DOE/EA-XXXX

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARDS FOR ELECTRICAL

DISTRIBUTION TRANSFORMERS

Month Year

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency & Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585

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ENVIRONMENTAL ASSESSMENT FOR ELECTRICAL DISTRIBUTION

TRANSFORMERS

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................. EA-1

2.0 METHODOLOGY ................................................ EA-1

3.0 RESULTS FORMAT .............................................. EA-2

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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 2003, DOE/EIA-0581(2003).

DOE/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 DOE/EIA assumptions, we refer to it as NEMS-BT (BT is DOE’s Building

Technologies Program).

EA-1

ENVIRONMENTAL ASSESSMENT FOR ELECTRICAL DISTRIBUTION

TRANSFORMERS

1.0 INTRODUCTION

The Department will assess the impacts of proposed distribution transformer standard

levels on certain environmental indicators using a variant of the U.S.DOE/Energy Information

Administration (EIA)’s National Energy Modelling System (NEMS).1 The DOE/EIA uses NEMS

to produce the Annual Energy Outlook 2003 (AEO2003).

2

 The Department will use a variant

known as NEMS-BT,a as well as some exogenous calculations, to provide key inputs to the

analysis. Results of the environmental analysis are similar to those provided in AEO2003.

The Department intends the environmental analysis 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 analysis considers two

pollutants, sulfur dioxide (SO2) and nitrogen oxides (NOx), as well as carbon emissions. The only

form of carbon tracked by NEMS-BT is carbon dioxide (CO2), so the carbon discussed in this

report is only in the form of CO2. For each of the trial standard levels, DOE will calculate total

undiscounted and discounted emissions using NEMS-BT and will use external analysis as needed. 

The Department will conduct the environmental analysis as a policy deviation from the

AEO2003, using the same basic set of assumptions. For example, the emissions characteristics of

an electricity generating plant will be exactly those used in AEO2003. The NEMS reference case

and alternative growth scenarios are as described in the utility impact analysis (Chapter 13).

2.0 METHODOLOGY

The NEMS-BT tracks carbon emissions using a detailed carbon module; this gives 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 NEMS-generated 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 displaces renewable

generating capacity in the later years of its forecast. On the whole, NEMS-BT provides carbon

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

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The NEMS-BT reports the two airborne pollutant emissions, SO2 and NOx, that DOE has

reported in past analyses. The Clean Air Act Amendments of 1990 set an SO2 emissions cap on

all power generation. Accurate simulation of SO2 trading tends to imply that physical emissions

effects will be zero, as long as emissions are at the ceiling. This fact has caused considerable

confusion in the past. However, there is an SO2 benefit from conservation in the form of a lower

allowance price as a result of additional allowances from this rule, and, if it is big enough to be

calculable by NEMS-BT, DOE will report this value. The NEMS-BT model also has an

algorithm for estimating NOx emissions from power generation. Two recent regulatory actions

proposed by the EPA regarding regulations and guidelines for best available retrofit technology

determinations and the reduction of interstate transport of fine particulate matter and ozone are

tending towards further NOx reductions and likely to an eventual emissions cap on nation-wide

NOx. 69 FR 25184 (May 5, 2004) and 69 FR 32684 (June 10, 2004). Therefore, as with SO2

emissions, a cap on NOx emissions will likely result in no physical emissions effects from

equipment efficiency standards. However, there is a NOx benefit from conservation in the form

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

enough to be calculable by NEMS-BT, DOE will report this value

3.0 RESULTS FORMAT

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

published in the AEO2003. These results include power sector emissions (or additional

allowances) for SO2, NOx, and carbon, and SO2 and NOx prices, in five-year forecasted

increments extrapolated to the year 2035. The Department reports the outcome of the analysis

for each trial standard level as a deviation from the AEO2003 reference cases.

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REFERENCES

1. U.S. Department of Energy-Energy Information Administration, National Energy

Modeling System: An Overview 2003, 2003. Report No. DOE/EIA-0581(2003).

<http://www.eia.doe.gov/oiaf/aeo/overview/index.html>

2. U.S. Department of Energy - Energy Information Administration, Annual Energy Outlook

2003: With Projections Through 2025, January, 2003. Washington, DC. Report No.

DOE/EIA-0383(2003). <http://www.eia.doe.gov/oiaf/aeo>

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