon dioxide (CO 2 ) is not a criteria pollutant (see below), but it is of interest because of its classification as a greenhouse gas (GHG). GHGs trap the sun’s radiation inside the Earth’s atmosphere and either occur naturally in the atmosphere or result from human activities. Naturally occurring GHGs include water vapor, CO 2 , methane (CH 4 ), nitrous oxide (N 2 O), and ozone (O 3 ). Human activitie s, however, add to the levels of most of these naturally occurring gases. For example, CO 2 is emitted to the atmosphere when solid waste, fossil fuels (oil, natural gas, and coal), wood, and wood products are burned. In 2007, over 90 percent of anthropogenic (i.e., human- made) CO 2 emissions resulted from burning fossil fuels. 4

Concentrations of CO 2 in the atmosphere are na turally regulated by numerous processes, collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and the land and oceans is dominated by natural processes, such as plant photosynthesis. While these natural processes can abso rb some of the anthropogenic CO 2 emissions produced each year, billions of metric tons are added to the atmosphere annually. In the United States, in 2007, CO 2 emissions from electricity generation accounted for 39 percent of total U.S. GHG emissions. 4

Particulate Matter . Particulate matter (PM) also known as particle pollution, is a complex mixture of extremely small part icles and liquid droplets. Particle pollution is made up of a number of components, including acids (such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles.

PM impacts are of concern due to human exposures that can impact health. Particle pollution - especially fine particles - contains microscopic solids or liquid droplets that are so small that they can get deep into the lungs and cause serious health problems. Numerous scientific studies have linked particle pollution e xposure to a variety of problems, including:15 -4 increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty breathing, for example; decreased lung function; aggravated asthma; development of chronic bronchitis; irregular heartbeat; nonfatal heart attacks; and premature death in people with heart or lung disease.

DOE acknowledges that particulate matter (PM) exposure can impact human health. Power plant emissions can have either direct or indirect impacts on PM. A portion of the pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. These are direct, or primary, PM emissions. However, the great majority of PM emissions associated with power plants are in the form of secondary sulfates, which are produced at a significant distance from power plants by complex atmospheric chemical reactions that often involve the gaseous (non-particulate) emissions of power plants, mainly SO 2 and NO
x . The quantity of the secondary sulfates produced is dete rmined by a very complex set of factors including the atmospheric quantities of SO 2 and NO
x , and other atmospheric constituents and conditions. Because these highly complex chemical reactions produce PM comprised of different constituents from different sources, EPA does not distinguish direct PM emissions from power plants from the secondary sulfate particulates in its ambient air quality requirements, PM monitoring of ambient air quality, or PM emissions inventories. For these reasons, it is not currently possible to determine how the amended standard impacts either direct or indirect PM emissions. Therefore, DOE is not planning to assess the impact of these standards on PM emissions. Further, as described previously, it is uncertain whether efficiency sta ndards will result in a net decrease in power plant emissions of SO 2 and NO
x , since those pollutants are now largely regulated by cap and trade systems.

Air Quality Regulation . The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that EP A is required to control. 6 EPA has set national air quality standards for six common pollutants (also referred to as “criteria” pollutants), two of which are SO 2 and NO X

. Also, the Clean Air Act Amendments of 1990 gave EPA the authority to control acidification and to require operators of electric power plants to reduce emissions of SO 2 and NO X . Title IV of the 1990 amendments established a cap- and

- trade program for SO 2 , in all 50 states and the District of Columbia (D.C.), intended to help control acid rain. 6 This cap -and- trade program serves as a model for more recent programs with s imilar features.

In 2005, EPA issued the Clean Air Interstate Rule (CAIR) under sections 110 and 111 of the Clean Air Act (40 CFR Parts 51, 96, and 97). 7 b

b See http: //www.epa.gov/cleanairinterstaterule/. CAIR will permanently cap emissions of
SO 2 and NO X in eastern States of the United States. CAIR achieves large reductions of SO 2 and/or NO X emissions across 28 eastern States and the District of Columbia. CAIR will gradually replace the Title IV program in the 28 states and D.C. States must achieve the required emission reductions using one of two compliance options: 1) meet an emission budge t for each regulated state by requiring power plants to participate in an EPA- administered interstate cap

and

- trade system that caps emissions in two stages, or 2) meet an individual state emissions budget through measures of the state’s choosing. Phase 1 caps for NO X have been in place since15 -5 2009. Phase 1 caps for SO 2 are to be in place beginning in 2010. The Phase 2 caps for both NO X and SO 2 are due in 2015.

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its decision in North Carolina v. Environmental Protection Agency

, which vacated the CAIR issued by the U.S. Environmental Protection Agency on March 10, 2005. c CAIR was the vehicle for capping NO X emissions

. d On December 23, 2008, the D.C. Circuit decided to allow CAIR to remain in effect until it is replaced by a rule consistent with the court’s earlier opinion. North Carolina v. EPA , 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur). e Thus, CAIR is currently in force. However, on July 6, 2010, EPA proposed the Transport Rule, a replacement for CAIR, which would limit emissions from EGUs in 32 states, potentially through the interstate trading of allowances, among other options. 75 FR 45210 (Aug. 2, 2010).

With respect to Hg emissions, in 2005, EPA issued the final rule entitled “Standards of Performance for New and Existing Stationary Sources: Electric Steam Generating Units,” under

sections 110 and 111 of the Clean Air Act (40 CFR Parts 60, 63, 72, and 75) 8 . This rule, called the Clean Air Mercury Rule (CAMR), was closely related to the CAIR and established standards of performance for Hg emissions from new and existing coal- fired electric utility steam generating units. The CAMR regulated Hg emissions from coal -fired power plants.

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 Agency

, f

15.2.2 Global Climate Change in which the Court, among other actions, vacated the CAMR referenced above.

Climate change has evolved into a matter of global concern because it is expected to have widespread, adverse effects on natural resources and systems. A growing body of evidence points to anthropogenic sources of greenhouse gases, such as carbon dioxide (CO 2 ), as major contributors to climate change. Because this Rule, if finalized, will likely decrease CO 2 emission rates from the fossil fuel sector in the United States, the Department here examines the impacts and causes of climate change and then the potential impact of the Rule on CO 2 emissions and global warming.

Impacts of Climate Change on the Environment. Climate is usually defined as the average weather, over a period ranging from months to many years. Climate change refers to a

c hange in the state of the climate, which is identifiable through changes in the mean and/or the variability of its properties (e.g., temperature or precipitation) over an extended period, typically decades or longer. 9

c See http://www.epa.gov/cleanairinterstaterule/.

d See id. at 903.

e State of North Carolina, et al. v. Environmental Protection Agency, 550 F.3d 1176 (D.C. Cir. 2008 ).

f 517 F.3d 574, 583 (D.C. Cir. 2008).15 -6 The World Meteorological Organization and United Nations Environment Pr ogramme (UNEP) established the Intergovernmental Panel on Climate Change (IPCC) to provide an objective source of information about climate change. According to the IPCC Fourth Assessment Report (IPCC Report), published in 2007, climate change is consistent with observed changes to the world’s natural systems; the IPCC expects these changes to continue. 9

Changes that are consistent with warming include warming of the world’s oceans to a depth of 3000 meters; global average sea level rise at an average rate of 1.8 mm per year from
1961 to 20 03; loss of annual average Arctic sea ice at a rate of 2.7 percent per decade, changes in wind patterns that affect extra

- tropical storm tracks and temperature patterns, increases in intense precipitation in some parts of the world, as well as increased drought and more frequent heat waves in many locations worldwide, and numerous ecological changes. 9

Looking forward, the IPCC describes continued global warming of about 0.2 °C per decade for the next two decades under a wide range of emission scenarios for carbon dioxide (CO 2 ), other greenhouse gases (GHGs), and aerosols. After that period, the rate of increase is less certain. The IPCC Report describes increases in average global temperatures of about 1.1 °C to 6.4 °C at the end of the century relative to today. These increases vary depending on the model

and emissions scenarios. 9

The IPCC Report describes incremental impacts associated with the rise in temperature. At ranges of incremental increases to the global average temperature, IPCC reports, with either high or very high confidence, that there is likely to be an incre asing degree of impacts such as coral reef bleaching, loss of wildlife habitat, loss to specific ecosystems, and negative yield impacts for major cereal crops in the tropics, but also projects that there likely will be some beneficial impacts on crop yield s in temperate regions.

Causes of Climate Change. The IPCC Report states that the world has warmed by about 0.74 °C in the last 100 years. The IPCC Report finds that most of the temperature increase since
the mid -20th century is very likely due to the increase in anthropogenic concentrations of CO 2 and other long-lived greenhouse gases such as methane and nitrous oxide in the atmosphere,
rather than from natural causes.

Increasing the CO 2 concentration partially blocks the earth’s re-radiation of captured solar energy in the infrared band, inhibits the radiant cooling of the earth, and thereby alters the energy balance of the planet, which gradually increases its average temperature. The I PCC Report estimates that currently, CO 2 makes up about 77 percent of the total CO 2 -equivalent g

g GHGs differ in their warming influence (radiative forcing) on a global climate system due to their different radiative properties and lifetimes in the atmosphere. These warming influences may be expressed through a common
metric based on the radiative forcing of CO 2 , i.e., CO 2 - equivalent. CO 2 equivalent emission is the amount of CO 2 emission that would cause the same
- time integrated radiative forcing, over a given time horizon, as an emitted amount of other long
- lived GHG or mixture of GHGs. global warming potential in GHGs emitted from human activities, with the vast majority (74 percent) of the CO 2 attributable to fossil fuel use. 10 For the future, the IPCC Report describes a15 -7 wide range of GHG em issions scenarios, but under each scenario CO 2 would continue to comprise above 70 percent of the total global warming potential. 10

Stabilization of CO 2 Concentrations. Unlike many traditional air pollutants, CO 2 mixes thoroughly in the entire atmosphere and is long- lived. The residence time of CO 2 in t he atmosphere is long compared to the emission processes. Therefore, the global cumulative
emissions of CO 2 over long periods determine CO 2 concentrations because it takes hundreds of years for natural processes to remove the CO 2 . Globally, 49 billion metric tons of CO 2

– equivalent of anthropogenic (man- made) greenhouse gases are emitted every year. Of this annual total, fossil fuels contribute about 29 billion metric tons of CO 2

. 11 h

Researchers have focused on considering atmospheric CO 2 concentrations that likely will result in some level of global climate stabilizat ion, and the emission rates associated with achieving the “stabilizing” concentrations by particular dates. They associate these stabilized
CO 2 concentrations with temperature increases that plateau in a defined range. For example, at the low end, the IPCC Report scenarios target CO 2 stabilized concentrations range between 350 ppm and 400 ppm (essentially today’s value)— because of climate inertia, concentrations in thislow-end range would still result in temperatures projected to increase 2.0 °C to 2.4 °C above preindustrial levels i (about 1.3 °C to 1.7 °C above today’s levels). To achieve concentrations between 350 ppm to 400 ppm, the IPCC scenarios present that there would have to be a rapid downward trend in total annual global emissions of greenhouse gases to levels that are 50 to 85 percent below today’s annual emission rates by no later than 2050. Since it is assumed that there would continue to be growth in global population and substantial increases in economic production, the scenarios identify required reductions in greenhouse gas emissions intensity (emissions per unit of output) of more than 90 percent. However, even at these rates, the scenarios describe some warming and some climate change is projected due to already

accumulated CO 2 and GHGs in the atmosphere. 12

The Beneficial Impact of the Rule on CO 2 Emissions. It is anticipated that the Rule will reduce energy

- related CO 2 emissions, particularly those associated with energy consumption in buildings. The U.S. Energy Information Administration (EIA) reports in its 2010 Annual Ene rgy Outlook (

AEO20 10 ) 13 that U.S. annual energy- related emissio ns of CO 2 in 2007 were about 6.0 billion metric tons, of which 1.2 billion tons were attributed to the residential buildings sector (including related energy –using products such as clothes dryer and room air conditioner products). Most of the greenhouse gas emissions attributed to residential buildings are emitted
from fossil fuel

- fired power plants that generate electricity used in this sector. In the AEO2010 Reference Case, EIA projected that annual energy

- related CO 2 emissions would grow from 5.7
billion metric tons in 2015 to 6.3 billion metric tons in 2035 , an increase of 10 percent (see
AEO20 10 ), while residential emissions would grow to from 1.2 billion metric tons to 1.3 billion metric tons, an increase of 12 percent.

h Other non

- fossil fuel contributors include CO 2 emissions from deforestation and decay from agriculture biomass; agricultural and industrial emissions of methane; and emissions of nitrous oxide and fluorocarbons.

i IPCC Working Group 3 Table TS 215 -8 T he estimated cumulative CO 2 emission reductions from residential clothes dryers and
room air conditioner efficiency standard s (shown a s a range of alternative TSLs) during the 30-

year analysis period are indicated in Table 15.2.1. Estimated CO 2 emission re ductions in Table
15.2.1 come from electricity generation (i.e., power plants) and household emissions. The
estimated CO 2 emission reductions from electricity generation are calc ulated using the NEMSBT model.

Table 15.2.1 Reduction in Cumulative Energy

- Related Emiss ions of CO 2 from 2014 through 2043 from Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards

Trial Standard Levels

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6

Million Metric Tons

Clothes Dryers 0.119 2.99 17.7 18.7 70.5 187

Room Air Conditioners 9. 83 11 .9 1 2.5 1 7.4 2 6.9 37. 7

Total 9. 95 1 4.9 30.2 3 6.1 97. 4 22 4

Percent of Total Cumulative Emissions Reduction compared
with the AEO2010 Reference
Case in 2014-2043 0.013 0.020 0.041 0.048 0.131 0.301

The Incremental Impact of the Rule on Climate Change. It is difficult to correlate specific emission rates with atmospheric concentrations of CO 2 and specific atmospheric concentrations with future temperatures because the IPCC Report describes a clear lag in the climate system between any given concentration of CO 2 (even if maintained for long periods) and the subsequent average worldwide and regional temperature, precipitation, and extreme weather regimes. For example, a major determinant of climate response is “equilibrium climate sensitivity”, a measure of the cl imate system r esponse to sustained radiative forcing. It is defined as the global average surface warming following a doubling of carbon dioxide concentrations. The IPCC Report describes its estimated, numeric value as about 3 °C, but the likely range of that value is 2 °C to 4.5 °C, with cloud feedbacks the largest source of uncertainty. Further, as illustrated above, the IPCC Report scenarios for stabilization rates are presented in terms of a range of concentrations, which then correlates to a range of temperature changes. Thus, climate sensitivity is a key uncertainty for CO 2 mitigation scenarios that aim to meet specific temperature
levels.

Because of how complex global climate systems are, it is difficult to know to what extent and when particular CO 2 emissions reductions will impact global warming. However, as Table 15.2.1 indicates, the rule is expected to reduce CO 2 emissions associated with energy consumption in buildings.15 -9 15.2.3 Analytical Methods for Air Emissions

Coal

- fired electric generation is the single largest source of electricity in the United States. Because the mix of coals used significantly affects the emissions produced, the model includes a detailed representation of coal supply. The model considers the rank of the coal as

well as the sulfur contents of the fuel used when determining optimal dispatch. 14

Within the NEMS -BT model, planning options for achieving emissions restrictions in the Clean Air Act Amendments include installing pollution control equipment on existing power plants and building new power plants with low emission rates. These methods for reducing emission are compared to dispatching options such as fuel switching and allowance trading. Environmental regulations also affect capacity expansion decisions. For instance, new plants are
not allocated SO 2 emissions allowances according to the Clean Air Act Amendments. Consequently, the decision to build a particular capacity type must consider the cost (if any) of obtaining sufficient allowances. This could involve purchasing allowances or over complying at an existing unit.

DOE’s analysis assume s the presence of nationwide emission caps on SO 2 and caps on
NO X emissions in the 28 States covered by the CAIR. The NEMS

- BT modeling system that DOE plans to use to forecast emissions reductions currently indicates that no physical reductions in power sector emissions would occur for SO 2. However , in contrast to the modeling forecasts
of NEMS

- BT that SO 2 emissions reductions will remain at the cap, during the years 2007 and 2008, SO 2 emissions have been below the trading cap. The difference between the emissions
levels that NEMS

- BT forecasts and tho se that EPA forecasts is an indicator of the uncertainties associated with long

- range energy sector forecasts. Because of such uncertainties, DOE is unable to estimate the economic and physical benefit from SO 2 emissions reductions at this time.

With res pect to Hg, in the absence of CAMR or other trading program, a DOE standard would likely reduce Hg emissions and DOE uses NEMS- BT to estimate these emission
reductions. However, DOE continues to review the impact of rules that reduce energy consumption on Hg emissions, and may revise its assessment of Hg emission reductions in future rulemakings.

As noted in chapter 14 , NEMS

- BT model forecasts end in year 2035. Emissions impacts beyond 2035 are assumed to be equal to the impacts in 2035.

15.2.4 Effects on Power Plant Emissions

Table 15.2.2 shows AEO2010 reference case power plant emissions in selected years. The Reference Case emissions are the emissions shown by the NEMS -BT model to result if none of the TSLs are promulgated (the base case).15

- 10 Table 15.2.2 Power Sector Emissions Forecast from AEO2010 Reference Case

NEMS

- BT Results 2010 2015 2020 2025 2030 2035

CO 2 (million metric tons) 2,218 2,278 2,341 2,421 2,534 2,636

NO X (million tons) 2.24 2.06 2.02 2.03 2.06 2.07
Hg (tons) 40.6 30.6 30.1 30.0 30.2 30.3

Tables 15.2.3 and 15.2.4 show the estimated changes in power plant emissions by TSL for residential clothes dryers and room air conditioners. The tables display changes in CO 2 , NO
x , and Hg emissions in selected years for each of the TSLs. “Mt” re fers to “million metric tons.”

Similarly T able 15.2.5 shows household emissions impacts for residential clothes dryers by TSL in selected years. This table displays changes in CO 2 , NO X , and SO 2 emissions. There are no household emissions impacts for room air conditioners.15

- 11 Table 15.2.3 Power Sector Emissions Impact s Forecasts for Clothes Dryer TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1
CO2 (Mt/yr) 0.000 0.001 -0.002 -0.004 -0.005 -0.005 -0.005 -0.005 -0.104
NOx (1,000 tons/yr) 0.000 0.001 -0.002 -0.003 -0.004 -0.004 -0.004 -0.004 -0.084 Hg (ton/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Standard Level 2
CO2 (Mt/yr) 0.008 0.039 -0.058 -0.105 -0.147 -0.136 -0.136 -0.136 -2.97
NOx (1,000 tons/yr) 0.008 0.035 -0.050 -0.088 -0.119 -0.106 -0.106 -0.106 -2.39
Hg (ton/yr) 0.000 0.000 -0.001 0.000 0.000 0.000 0.000 0.000 -0.009

Standard Level 3 CO2 (Mt/yr) 0.048 0.235 -0.345 -0.625 -0.877 -0.808 -0.808 -0.808 -17.7 NOx (1,000 tons/yr) 0.049 0.212 -0.298 -0.525 -0.712 -0.633 -0.633 -0.633 -14.2 Hg (ton/yr) 0.000 0.000 -0.003 -0.001 -0.003 -0.002 -0.002 -0.002 -0.053

Standard Level 4 CO2 (Mt/yr) 0.047 0.227 -0.333 -0.603 -0.846 -0.779 -0.779 -0.779 -17.1 NOx (1,000 tons/yr) 0.047 0.205 -0.287 -0.507 -0.687 -0.611 -0.611 -0.611 -13.7 Hg (ton/yr) 0.000 0.000 -0.003 -0.001 -0.003 -0.002 -0.002 -0.002 -0.051

Standard Level 5 CO2 (Mt/yr) 0.173 0.837 -1.231 -2.227 -3.125 -2.878 -2.878 -2.878 -63.2 NOx (1,000 tons/yr) 0.174 0.757 -1.061 -1.871 -2.537 -2.256 -2.256 -2.256 -50.8 Hg (ton/yr) 0.001 -0.001 -0.012 -0.005 -0.009 -0.007 -0.007 -0.007 -0.188

Standard Level 6 CO2 (Mt/yr) 0.421 0.826 -3.279 -6.880 -8.205 -7.971 -7.971 -7.971 -179 NOx (1,000 tons/yr) 0.425 0.747 -2.825 -5.781 -6.662 -6.248 -6.248 -6.248 -145 Hg (ton/yr) 0.006 -0.009 -0.018 -0.015 -0.012 -0.022 -0.022 -0.022 -0.569

*CO 2 results are in metric tons, NO X and Hg results are in short tons. Extrapolation15

- 12 Table 15.2.4 Power Sector Emissions Impact Forecasts for Room Air Conditioner
TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1
CO2 (Mt/yr) 0.050 0.030 -0.338 -0.480 -0.408 -0.333 -0.333 -0.333 -9.83
NOx (1,000 tons/yr) 0.051 0.027 -0.291 -0.403 -0.331 -0.261 -0.261 -0.261 -8.02 Hg (ton/yr) 0.000 0.001 -0.001 -0.001 0.000 0.000 0.000 0.000 -0.012

Standard Level 2
CO2 (Mt/yr) 0.060 0.036 -0.403 -0.573 -0.491 -0.410 -0.410 -0.410 -11.9
NOx (1,000 tons/yr) 0.061 0.033 -0.347 -0.482 -0.398 -0.321 -0.321 -0.321 -9.69
Hg (ton/yr) 0.000 0.001 -0.001 -0.001 0.000 0.000 0.000 0.000 -0.015

Sandard Level 3 CO2 (Mt/yr) 0.073 0.042 -0.455 -0.613 -0.506 -0.418 -0.418 -0.418 -12.5 NOx (1,000 tons/yr) 0.074 0.038 -0.392 -0.515 -0.410 -0.327 -0.327 -0.327 -10.2 Hg (ton/yr) 0.000 0.001 -0.002 -0.001 0.000 0.000 0.000 0.000 -0.017

Standard Level 4 CO2 (Mt/yr) 0.097 0.056 -0.607 -0.833 -0.705 -0.604 -0.604 -0.604 -17.4 NOx (1,000 tons/yr) 0.097 0.051 -0.523 -0.700 -0.572 -0.474 -0.474 -0.474 -14.2 Hg (ton/yr) 0.001 0.001 -0.002 -0.002 -0.001 0.000 0.000 0.000 -0.022

Standard Level 5 CO2 (Mt/yr) 0.139 0.081 -0.892 -1.255 -1.091 -0.970 -0.970 -0.970 -26.9 NOx (1,000 tons/yr) 0.141 0.073 -0.769 -1.054 -0.885 -0.760 -0.760 -0.760 -21.9 Hg (ton/yr) 0.001 0.002 -0.003 -0.002 -0.001 0.000 0.000 0.000 -0.032

Standard Level 6 CO2 (Mt/yr) 0.186 0.108 -1.208 -1.726 -1.528 -1.396 -1.396 -1.396 -37.7 NOx (1,000 tons/yr) 0.187 0.098 -1.041 -1.450 -1.241 -1.094 -1.094 -1.094 -30.7 Hg (ton/yr) 0.001 0.002 -0.004 -0.003 -0.001 0.000 0.000 0.000 -0.044

*CO 2 results are in metric tons, NO X and Hg results are in short tons. Extrapolation15

- 13 Table 15.2.5 Household Emissions Impact Forecasts for Clothes Dryer TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1
CO2 (Mt/yr) 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.015
NOx (1,000 tons/yr) 0.000 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.012 SO2 (1,000 tons/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Standard Level 2
CO2 (Mt/yr) 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.021
NOx (1,000 tons/yr) 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.017
SO2 (1,000 tons/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Standard Level 3 CO2 (Mt/yr) 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.021 NOx (1,000 tons/yr) 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.017 SO2 (1,000 tons/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Standard Level 4 CO2 (Mt/yr) 0.000 -0.008 -0.031 -0.050 -0.064 -0.074 -0.074 -0.074 -1.57 NOx (1,000 tons/yr) 0.000 -0.007 -0.025 -0.040 -0.052 -0.060 -0.060 -0.060 -1.27 SO2 (1,000 tons/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 -0.010

Standard Level 5 CO2 (Mt/yr) 0.000 -0.039 -0.143 -0.232 -0.298 -0.344 -0.344 -0.344 -7.31 NOx (1,000 tons/yr) 0.000 -0.032 -0.115 -0.188 -0.241 -0.278 -0.278 -0.278 -5.90 SO2 (1,000 tons/yr) 0.000 0.000 -0.001 -0.001 -0.002 -0.002 -0.002 -0.002 -0.046

Standard Level 6 CO2 (Mt/yr) 0.000 -0.039 -0.143 -0.232 -0.298 -0.344 -0.344 -0.344 -7.31 NOx (1,000 tons/yr) 0.000 -0.032 -0.115 -0.188 -0.241 -0.278 -0.278 -0.278 -5.90 SO2 (1,000 tons/yr) 0.000 0.000 -0.001 -0.001 -0.002 -0.002 -0.002 -0.002 -0.046

*All results in metric tons (t), equivalent to 1.1 short tons Extrapolation15

- 14 15.2.5 Effects on Upstream Fuel

- Cycle Emissions

Upstream fuel -cycle emissions refer to the emissions associated with the amount of energy used in the upstream production and downstream consumption of electricity, including energy used at the power plant. 17 Upstream processes include the mining of coal or extraction of natural gas, physical preparatory and cleaning processes, and transportation to the power plant.
The NEMS -BT does a thorough accounting of emissions at the power plant due to downstream

energy consumption, but does not account for upstream emissions (i.e., emissions from energy losses during coal and natural gas production). Thus, this analysis reports only power plant
emissions.

However, previous DOE environmental assessment documents have d eveloped approximate estimates of effects on upstream fuel

- cycle emissions. These emissions factors provide the reader with a sense of the possible magnitude of upstream effects. These upstream
emissions would be in addition to emissions from direct combustion.

Relative to the entire fuel cycle, estimates based on the work of Dr. Mark DeLuchi, and reported in earlier DOE environmental assessment documents, find that an amount approximately equal to eight percent, by mass, of emissions (including SO 2 ) fro m coal production are due to mining, preparation that includes cleaning the coal, and transportation from the mine to the power plant. 18 Transportation emissions include emissions from the fuel used by the mode of transportation that moves the coal from the mine to the power plant. In addition, based on Dr. DeLuchi’s work, DOE estimated that an amount equal to approximately 14 percent of emissions from natural gas production result from upstream processes.

Emission factor estimates and corresponding percentages of contributions of upstream
emissions f rom coal and natural gas production, relative to power plant emissions, are shown in
Table 15.2.6 for CO 2 and NO X . The percentages provide a means to estimate upstream emission savings based on changes in emissions from power plants. This approach does not address Hg
emissions.

Table 15.2.6 Estimated Upstream Emissions of Air Pollutants as a Percentage of
Direct Power Plant Combustion Emissions

Pollutant Percent of Coal
Combustion Emissions Percent of Natural Gas
Combustion Emissions

CO 2 2.7 11.9

NO X 5.8 4015

- 15 15.3 WETLAND, ENDANGERED AND THREATENED SPECI ES, AND

CULTURAL RESOURCES

Beca use residential clothes dryers and room air conditioners are not water -consuming products, more energy efficient operation would not reduce the amount of water discharged into
the waste stre am. As a result, the energy conservation standards do not have the effect of improving the quality of wetlands, nor threatened or endangered species that reside in these wetlands. This action is also not expected to impact cultural resources such as historical or archaeological sites.

15.4 SOCIOECONOMIC IMPACT S

DOE's analysis has shown that the increase in the first cost of purchasing more efficient clothes dryers and room air conditioners at the proposed standard levels is, in most cases, completely offset by a reduction in the life -cycle cost (LCC) of owning a more efficient product for the average consumer. In other words, the consumer will pay less operating costs over the life of the product even through the first cost increases. The complete LCC analysis and its conclusions are presented in chapter 8 of the TSD.

For subgroups of low-income and senior consumers that purchase clothes dryer and room air conditioner products, DOE determined that the average LCC impact of the standards is similar to that for the full sample of consumers. Therefore, DOE concludes that the proposed standards would have no significant adverse socioeconomic impact. For a complete discussion on the LCC impacts on consumer subgroups, see chapter 11 of the TSD.

15.5 ENVIRONMENTAL JUSTIC E IMPACTS

In view of Executive Order 12898 of February 11, 1994, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,” DOE examined the effect of the energy conservation standards on low-income households. As described in the LCC subgroup analysis in chapter 11 of the TSD, DOE found that there were no disproportionately high and adverse human health or environmental effects on low- income populations that would result from the proposed energy conservation standards.

15.6 NOISE AND AESTHETICS

Improvements in efficiency of residential clothes dryers and room air conditioners are expected to result from changes in the choice of components and other design features. These changes are described in chapter 5 of this TSD. These design changes are not expected to change noise levels in comparison to products in today’s market. Products that are currently manufactured in the existing market t hat would meet the standards are no louder than less15

- 16 efficient products. Changes to the design to improve the efficiency levels are not anticipated to affect the product aesthetics.

15.7 SUMMARY OF ENVIRONME NTAL IMPACTS

Table 15.7.1 summarize s the estimated em issions impacts for each of the TSLs for clothes dryers and room air conditioners. It shows cumulative changes in emissions for CO 2 , NO X , and Hg for 2014 through 2043 for each of the TSLs . C umulative CO 2 , NO X , and Hg

e missions are reduced compared to the R eference case for all TSLs. For comparison, t he cumulative power sector emissions in the AEO 2010 R eference case, over the period 2014 through 2043, ar e 74,571 Mt for CO 2 , 61,625 kt for NOx, and 917 tons for Hg.

Upstream fuel cycle emission of CO 2 and NO X are described but not quantified in section
15.2.6 . The text describes potential reductions in fuel cycle emissions as percentage of decreases in power plant emissions. This approach suggests that upstream fuel cycle emissions would decrease and provides a sense for the magnitude of effects; however DOE does not report actual
estimates of the effects.

For subgroups of low-income and senior consumers that purchase room air conditioning and clothes dryer products, DOE determined that the average LCC impa ct of the standards is similar to that for the full sample of consumers. Therefore, DOE concludes that the proposed standards would have no significant adverse socioeconomic impact.

No impacts are anticipated in the area s of environmental justice, wetlan ds, endangered and threatened species, and cultural resources; or noise and aesthetics.

Table 15.7.1 Cumulative Emissions Reductions Under Clothes Dryer and Room Air
Conditioner TSLs *

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 Clothes Dryers
CO 2 (Mt)
NO X (1,000 tons ) Hg (t on) 0.119
0.097
0.000 2.99
2.41
0.009 17.7
14.3
0.053 18.7
15.1
0.051 70.5
57.3
0.188 187
151
0.569
Room Air Conditioners
CO 2 (Mt)
NO X (1,000 tons ) Hg (t on ) 9.83
8.02
0.012 11.9
9.69
0.015 12.5
10.2
0.01 7 17.4
14.2
0.02 2 26.9
21.9
0.03 2 37.7
30.7
0.044

* CO 2 results are in metric tons; NO X and Hg results are in short tons.15

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