### 16-i 

## CHAPTER 16. ENVIRONMENTAL ASSESSMENT

TABLE OF CONTENTS

16.1 INTRODUCTION ......................................................................................................... 16-1

16.2 AIR EMISSIONS ANALYSIS ...................................................................................... 16-1

16.2.1 Air Emissions Descriptions ................................................................................ 16-1

16.2.2 Air Quality Regulation ....................................................................................... 16-3

16.2.3 Global Climate Change ...................................................................................... 16-4

16.2.4 Analytical Methods for Air Emissions .............................................................. 16-8

16.2.5 Effects on Power Plant Emissions ..................................................................... 16-9

16.2.6 Effects on Upstream Fuel-Cycle Emissions .................................................... 16-15

16.2.7 Economic Value of Emission Reductions ........................................................ 16-15

16.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND

CULTURAL RESOURCES ........................................................................................ 16-22

16.4 SOCIOECONOMIC IMPACTS .................................................................................. 16-22

16.5 ENVIRONMENTAL JUSTICE IMPACTS ................................................................ 16-22

16.6 NOISE AND AESTHETICS ....................................................................................... 16-23

16.7 SUMMARY OF ENVIRONMENTAL IMPACTS ..................................................... 16-23

REFERENCES ........................................................................................................................ 16-25

LIST OF TABLES

Table 16.2.1 Impact of Amended IRL and GSFL Efficacy Standards on Cumulative Energy-Related Emissions of CO 2 

## between 2012-2042 by Trial Standard Level (Million Metric Tons of CO 2 

## ) .................................................................. 16-7

Table 16.2.2 Power Sector Emissions Forecast from AEO2008 Reference Case ................. 16-10

Table 16.2.3 Power Sector Emissions Impact Forecasts IRL Under the Existing Technologies, Shift, Product Substitution Scenario ........................................ 16-11

Table 16.2.4 Power Sector Emissions Impact Forecasts for IRL Under the Emerging Technologies, Roll-up, No Product Substitution Scenario .............................. 16-12

Table 16.2.5 Power Sector Emissions Impact Forecasts for GSFL Under the Existing Technologies, Shift, High Lighting Expertise Scenario .................................. 16-13

Table 16.2.6 Power Sector Emissions Impact Forecasts for GSFL Under the Emerging Technologies, Roll-up, Market Segm ent Based Lighting Expertise

Scenario ............................................................................................................ 16-14

Table 16.2.7 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct

Power Plant Combustion Emissions ................................................................ 16-15

Table 16.2.8 Estimates of Savings from CO 2 

## Emissions Reductions under IRL Trial

Standard Levels at 7% Disc ount Rate and 3% Discount Rate ......................... 16-18

Table 16.2.9 Estimates of Savings from CO 2 

## Emissions Reductions under GSFL Trial

Standard Levels at 7% Disc ount Rate and 3% Discount Rate ......................... 16-18

### 16-ii 

## Table 16.2.10 Estimates of Monetary Savings from NOX Emissions Reductions under

IRL Trial Standard Levels at 7% Discount Rate and 3% Discount Rate ......... 16-19

Table 16.2.11 Estimates of Monetary Savings from NOX Emissions Reductions under

GSFL Trial Standard Levels at 7% Discount Rate and 3% Discount Rate ..... 16-19

Table 16.2.12 High Emission Rate Estimates of Mone tary Savings from Hg Emissions

Reductions under IRL Trial Standard Le vels at 7% Discount Rate and 3%

Discount Rate ................................................................................................... 16-20

Table 16.2.13 High Emission Rate Estimates of Mone tary Savings from Hg Emissions

Reductions under GSFL Trial Standard Levels at 7% Discount Rate and

3% Discount Rate ............................................................................................ 16-20

Table 16.7.1 Environmental Impact Analysis Results Summary for IRL ............................ 16-24

Table 16.7.2 Environmental Impact Analysis Results Summary for GSFL ......................... 16-24

LIST OF FIGURE

## CHAPTER 16. ENVIRONMENTAL ASSESSMENT

16.1 INTRODUCTION

This chapter describes potential environmen tal effects that may result from amended efficacy standards for incandescent reflector lamps (IRL) and general service fluorescent lamps (GSFL). The U.S. Department of Energy (DOE )’s proposed efficacy standards are not sitespecific, and would apply to all 50 States and U. S. territories. Therefor e, none of the proposed standards would impact land uses, cause any direct disturbance to the lan d, or directly affect biological resources in any one area.

All of the potential trial standard leve ls (TSLs) are expected to reduce energy consumption in comparison to a baseline efficac y level. These changes in the demand for electricity and the costs of achieving these savings are the primary drivers in analyzing

environmental effects. Estimates of source ener gy savings can be found in the national impact analysis in Chapter 11 of this technical suppor t document (TSD). Detailed discussion on TSLs can be found in Chapter 9 of this TSD.

The primary impact of the TSLs is in air quality resulting from changes in power plant operations and capacity additions. Therefore, mu ch of this chapter describes the air quality analysis.

16.2 AIR EMISSIONS ANALYSIS

The primary focus of the environmental analys is is the impact on air quality of amended efficacy standards for residential, commercial and industrial IRL and GSFL. The outcomes of the environmental analysis are driven by chan ges in power plant t ypes and quantities of electricity generated under each of the alternatives. Changes in generation are described in the utility impact analysis in Chapter 14.

16.2.1 Air Emissions Descriptions

For each of the TSLs, DOE calculated total power-sector emissions based on output from NEMS-BT model (see Chapter 14). This analysis considers three pollutant s: nitrogen oxides (NO X 

## ), mercury (Hg), and sulfur dioxide (SO 2 

## ). An air pollutant is a ny 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 part icles (i.e., particulates or particulate matter), liquid droplets, or gases a 

## . This analysis also considers carbon dioxide (CO 2 

## ).

Sulfur Dioxide (SO 2 

## )

a 

### More information on air pollution characteristics and regul ations is available on the U.S. Environment Protection Agent (EPA)’s website at http://www.epa.gov

16-1

## In addressing SO 2 

## emissions, the Clean Air Act Amendments of 1990 set an SO 2 

## emissions cap on all power generation, but pe rmitted flexibility among generators through the use of emissions allowances and tradable permits. This SO 2 

## trading process (sometimes called “cap and trade”) implies that the standard will have no affect on total physical emissions because emissions will always be at, or near, the allo wed emissions ceiling. Consequently, there is no

direct SO 2 

## environmental benefit from a reduction in el ectricity use due to the proposed efficacy standards, as long as there is enforcement of the emissions ceiling. But to the extent reduced power generation demand decreases the demand fo r and price of emissions allowance permits, there is an environmentally related economic benefit from the proposed efficacy standards reducing SO 2 

## emissions allowance demand. Furthermore, over time, if emissions decline, there is greater flexibility in reducing the ceiling am ount. However, since DOE does not anticipate a change in SO 2 

## emissions, SO 2 

## emission results are not repor ted in this Chapter.

Nitrogen Oxides (NO X 

## )

Nitrogen oxides

, or NO X 

## , are 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 la yer 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 tr igger 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.

Nitrogen oxides form when fossil fuel is bur ned at high temperatures, as in a combustion process. The primary manmade sources of NO X 

## are motor vehicles, elec tric utilities, and other industrial, commercial, and residentia l sources that burn fossil fuels. NO X 

## can also be formed naturally. Electric utilities acc ount for about 22 percent of NO X 

## emissions in the United States.

Mercury(Hg)

Coal-fired power plants emit Hg present in coal during the burning process. While coalfired power plants are the largest remaining s ource of human-generated Hg emissions in the United States, they contribute very little to th e global Hg pool or to contamination of U.S. waters. U.S. coal-fired power plants emit Hg in three different forms: oxidized Hg (likely to deposit within the United States); elemental H g, 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 estuarie s through rain, snow, and dry deposition. Once there, it can transform into methylmercur y and accumulate in fish tissue through

bioaccumulation.

Americans are exposed to methylmercury pr imarily 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 performa nce on neurobehavioral

16-2

## tasks, such as those measuring attention, fine motor function, language skills, visual-spatial abilities, and verbal memory.

Carbon Dioxide (CO 2 

## )

Carbon dioxide (CO 2 

## ) is not a regulated or criteria po llutant (see below), but it is of

interest because of its classifi cation 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 occurri ng GHGs include water vapor, CO 2 

## , methane (CH 4 

## ), nitrous oxide (N 2 

## O), and ozone (O 3 

## ). Human activities, however, add to th e 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 pr oducts are burned. During the past 20 years, about three-quarters of anthropogenic (i.e., human-made) CO 2 

## emissions resulted from burning

fossil fuels.

Concentrations of CO 2 

## in the atmosphere are naturally regulated by numerous processes, collectively known as the “carbon cycle.” The m ovement of carbon between the atmosphere and the land and oceans is dominated by natural processe s, such as plant photosynthesis. While these natural processes can absorb some of the anthropogenic CO 2 

## emissions produced each year,

billions of metric tons are added to th e atmosphere annually. In the U. S., CO 2 

## emissions from both energy generation and industr ial processes account for 8 4.6 percent of total U.S. GHG

emissions.

16.2.2 Air Quality Regulation

The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that EPA is required

to control. EPA has set nationa l air quality standards for six co mmon 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 acidificat ion 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 capand-trade program for SO 2 

## intended to help control acid rain. This cap-and-trade program serves as a model for more recent programs with similar 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). b 

## CAIR would permanently cap emissions of

SO 2 

## and NO X 

## in eastern States of the United States . CAIR required large reductions of SO 2 

## and/or NO X 

## emissions across 28 eastern states and the Di strict of Columbia. States must achieve the required emission reductions using one of two compliance options: 1) meet an emission budget for each regulated state by requiring power plants to partic ipate in an EPA-administered interstate cap-and-trade system th at caps emissions in two stages, or 2) meet an individual state emissions budget through measures of th e state’s choosing. Phase 1 caps for NO X 

## are to be in

b 

### 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, No. 05-1244, 2008 WL 5335481 (D.C. Cir. Dec. 23, 2008). Neither the July 11, 2008 nor the December 23, 2008 d ecisions of the D.C. Circ uit change the standardsetting proposals reached in this rule. See www.epa.gov/cleanairinterstaterule.

16-3

## place in 2009. Phase 1 caps for SO 2 

## are to be in place in 2010. The Phase 2 caps for both pollutants are due in 2015.

Also in 2005, EPA issued the final rule en titled “Standards of Performance for New and Existing Stationary Sources: Electric Steam Ge nerating Units,” under sections 110 and 111 of the Clean Air Act (40 CFR Parts 60, 63, 72, and 75) . This rule, also called the Clean Air Mercury Rule (CAMR), was closely related to the CAIR and estab lished 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 App eals for the District of Columbia Circuit (D.C. Circuit) issued its decision in State of New Jersey, et al. v. Environmental Protection Agency

, c 

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

On July 11, 2008, the U.S. Court of Appeals fo r 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. Envi ronmental Protection Agency on March 10, 2005. d



## CAIR was the basis under which NO X 

## emissions were capped

. e 

## However, even though the D.C. Circuit vacated the CAIR, DOE notes that the D.C. Circuit left intact a voluntary program set in place by EPA's 1998 NO X 

## SIP Call rule, which provided 23 ju risdictions with an option to implement a cap and trade emission program for NO X 

## emissions. See 63 Fed. Reg. 57356, 57359 (Oct. 27, 1998). f



## 16.2.3 Global Climate Change

Climate change has evolved into a matter of gl obal concern because it is expected to have widespread, adverse effects on natural resour ces and systems. A growing body of evidence points to anthropogenic sources of gree nhouse 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 St ates, 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 Chan ge on the Environment

c 

### No. 05-1097, 2008 WL 341338, at *1 (D.C. Cir. Feb. 8, 2008).

d 

### See www.epa.gov/cleanai rinterstaterule/

.

e 

### Case No. 05-1244, 2008 WL 2698180 at *1 (D.C. Cir. July 11, 2008).

f 

### In the NO X 

### SIP Call rule, EPA found that sources in the District of Columbia and 22 “upwind” states (States) were emitting NO X 

### (an ozone precursor) at levels that significantly contributed to “downwind” states not attaining the ozone NAAQS or at levels that interfered with states in a ttainment maintaining the ozone NAAQS. In an effort to

ensure that “downwind” states attain or continue to a ttain the ozone NAAQS, EPA established a region-wide cap for

NO X 

### emissions from certain large combustion sources and set a NO X 

### emissions budget for each State. In order to comply with the NO X 

### SIP Call Rule, States could elect to participate in the NO X 

### Budget Trading Program. Under

the NO X 

### Budget Trading Program, each emi ssion source is required to have one allowance for each ton of NO X 

### emitted during the ozone season. States have flexibility in how they allocate allowances through their State Implementation Plans but States must remain within the EPA-established budget. Emission sources are allowed to buy, sell and bank NO X 

### allowances as appropriate.

16-4

## Climate is usually defined as the average we ather, over a period ranging from months to many years. Climate change refers to a change in the state of the climate, which is identifiable through changes in the mean and/or the variabil ity of its properties (e.g., temperature or precipitation) over an extended perio d, typically decades or longer.

The World Meteorological Organization a nd United Nations E nvironment Programme (UNEP) established the Intergovernmental Pa nel on Climate Change (IPCC) to provide an objective source of information about climat e change. According to the IPCC Fourth Assessment Report (IPCC Report), published in 2007, climate change is consistent with observed changes to the world’s na tural systems; the IPCC expects these changes to continue.

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 2003; loss of annual average Arctic sea i ce at a rate of 2.7 % 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 a nd more frequent heat waves in many locations worldwide, and numerous ecological changes.

Looking forward, the IPCC describes con tinued 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 (GHG)s, and aerosols. After that period, the ra te 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 t oday. These increases vary depending on the model

and emissions scenarios.

The IPCC Report describes incremental impacts a ssociated 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 increas ing degree of impacts such as coral reef bleaching, loss of wild life habitat, loss to specific ecosystems, and negative yield impacts for major cereal crops in the tropics, but al so projects that there likely will be some beneficial impacts on crop yields in temperate regions.

Causes of Climate Change

The IPCC Report states that the world has wa rmed by about 0.74°C in the last 100 years. The IPCC Report finds that most of the temperat ure increase since the mi d-20th century is very likely due to the increase in anth ropogenic concentrations of CO 2 

## and other long-lived greenhouse gases (GHGs) 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 ther eby alters the energy balance of the planet, which gradually increases its average temperature. The IPCC

16-5

## Report estimates that currently, CO 2 

## makes up about 77% of the total CO 2 

## -equivalent g 

## global warming potential in GHGs emitted from human activit ies, with the vast ma jority (74%) of the

CO 2 

## attributable to fossil fuel use. For the fu ture, the IPCC Report describes a wide range of GHG emissions scenarios, but under each scenario CO 2 

## would continue to comprise above 70% of the total global warming potential.

Stabilization of CO 2 

## Concentrations

Unlike many traditional air pollutants, CO 2 

## mixes thoroughly in the entire atmosphere and is long-lived. Th e residence time of CO 2 

## in the atmosphere is long compared to the emission processes. Therefore, the gl obal cumulative emissions of CO 2 

## over long periods determine CO 2 

## concentrations because it takes hundreds of y ears 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



## . h



## Researchers have focused on considering atmospheric CO 2 

## concentrations that likely will result in some level of globa l climate stabilization, and the emission rates associated with achieving the “stabilizing” concentrations by partic ular 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 this low 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 leve ls). To achieve concentrations between 350 ppm to 400 ppm, the IPCC scenarios pr esent that there would have to be a rapid downward trend in total annual gl obal emissions of greenhouse gase s to levels that are 50% to 85% below today’s annual emission rates by no later than 2050. Since it is assumed that there would continue to be growth in global populations and substantial increases in economic production, the scenarios identify required re ductions in greenhouse gas emissions intensity (emissions per unit of output) of more than 90%. 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.

The Beneficial Impact of the Rule on CO 2 

## Emissions

If finalized, it is anticipated thatthe Rule will reduce energy-related CO 2 

## emissions, particularly those associated with energy consum ption in buildings. In the United States, the U.S. Energy Information Administration (EIA ) reports in its 2 008 Annual Energy Outlook ( AEO2008 ) 1 

## that U.S. annual energy-related emissions of CO 2 

## in 2005 were about 6.0 billion

g 

### GHGs differ in their warming influence (radiative forci ng) on a global climate syst em 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.

h 

### Other non-fossil fuel contributors include CO 2 

### emissions from deforest ation 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 2

16-6

## metric tons (about 20 percent of the world energy-related CO 2 

## emissions and about 12 percent of total global greenhouse gas emissions), of which 2.4 billion tons were attributed to the electric power sector. In the AEO2008 Reference Case, EIA projected that annual energy-related CO 2 

## emissions would grow from 6.0 billion metric tons in 2005 to 6.9 billion metric tons in 2030, an increase of 15 percent (see AEO2008 ), while emissions attributable to the electric power sector would grow to 2.9 billion tons, an increase of 23 percent.

As shown in Table 16.2.2 in the AEO2008 Reference Case, the cumulative U.S. energyrelated power sector CO 2 

## emissions between 2012 and 2042 are described at about 86 billion

metric tons. The estimated cumulative CO 2 

## emission reductions from amended IRL and GSFL efficacy standards during this same 30-year period are indicated in Table 16.2.1. Estimated CO 2 

## emission reductions in Table 16.2.1 come from elect ricity generation (i.e., power plants). The

estimated CO 2 

## emission reductions from electricity gene ration are calculated using the NEMSBT model.

Table 16.2.1 Impact of Amended IRL and GSFL Efficacy Standards on Cumulative Energy-Related Emissions of CO 2 

## between 2012-2042 by Trial Standard Level (Million Metric Tons of CO 2 

## )

GSFL

TSL Estimated Cumulative CO2 (MMt) Emission

Reductions

1 85.7 to 236.4

2 103.5 to 233.7

3 184.3 to 395.2

4 239.7 to 597.7

5 312.8 to 679.7

IRL

TSL Estimated Cumulative CO2 (MMt) Emission

Reductions

1 10.3 to 17.7

2 25.1 to 44.8

3 46.2 to 88.1

4 58.6 to 114.4

5 79.3 to 118.8



## The estimated savings shown in Table 16.2.1, which are at most 0.9 percent of U.S.

emissions of CO 2 

## from electricity generation (total em issions reported for TSL 5 in Table 16.2.1 combining IRL and GSFL), comprise an even sm aller fraction of U.S. emissions of greenhouse gases and of world emissions of greenhouse gase s. However, the savings would likely reduce

overall U.S. CO 2 

## emissions, as compared to U.S. CO 2 

## emissions absent an increase in the required efficacy of IRLs and GSFLs.

The Incremental Impact of th e Rule on Climate Change

It is difficult to correlate specific emissi on rates with atmospheri c concentrations of CO 2 

## and specific atmospheric concentrations with future temperatures because the IPCC Report

16-7

## describes a clear lag in the climate syst em between any given concentration of CO 2 

## (even if maintained for long periods) and the subsequent average worldwide and regional temperature, precipitation, and extreme weathe r regimes. For example, a major determinant of climate response is “equilibrium climate sensitivity”, a measure of the climate system response to sustained radioactive forcing. It is defined as the global average surface warming following a doubling of carbon dioxide concentrations. Th e 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 sp ecific temperature levels.

Because of the complexity of global climate sy stems, it is difficult to know to what extent and when particular CO 2 

## emissions rates will impact global warming. However, as Table 16.2.1 indicates, the Rule will likely reduce CO 2 

## emissions rates from the electric power sector.

16.2.4 Analyti cal Methods for Air Emissions

NEMS-BT incorporates capabilit ies to assess compliance with SO 2 

## restrictions specified

in the Clean Air Act and its amendments. Clean air act provisi ons include New Source Performance Standards, and Re vised New Source Performance St andards. The version of NEMS-BT in 2008 also included provisions for the CAIR, which imposes stricter restrictions on

SO 2 

## and NO X 

## for some states, and the CAMR, which imposed a national Hg constraint. As discussed earlier is section 16.2.2, on July 11, 2008, th e U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its decision in North Carolina v. Environmental Protection Agency , vacating the CAIR. 531 F.3d 896 (D.C . Cir. 2008). Although the constraints

on NO X 

## in CAIR and Hg in CAMR have sinc e been vacated by a court decision, the AEO2008

Reference Case assumes that emissions of NO X 

## and Hg would decline over time as shown in

Table 16.2.2.

Because the courts vacated CAIR and CA MR, the 2008 version of NEMS-BT could not be used directly to estimate emissions impacts for NO X 

## and Hg. Instead, DOE established a range of NO X 

## reductions due to standards. DOE’s high estimate was based on the use of a

nationwide NO X 

## emission rate for electrical gene ration. DOE derived a current NO X 

## emission rate for the power sector based on data from the AEO2008 . DOE based the emission rate on the

tons of NO X 

## emitted per TWh of electricity gene rated in the year 2006. For 2006, the NO X 

## emission rate was 0.764 kt/TWh (0.842 thousand short tons/TWh). DOE’s low estimate was

based on the use of an emission rate for new co mbined-cycle gas plants as provided in the NEMS-BT. This emission rate equals 0.0310 kt/TWh (0.0341 thousand short tons/TWh) and represents the lowest emission ra te of fossil-fuel based generation that might be displaced under

standards. To estimate the reduction in NO X 

## emissions from the power sector, DOE multiplied these emission rates by the reduction in electricity generation due to the standards considered as determined by the utility impact analysis (see Chap ter 14, Utility Impact Analysis). The range in

NO X 

## emission changes calculated using the low a nd high estimate scenarios are shown by TSL for IRL and GSFL in Table 16.2.3 through 16.2.6 for the period from 2012 to 2042.

16-8

## DOE estimated the physical quantity change s in Hg emissions associated with the efficacy standard. As opposed to using the NEMS-BT model, DOE established a range of Hg reductions due to standards. DOE’s high estimate used a Hg emission rate based on the

AEO2008 . Because virtually all Hg emitted from electricity generation is from coal-fired power plants, DOE based the emission rate from the t ons of Hg emitted per TWh of coal-generated electricity. DOE based the emission rate on the average value reported in the AEO2008 for the year 2006. This emission rate is 0.0230 metric tons per TWh (0.0253 short tons/TWh). DOE’s

low estimate was based on the use of an emissi on rate for new combined-cycle gas plants as provided in the NEMS-BT. The emission rate for this generation technology is 0.000 tons per TWh. To estimate the reduction in Hg emissions from the power sector, DOE multiplied the low and high emission rates by the redu ction in coal-generated elect ricity due to the standards considered as determined in the utility impact an alysis (see Chapter 14, Utility Impact Analysis). The estimated changes in Hg emissions are shown by TSL for IRL and GSFL in Table 16.2.3 through Table 16.2.6 for the period from 2012 to 2042.

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

well as the sulfur contents of the fuel us ed when determining optimal dispatch.

Within the NEMS-BT model, pl anning options for achieving em issions restrictions in the Clean Air Act Amendments include installing pollution control equipment on existing power plants and building new power plants with lo w emission rates. These methods for reducing emission are compared to dispatching options su ch as fuel switching and allowance trading. Environmental regulations also a ffect 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 invo lve purchasing allowances or over complying at an existing unit.

Modeling of SO 2 

## trading tends to imply that the phys ical emissions effects will be zero, as long as emissions are at the allowed ceiling. Because SO 2 

## has been regulated with emissions caps for more than a decade, and no emissions reductions are reported from the NEMS-BT forecast model, DOE does not report SO 2 

## results here. This assu mption is consistent with previous DOE environmental assessment documents.

As noted in Chapter 14, NEMS-BT model for ecasts end in year 2030. Emissions impacts beyond 2030 were extrapolated for this rulemaking in Table 16.2.3 through 16.2.6.

16.2 .5 Effects on Power Plant Emissions

Table 16.2.2 shows the AEO2008 Reference Case power plant emissions in selected years along with the extrapolation to 2042. The Refe rence case emissions are the emissions shown by

the NEMS-BT model to result if non e of the TSLs are promulgated.

16-9

## Tabl e 16.2.2 Power Sector Emissions Forecast from AEO2008 Reference Case

NEMS-BT Results*:

2005 2010 2015 2020 2025 2030 Total

2012-

2042 ††



## CO 2 

## (Million tons)** 2,397 2,413 2,519 2,627 2,771 2,948 85,998



## NO X 

## (Million tons) † 

## 6.02 2.11 1.91 1.91 1.94 1.96 60.9

Hg (tons) † 

## 46.91 33.78 22.45 17.44 15.31 13.56 522.2

* All 

### units are metric , equivalent to 1.1 short tons

** Comparable to Table A18 of AEO2008 : Electric Power

† 

### Comparable to Table A8 of AEO2008 : Electric Power Sector Emissions

†† 

### Extrapolated by assuming 2030 end values in all subsequent years 2031-2042.



## Table 16.2.3 through Table 16.2.6 show the esti mated changes in power plant emissions in selected years for all the TSLs. Changes in CO 2 

## , NO X 

## and Hg emissions from power plants are shown in these tables. Compared to the antic ipated reference case emissions impacts forecast shown in Table 16.2.2, changes in emission levels shown in Table 16.2.3 though 16.2.6 are extremely small.

16-10

## Table 1 6.2.3 Power Sector Emissions Impact Forecasts IRL Under the Existing Technologies, Shift, Produc t Substitution Scenario

IRL Existin g Technolo g ies, Shift Product Substitution Scenario

NEMS-BT Results Difference from AEO2008 Reference Case
Exptrapolation Total

Trial Standard Level 1 2010 2015 2020 2025 2030 2035 2040 2042 2012-2042
Power Sector CO2 (MMT CO2) ( 0.01 ) ( 0.53 ) ( 0.71 ) ( 0.70 ) ( 0.54 ) ( 0.54 ) ( 0.54 ) ( 0.54 ) ( 17.7 )

Nitrogen Oxides - Low (kt) ( 0.00 ) ( 0.03 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 1.2 )
Nitrogen Oxides - High (kt) (0.00) (0.81) (0.88) (0.98) (1.02) (1.02) (1.02) (1.02) (29.0)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) ( 0.00 ) ( 0.00 ) ( 0.01 ) ( 0.01 ) ( 0.01 ) ( 0.01 ) ( 0.01 ) ( 0.01 ) ( 0.2 )

Trial Standard Level 2 Power Sector CO2 (MMT CO2) (0.01) (1.42) (1.88) (1.81) (1.23) (1.23) (1.23) (1.23) (44.8)

Nitrogen Oxides - Low (kt) ( 0.00 ) ( 0.09 ) ( 0.10 ) ( 0.11 ) ( 0.11 ) ( 0.11 ) ( 0.11 ) ( 0.11 ) ( 3.1 )

Nitrogen Oxides - High (kt) ( 0.01 ) ( 2.15 ) ( 2.36 ) ( 2.61 ) ( 2.69 ) ( 2.69 ) ( 2.69 ) ( 2.69 ) ( 77.6 )

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.01) (0.04) (0.04) (0.01) (0.01) (0.01) (0.01) (0.6)

Trial Standard Level 3
Power Sector CO2 (MMT CO2) ( 0.01 ) ( 2.58 ) ( 3.33 ) ( 3.45 ) ( 2.73 ) ( 2.73 ) ( 2.73 ) ( 2.73 ) ( 88.1 )

Nitrogen Oxides - Low (kt) (0.00) (0.16) (0.17) (0.19) (0.20) (0.20) (0.20) (0.20) (5.7)

Nitrogen Oxides - High (kt) (0.02) (3.87) (4.25) (4.70) (4.94) (4.94) (4.94) (4.94) (140.6)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) ( 0.00 ) ( 0.02 ) ( 0.06 ) ( 0.08 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 0.04 ) ( 1.3 )

Trial Standard Level 4
Power Sector CO2 (MMT CO2) ( 0.01 ) ( 3.44 ) ( 4.31 ) ( 4.35 ) ( 3.55 ) ( 3.55 ) ( 3.55 ) ( 3.55 ) ( 114.4 )

Nitrogen Oxides - Low (kt) ( 0.00 ) ( 0.21 ) ( 0.23 ) ( 0.25 ) ( 0.25 ) ( 0.25 ) ( 0.25 ) ( 0.25 ) ( 7.3 )
Nitrogen Oxides - High (kt) (0.02) (5.10) (5.57) (6.16) (6.26) (6.26) (6.26) (6.26) (180.7)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.03) (0.08) (0.09) (0.05) (0.05) (0.05) (0.05) (1.7)

Trial Standard Level 5
Power Sector CO2 (MMT CO2) (0.02) (3.58) (4.64) (4.59) (3.60) (3.60) (3.60) (3.60) (118.8)

Nitrogen Oxides - Low (kt) ( 0.00 ) ( 0.22 ) ( 0.24 ) ( 0.26 ) ( 0.27 ) ( 0.27 ) ( 0.27 ) ( 0.27 ) ( 7.8 )

Nitrogen Oxides - High (kt) ( 0.03 ) ( 5.35 ) ( 5.88 ) ( 6.48 ) ( 6.76 ) ( 6.76 ) ( 6.76 ) ( 6.76 ) ( 193.1 )

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.03) (0.08) (0.10) (0.04) (0.04) (0.04) (0.04) (1.7)



### Note: All units are metric tons, equivalent to 1.1 short tons and negative values re fer to a reduction compared with the Base

Case.



### 16-11

## Table 1 6.2.4 Power Sector Emissions Impact Fo recasts for IRL Under the Emerging Technologies, Roll-up, No Product Substitution Scenario

IRL Emer g in g Technolo g ies Roll-u p No Product Substitution Scenario

NEMS-BT Results Difference from AEO2008 Reference Case
Exptrapolation Total

Trial Standard Level 1 2010 2015 2020 2025 2030 2035 2040 2042 2012-2042
Power Sector CO2 (MMT CO2) (0.00) (0.35) (0.42) (0.35) (0.30) (0.30) (0.30) (0.30) (10.3)

Nitrogen Oxides - Low (kt) 0.00 (0.02) (0.02) (0.02) (0.02) (0.02) (0.02) (0.02) (0.7)
Nitrogen Oxides - High (kt) 0.00 (0.52) (0.51) (0.51) (0.57) (0.57) (0.57) (0.57) (16.7)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.00) (0.01) (0.01) (0.00) (0.00) (0.00) (0.00) (0.1)

Trial Standard Level 2 Power Sector CO2 (MMT CO2) (0.00) (0.84) (0.88) (0.85) (0.76) (0.76) (0.76) (0.76) (25.1)

Nitrogen Oxides - Low (kt) 0.00 (0.05) (0.05) (0.05) (0.05) (0.05) (0.05) (0.05) (1.6)

Nitrogen Oxides - High (kt) 0.00 (1.27) (1.13) (1.22) (1.31) (1.31) (1.31) (1.31) (39.3)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.01) (0.01) (0.02) (0.01) (0.01) (0.01) (0.01) (0.3)

Trial Standard Level 3
Power Sector CO2 (MMT CO2) (0.00) (1.60) (1.68) (1.66) (1.37) (1.37) (1.37) (1.37) (46.2)

Nitrogen Oxides - Low (kt) 0.00 (0.10) (0.09) (0.09) (0.10) (0.10) (0.10) (0.10) (3.0)
Nitrogen Oxides - High (kt) 0.00 (2.40) (2.18) (2.33) (2.53) (2.53) (2.53) (2.53) (74.9)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.01) (0.03) (0.04) (0.01) (0.01) (0.01) (0.01) (0.6)

Trial Standard Level 4
Power Sector CO2 (MMT CO2) 0.00 (1.94) (2.17) (2.00) (1.77) (1.77) (1.77) (1.77) (58.6)

Nitrogen Oxides - Low (kt) 0.00 (0.12) (0.11) (0.12) (0.13) (0.13) (0.13) (0.13) (3.8)
Nitrogen Oxides - High (kt) 0.01 (2.96) (2.74) (2.86) (3.19) (3.19) (3.19) (3.19) (93.9)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.01) (0.04) (0.04) (0.02) (0.02) (0.02) (0.02) (0.8)

Trial Standard Level 5
Power Sector CO2 (MMT CO2) (0.01) (2.38) (2.57) (2.77) (2.59) (2.59) (2.59) (2.59) (79.3)

Nitrogen Oxides - Low (kt) 0.00 (0.14) (0.13) (0.14) (0.15) (0.15) (0.15) (0.15) (4.5)

Nitrogen Oxides - High (kt) 0.00 (3.54) (3.26) (3.44) (3.83) (3.83) (3.83) (3.83) (112.4)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.00) (0.02) (0.04) (0.07) (0.05) (0.05) (0.05) (0.05) (1.3)



### Note: All units are metric tons, equivalent to 1.1 short tons and negative values re fer to a reduction compared with the Base

Case.



### 16-12

## Table 1 6.2.5 Power Sector Emissions Impact Foreca sts for GSFL Under the Existing Technologies, Shift, High Li ghting Expertise Scenario

NEMS-BT Results Difference from AEO2008 Reference Case
Exptrapolation Total

Trial Standard Level 1 2010 2015 2020 2025 2030 2035 2040 2042 2012-2042

Power Sector CO2 (MMT CO2) (0.1) (4.6) (8.4) (9.1) (8.4) (8.4) (8.4) (8.4) (236.4)

Nitrogen Oxides - Low (kt) (0.0) (0.3) (0.4) (0.5) (0.6) (0.6) (0.6) (0.6) (14.1)

Nitrogen Oxides - High (kt) (0.0) (6.6) (9.6) (12.3) (13.7) (13.7) (13.7) (13.7) (347.4)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) ( 0.0 ) ( 0.0 ) ( 0.2 ) ( 0.2 ) ( 0.1 ) ( 0.1 ) ( 0.1 ) ( 0.1 ) ( 4.2 )

Trial Standard Level 2
Power Sector CO2 (MMT CO2) (0.1) (5.2) (8.2) (9.1) (8.1) (8.1) (8.1) (8.1) (233.7)

Nitrogen Oxides - Low (kt) (0.0) (0.3) (0.4) (0.5) (0.6) (0.6) (0.6) (0.6) (14.6)

Nitrogen Oxides - High (kt) ( 0.0 ) ( 7.7 ) ( 10.1 ) ( 12.5 ) ( 13.9 ) ( 13.9 ) ( 13.9 ) ( 13.9 ) ( 361.1 )

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.0) (0.2) (0.2) (0.1) (0.1) (0.1) (0.1) (3.8)

Trial Standard Level 3
Power Sector CO2 (MMT CO2) ( 0.1 ) ( 9.8 ) ( 14.8 ) ( 16.0 ) ( 12.7 ) ( 12.7 ) ( 12.7 ) ( 12.7 ) ( 395.2 )
Nitrogen Oxides - Low (kt) (0.0) (0.6) (0.7) (0.9) (0.9) (0.9) (0.9) (0.9) (25.2)
Nitrogen Oxides - High (kt) (0.1) (13.8) (18.2) (22.8) (23.2) (23.2) (23.2) (23.2) (623.0)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.1) (0.3) (0.4) (0.2) (0.2) (0.2) (0.2) (6.9)

Trial Standard Level 4
Power Sector CO2 (MMT CO2) 0.1 ( 20.9 ) ( 25.6 ) ( 24.2 ) ( 16.1 ) ( 16.1 ) ( 16.1 ) ( 16.1 ) ( 597.7 )
Nitrogen Oxides - Low (kt) (0.0) (1.2) (1.3) (1.3) (1.2) (1.2) (1.2) (1.2) (38.5)
Nitrogen Oxides - High (kt) (0.2) (30.2) (33.1) (33.0) (30.8) (30.8) (30.8) (30.8) (950.7)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.2) (0.5) (0.5) (0.1) (0.1) (0.1) (0.1) (7.9)

Trial Standard Level 5
Power Sector CO2 (MMT CO2) ( 0.1 ) ( 22.9 ) ( 27.7 ) ( 28.2 ) ( 18.6 ) ( 18.6 ) ( 18.6 ) ( 18.6 ) ( 679.7 )
Nitrogen Oxides - Low (kt) (0.0) (1.3) (1.5) (1.5) (1.4) (1.4) (1.4) (1.4) (43.3)

Nitrogen Oxides - High (kt) ( 0.2 ) ( 32.3 ) ( 36.1 ) ( 37.5 ) ( 35.8 ) ( 35.8 ) ( 35.8 ) ( 35.8 ) ( 1,071.6 )
Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.2) (0.5) (0.6) (0.1) (0.1) (0.1) (0.1) (9.1)



### Note: All units are metric tons, equivalent to 1.1 short tons and negative values re fer to a reduction compared with the Base

Case.



### 16-13

## Table 16.2.6 Power Sector Emissions Impact Foreca sts for GSFL Under the Emerging Technologies, Roll-up, Market Segment Based Lighting Expertise Scenario

NEMS-BT Results Difference from AEO2008 Reference Case
Exptrapolation Total

Trial Standard Level 1 2010 2015 2020 2025 2030 2035 2040 2042 2012-2042

Power Sector CO2 (MMT CO2) 0.0 (1.9) (2.9) (3.2) (3.1) (3.1) (3.1) (3.1) (85.7)

Nitrogen Oxides - Low (kt) (0.0) (0.1) (0.1) (0.2) (0.2) (0.2) (0.2) (0.2) (5.1)

Nitrogen Oxides - High (kt) (0.0) (2.7) (3.4) (4.2) (5.0) (5.0) (5.0) (5.0) (126.9)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.0) (0.1) (0.1) (0.0) (0.0) (0.0) (0.0) (1.5)

Trial Standard Level 2
Power Sector CO2 (MMT CO2) (0.0) (3.5) (3.8) (3.8) (3.1) (3.1) (3.1) (3.1) (103.5)

Nitrogen Oxides - Low (kt) (0.0) (0.2) (0.2) (0.2) (0.2) (0.2) (0.2) (0.2) (6.8)

Nitrogen Oxides - High (kt) (0.0) (5.1) (5.0) (5.4) (5.9) (5.9) (5.9) (5.9) (167.0)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.0) (0.1) (0.1) (0.0) (0.0) (0.0) (0.0) (1.5)

Trial Standard Level 3
Power Sector CO2 (MMT CO2) 0.1 (5.5) (7.4) (7.1) (5.6) (5.6) (5.6) (5.6) (184.3)
Nitrogen Oxides - Low (kt) (0.0) (0.3) (0.4) (0.4) (0.4) (0.4) (0.4) (0.4) (11.7)
Nitrogen Oxides - High (kt) (0.1) (8.0) (8.8) (10.1) (10.2) (10.2) (10.2) (10.2) (289.4)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) 0.0 (0.1) (0.2) (0.2) (0.1) (0.1) (0.1) (0.1) (2.9)

Trial Standard Level 4
Power Sector CO2 (MMT CO2) 0.1 (9.4) (10.6) (9.4) (6.1) (6.1) (6.1) (6.1) (239.7)
Nitrogen Oxides - Low (kt) (0.0) (0.6) (0.5) (0.5) (0.5) (0.5) (0.5) (0.5) (16.5)
Nitrogen Oxides - High (kt) (0.0) (14.1) (13.4) (13.3) (13.2) (13.2) (13.2) (13.2) (407.0)

Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.1) (0.2) (0.2) (0.1) (0.1) (0.1) (0.1) (3.2)

Trial Standard Level 5
Power Sector CO2 (MMT CO2) 0.1 (11.4) (13.7) (12.9) (8.2) (8.2) (8.2) (8.2) (312.8)
Nitrogen Oxides - Low (kt) (0.0) (0.7) (0.7) (0.7) (0.7) (0.7) (0.7) (0.7) (20.3)

Nitrogen Oxides - High (kt) (0.1) (16.5) (16.6) (17.4) (16.3) (16.3) (16.3) (16.3) (502.5)
Mercury (Hg) - Low (t)

- - - - - - - - - Mercury (Hg) - High (t) (0.0) (0.1) (0.3) (0.3) (0.1) (0.1) (0.1) (0.1) (4.4)



### Note: All units are metric tons, equivalent to 1.1 short tons and negative values re fer to a reduction compared with the Base

Case.



### 16-14

## 16.2.6 Effects on Upstream Fuel-Cycle Emissions

Fuel-cycle emissions refer to the emissions associated with the am ount of energy used in the upstream production and downstream consumpti on of electricity, including energy used at the power plant. Upstream processes include the mining of coal or extraction of natural gas, physical preparatory and cleaning processes, and transportation to the power plant. The NEMSBT 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 produc tion). Thus, this analysis re ports only power plant emissions.

However, previous DOE environmental assessment documents have developed qualitative estimates of affects on upstream fuel -cycle emissions. These emissions factors provide the reader with a sense of the possible ma gnitude of upstream effects. These upstream

emissions would be in addition to emissions from direct combustion. Relativ e 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 

## ) from coal production are due to mining, preparation that includes cleaning the coal, and transporta tion from the mine to the power plant. 2 

## Transportation emissions include emissions from the fuel used by the mode of transportati on that moves the coal from the mine to the power plant.

In addition, based on Dr. DeLu chi’s work, DOE estimated that approximately an amount equal to 14 percent of emissions from natural ga s production result from upstream processes. Emission factor estimates and corresponding percen tages of contributions of upstream emissions from coal and natural gas production, relative to power plant emissions, are shown in Table

16.2.7 for CO 2 

## and NO X 

## . The percentages are relative to power plant emissions and provide a means to estimate upstream emission savings based on changes in emissions from power plants. The percentage effects presented in Table 16.2.7 provides a qualitative approach to viewing effects on fuel cycle emissions. The previous section indicates slight overall reductions in CO 2 

## and NO X 

## . Thus, very small reductions in upstream emi ssions of air pollutant could be expected. This approach does not address Hg emissions.

Table 1 6.2.7 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 40



## 16.2.7 Econom ic Value of Emission Reductions

In examining the impact of potential efficacy standards, DOE assessed potential monetary

benefits from reduced emissions of CO 2 

## , NO X 

## , Hg, and SO 2 

## associated with this rulemaking.

With regard to CO 2 

## , the monetary estimates presen ted below in Tables 16.2.8 through 16.2.13 are based on an assumption of a range from no benefit to an average benefit value

16-15

## reported by the Intergovernmental Panel on Climate Change (IPCC). j 

## It is important to note that the IPCC estimate used as the upper bound value was derived from an estimate of the mean value of worldwide impacts from pot ential climate impacts caused by CO 2 

## emissions, and not just the effects likely to occur within the Unite d States. As DOE considers a monetary value for

CO 2 

## emission reductions, the value should be restricted to a representation of those costs/benefits likely to be experienced in the United States. As DOE expects that such values would be lower than comparable global values, however, there cu rrently are no consensus estimates for the U.S. benefits likely to result from CO 2 

## emission reductions. However, DOE believes it is appropriate to use U.S. benefit values, where available, and not world benefit va lues in its analysis. k


## Because U.S. specific estimates are not available, and DOE did not receive any additional information that would help serve to narrow th e proposed range as a representative range for domestic U.S. benefits, DOE belie ves it is appropriate to propose the global mean value as an appropriate upper bound U.S. value for purposes of sensitivity analysis.

Given the uncertainty surrounding estimates of the societal cost of carbon (SCC), relying on any single study may be inadvisable since its estimate of the SCC will depend on many assumptions made by its authors. The Wo rking Group II’s contribution to the Fourth Assessment Report of th e IPCC notes that:

The large ranges of SCC are due in the large part to differenc es in assumptions regarding climate sensitivity, response lags, the treatm ent of risk and equity, economic and noneconomic impacts, the inclusion of potential ly catastrophic losses, and discount rates. 3



## Because of this uncertainty, DOE is relying on research performed by Tol, 4 

## which was presented in the IPCC’s Fourth Assessment Repo rt, and was a comprehensive meta-analysis of

estimates for the value of SCC.

DOE continues to believe that the most approp riate monetary values for consideration in the development of efficacy standards are those dr awn from studies that attempt to estimate the present value of the marginal economic benefits likely to result from reducing greenhouse gas emissions, rather than estimates that are based on the market value of emission allowances under existing cap and trade programs or estimates that are based on the cost of reducing emissions - both of which are largely determined by policy decisions that set the timing and extent of

j 

### During the preparation of its most recent review of the state of climate sc ience, the Intergovernmental Panel on Climate Change (IPCC) identified various estimates of th e present value of reducing carbon-dioxide emissions by one ton over the life that these emissions would remain in the atmosphere. The estimates reviewed by the IPCC spanned a range of values. In the absence of a consensus on any single estimate of the monetary value of CO 2 

### emissions, DOE used the estimates identified by the study cited in Summary for Policymakers prepared by Working Group II of the IPCC’s Fourth Assessment Report to estimate the potential monetary value of CO 2 

### reductions likely to result from standards finalized in this rulemaking. A ccording to IPCC, the mean so cial cost of carbon (SCC) reported in studies published in peer-reviewed journals was $43 per ton of carbon. This translates into about $12 per
ton of carbon dioxide. The literature review (Tol 2005) from which this mean was derived did not report the year in
which these dollars were denominated. However, we unders tand this estimate was denominated in 1995 dollars. Updating that estimate to 2007 dollars yields a SCC of $15 per ton of carbon dioxide.

k 

### In contrast, most of the estimates of costs and benefits of increasing th e efficacy IRL and GSFLs include only economic values of impacts that would be experienced in the U.S. For example, in determining impacts on manufacturers, DOE generally does not consider impacts that occur solely outside of the United States.

16-16

## emission reductions and do not necessarily reflec t the benefit of reductions. DOE also believes

that the studies it relie s upon generally should be studies that were the su bject of a peer review process and were published in reputable journals.

For this analysis, DOE is essentially proposi ng to rely on a range of values based on the values presented in the Tol’s study. Additionally, DOE has applie d an annual growth rate of 2.4 percent to the value of SCC, as suggested by the IPCC Working Group II, 5 

## based on estimated increases in damages from future emissions repor ted in published studies. Because the values in the Tol study were presented in 1995 dollars, DOE is assigning a range for the SCC of $0 to $20 (in $2007) per ton of CO 2 

## emissions.

DOE is proposing to use the median estimated social cost of CO 2 

## as an upper bound of the range. This value is based on the Tol st udy, which reviewed 103 estimates of the SCC from 28 published studies, and concluded that when only peer-reviewed studies published in recognized journals are considere d, “that climate change impacts ma y be very uncertain but [it] is unlikely that the marginal damage costs of carbon dioxide emissions exceed $50 per ton carbon [comparable to a 2007 value of $20 per t on carbon dioxide when expressed in 2007 U.S. dollars with a 2.4% growth rate].”

In proposing a lower bound of $0 for the es timated range, DOE agrees with the IPCC Working Group II report that “significant warm ing across the globe a nd the locations of significant observed changes in many systems consistent with warming is very unlikely to be due solely to natural variability of temperatur es or natural variability of the systems”, 6 

## and, thus, tentatively concludes that a gl obal value of zero for reducing em issions cannot be justified. However, DOE also believes that it is reasonabl e to allow for the possibility that the U.S. portion of the global cost of carbon dioxide emissions may be quite low. In fact, some of the studies looked at in Tol reported negative values for the S CC. DOE is using U.S. benefit values, and not world benefit values, in its analysis, and, further, DOE believes that U.S. domestic values will be lower than the global values. Additionally, th e statutory criteria in EPCA do not require consideration of global effects. Therefore, DOE is propos ing to use a lower bound of $0 per ton

of CO 2 

## emissions in estimating the potential benef its of today’s proposed rule.

The resulting estimates of the potential range of net present value benefits associated with

the reduction of CO 2 

## emissions are reflected in Tables 16.2.8 and Table 16.2.9.

16-17

## Table 16.2.8 Estimates of Savings from CO 2 

## Emissions Reductions under IRL Trial

Standard Levels at 7% Discount Rate and 3% Discount Rate

IRL

TSL Estimated Cumulative CO2 (MMt) Emission

Reductions Value of Estimated CO2

Emission Reductions (Billion 2007$) at 7%

Discount Rate Value of Estimated CO2

Emission Reductions (Billion 2007$) at 3%

Discount Rate

1 10.3 to 17.7 $0 to $0.1 $0 to $0.2

2 25.1 to 44.8 $0 to $0.3 $0 to $0.5

3 46.2 to 88.1 $0 to $0.5 $0 to $1.0

4 58.6 to 114.4 $0 to $0.6 $0 to $1.3

5 79.3 to 118.8 $0 to $0.7 $0 to $1.3



## Table 16.2.9 Estimates of Savings from CO 2 

## Emissions Reductions under GSFL Trial

Standard Levels at 7% Discount Rate and 3% Discount Rate

GSFL

TSL Estimated Cumulative CO2 (MMt) Emission

Reductions Value of Estimated CO2

Emission Reductions (Billion 2007$) at 7%

Discount Rate Value of Estimated CO2

Emission Reductions (Billion 2007$) at 3%

Discount Rate

1 85.7 to 236.4 $0 to $1.2 $0 to $2.5

2 103.5 to 233.7 $0 to $1.2 $0 to $2.5

3 184.3 to 395.2 $0 to $2.1 $0 to $4.3

4 239.7 to 597.7 $0 to $3.5 $0 to $6.8

5 312.8 to 679.7 $0 to $4.0 $0 to $7.7



## DOE also investigated the potential moneta ry impact resulting from the impact of potential efficacy standards on NO X 

## and Hg emissions.

As discussed earlier, with respect to NO X 

## the CAIR rule has been vacated by the courts, so projected annual NO X 

## allowances from NEMS-BT are no lo nger relevant. Therefore, DOE’s

estimates of NO X 

## emissions are not controlled by a nati onwide regulatory syst em. For the range

of NO X 

## reduction estimates and Hg reduction estimat es, DOE estimated the national monetized

benefits of emissions reductions based on environm ental damage estimates from the literature. Available estimates suggest a very wi de range of monetary values for NO X 

## emissions, ranging

from $370 per ton to $3,800 per ton of NO X 

## from stationary sources, measured in 2001$ or a range of $432 per ton to $4,441 per ton in 2007$. 7 

## The resulting estimates of the potential range of the present value benefits associated with the national reduction of NO X 

## are presented in Tables 16.2.10 through 16.2.11. Because DOE estimated NO X 

## emissions with high and low emission rate estimates, a range of re sults are presented for each product.

16-18

## Table 16.2.10 Estimates of Monetary Savings from NO X 

## Emissions Reductions under

IRL Trial Standard Levels at 7% Di scount Rate and 3% Discount Rate

IRL

TSL Estimated Cumulative NOx (kt) Emission

Reductions Value of Estimated NOx

Emission Reductions (Billion 2007$) at 7%

Discount Rate Value of Estimated NOx

Emission Reductions (Billion 2007$) at 3%

Discount Rate

1 0.7 to 29.0 $0 to $0.0 $0 to $0.1

2 1.6 to 77.6 $0 to $0.1 $0 to $0.2

3 3.0 to 140.6 $0 to $0.2 $0 to $0.4

4 3.8 to 180.7 $0 to $0.2 $0 to $0.5

5 4.5 to 193.1 $0 to $0.2 $0 to $0.5



## Table 16.2.11 Estimates of Monetary Savings from NO X 

## Emissions Reductions under

GSFL Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

GSFL

TSL Estimated Cumulative NOx (kt) Emission

Reductions Value of Estimated NOx

Emission Reductions (Billion 2007$) at 7%

Discount Rate Value of Estimated NOx

Emission Reductions (Billion 2007$) at 3%

Discount Rate

1 5.1 to 347.4 $0 to $0.5 $0 to $0.9

2 6.8 to 361.1 $0 to $0.5 $0 to $0.9

3 11.7 to 623.0 $0 to $0.8 $0 to $1.6

4 16.5 to 950.7 $0 to $1.3 $0 to $2.6

5 20.3 to 1071.6 $0 to $1.4 $0 to $2.8



## DOE has determined that t he basic science linking mercury emissions from power plants to impacts on humans is considered highly uncertain. However, DOE identified two estimates of 

## the environmental damages of mercury based on two estimates of the adverse impact of childhood exposure to methyl mercury on IQ for Ameri can children, and subse quent loss of lifetime economic productivity resulting from these IQ losses. The high-end estimate is based on an estimate of the current aggregate co st of the loss of IQ in Americ an children that results from exposure to mercury of U.S. power plant origin ($1.3 billion per year in 2000$), which translates to $32.6 million per ton emitted per year (2007$). 8 

## The low-end estimate was $664,000 per ton emitted in 2004$ or $729,000 per ton in 2007$, which DOE derived from a published evaluation of mercury control using different methods and assumptions from the first study, but also based on the present value of the lifet ime earnings of children exposed. 9 l 

## The resulting estimates of the potential range of the present value benefits as sociated with the nation al reduction of Hg are presented in Table 16.2.12 and Table 16.2.13. DOE es timated Hg emissions with high and low

emission rate estimates.

l 

### The estimate was derived by back-calculating the annual benefits per ton from the net present value of benefits reported in the study.

16-19

## Table 1 6.2.12 High Emission Rate Estimates of Mo netary Savings from Hg Emissions

Reductions under IRL Trial Standard Le vels at 7% Discount Rate and

3% Discount Rate

IRL

TSL Estimated Cumulative Hg (Tons) Emission

Reductions Value of Estimated Hg

Emission Reductions (Million 2007$) at 7%

Discount Rate Value of Estimated Hg

Emission Reductions (Million 2007$) at 3%

Discount Rate

1 0 to 0.2 $0 to $2 $0 to $5

2 0 to 0.6 $0 to $7 $0 to $13

3 0 to 1.3 $0 to $13 $0 to $26

4 0 to 1.7 $0 to $16 $0 to $33

5 0 to 1.7 $0 to $16 $0 to $33



## Table 16.2.13 High Emission Rate Estimates of Mo netary Savings from Hg Emissions

Reductions under GSFL Trial Standard Levels at 7% Discount Rate and

3% Discount Rate

GSFL

TSL Estimated Cumulative Hg (Tons) Emission

Reductions Value of Estimated Hg

Emission Reductions (Million 2007$) at 7%

Discount Rate Value of Estimated Hg

Emission Reductions (Million 2007$) at 3%

Discount Rate

1 0 to 4.2 $0 to $38. $0 to $80.

2 0 to 3.8 $0 to $35. $0 to $73.

3 0 to 6.9 $0 to $65. $0 to $134.

4 0 to 7.9 $0 to $88. $0 to $166.

5 0 to 9.1 $0 to $102. $0 to $192.



## With regard to SO 2 

## emissions, unlike the other pollutant s considered in this analysis, these emissions have for some time been subj ect to a national cap w ith corresponding annual allowances openly traded; therefor e, considerable market experience with these instruments has already been accumulated. It has been argued that imposition of any standard that lowers U.S. national electricity consumption creates beneficial downward pre ssure on the prices of these allowances, and this cost reduction benefit should be considered in any analysis of a proposed efficacy standard. While this assertion is funda mentally sound (i.e., reduced electricity demand

should ceteris paribus bring about lower SO 2 

## allowance prices) there are a myriad of complications impeding any meaningful quantifi cation of any associated benefit. While complexity of analysis alone clearly cannot ju stify disregarding a potential consequence of a standard, DOE additionally believes these benefits to be both volatile and de minimis when compared to the direct effects of a st andard as estimated in this analysis.

16-20

## Some of the problems to be confronted in an allowance price effect forecast are:

• Only a ny net lowering of the total allowance bill to generators free of transfers is the potential source of a benefit. Any such compliance cost saving would need to be accurately estimated, and this effect is no diffe rent from the benefit derived from a cost reduction for other inputs, such as fuel. When the SO 2 

## allowance market that was created

in 1995 under the Clean Air Act Amendments be gan, initial allowance allocations were directly granted to large affected units based on their historic (1985-87) use of fuel. For 30 years, allowances for the following year ar e issued every spring at a declining rate to these entitled parties, and thereafter can be freely used, traded, or banked. Some

additional allowances are allocated in dive rse ways (e.g. as rewards to generators installing control equipment). In other word s, the entitled generators holding emission rights are losers when the valu e of allowances declines, wh ile the buyers of allowances are gainers. Before they are used, allowa nces may be traded many times at prices reflecting the marginal not average cost of compliance.

• The trading system allows for allowance banki ng. Consequently, any observed change in a forecast year could represent the manife station of market fundamentals but could similarly just indicate deposit or withdrawal of allowances. In general, used allowances have fallen short of the cap so emissions may exceed the specified cap for future years.

• Control effo rts could further reduce the SO 2 

## cap for some jurisdictions, creating regulatory uncertainty that pe rturbs the allowance market. The issuance of the proposed and final CAIR rules were likely contributing factors to allowance price increases leading to a dramatic 2005 allowance price spike. While prices had already fallen far below their historic highs by the time CAIR was vacated in the summer of 2008, spot allowance prices nonetheless made a further precipitous drop following the D.C. Circuit Court ruling.

• Because allo wances can be traded freely by generators, brokers, and investors, they can serve as financial instruments, and, especi ally since 2003, allowance prices have been volatile. Between 2000, when a tightened Clean Air Amendment cap came into force, and 2007, allowances traded between a low of about $120/short ton in 2002 and a high of about $1600/short ton, with the 2005 spike being pa rticularly dramatic. 10 11 

## Since there

is no reason to believe that these conditions will alter over th e life of a proposed efficacy standard, the challenge of forecasting prices is much more complex than a simple supplydemand balance might suggest. Also, note that any quantification of the benefit likely depends on the level of prices as well as thei r net change. To believe that a simple delta in the prices could be used to estimate the be nefit is to believe that the same numerical reduction in price would result from the st andard whether the pr evailing trading price were $100 or $1000 per short ton.

As noted earlier, the forecasting tool used for this analysis is the AEO2008 version of NEMS-BT, which generates forecasts of both SO 2 

## emissions and allowance prices. Unfortunately, this model was released before CA IR was overturned so its forecast enforces the tighter CAIR cap in the affected east of countr y, and does not represent current conditions. Given

16-21

## the timing of the CAIR ruling relative to the pr ogress of this analysis , attaining projections absent CAIR has not been possible. Nonetheles s, as a indicative bounding case, the net average price delta for the period 2012 to 2030 for the maximum technologically feasible (Max Tech) TSL reported by the AEO2008 NEMS-BT was -4.5 percent for GSFL and –0.4 percent for IRL.

These estimates represent the average of percentage changes from the interpolated Max Tech standards for each of the pr oducts in the EMM East region. DOE considers this effect to be inconsequential relative to other elements in the benefits analysis, and given the significant effort that would be required to deve lop a refined estimate, the SO 2 

## allowance price effect is not

considered further in this analysis. If future an alysis suggests that the SO 2 

## allowance price effect is both significant and estimable using NEMS-B T, it may be added to supporting material.

16.3 WETLAND, E NDANGERED AND THREATENED SPECIES, AND

CULTURAL RESOURCES

DOE’s proposed action is not site-specific, nor would it affect land disturbance or use due to IRL and GSFL adoption. Ther efore, none of the proposed TSLs is expected to affect the quality of wetlands, or threatened or endangered species. Further, this ac tion is not expected to impact cultural resources such as hi storical or arch aeological sites.

16.4 SOCIOECON OMIC IMPACTS

DOE's analysis has shown that the increase in the first cost of pur chasing more efficient lighting products at the proposed standard level is completely offset by a reduction in the lifecycle cost (LCC) of owning a more efficient product. In other words, the customer will pay less operating costs over the life of the equipment even through the first cost increases. The complete analysis and its conclusions are pr esented in Chapter 8 of the TSD.

For subgroups of low-income consum ers that purchase lighting products, DOE determined that the average LCC impact is simila r to that for the full sample of consumers. Therefore, DOE concludes that the proposed ac tion would have no significant socioeconomic impact. For a complete discussion on the LCC impacts on consumer subgroups, see Chapter 12

of the TSD.

16.5 ENVIRONME NTAL JUSTICE IMPACTS

According to Executive Order 12898 of Febr uary 11, 1994, “Federal Actions to Address

Environmental Justice in Minorit y Populations and Low-Income Populations,” DOE is required to examine the effect of more stringent efficacy standards on (1) small businesses that either

manufacture or use IRL and GSFL , (2) manufacturers of niche pr oducts related to IRL and GSFL and (3) small businesses operated by di sadvantaged or minority populations.

16-22

## DOE identified small businesses as a sub-group that possibly could be disproportionately affected by IRL and GSFL efficacy standards. As described in the Manufacturer Impact Analysis, Chapter 13 of TSD, DOE identifie d only one company as a small business

manufacturer based on SBA’s definition of a small business manufacturer fo r this industry. The

small business manufacturer th at DOE identified only produces covered GSFL products. DOE

found that the small manufacturer of covered GSFL shared some of the same concerns about energy conservation standards as large manufacturers. Therefore, DOE does not believe that there would be significant dispr oportionate impacts on small busin esses that manufacture GSFL or IRL. Also, as described in the Life-Cycle Cost Subgroup Analysis, Chapter 12 of the TSD, DOE found that there was no disproportionate ly high and adverse human health or environmental effects on small businesses (analyzed as institutions that serve low income populations) that would result from the proposed efficacy standards. DOE believes that above conclusion also applies to minority populations.

1 6.6 NOISE AND AESTHETICS

Improvements in the efficacy of IRL and G SFL products are expected to result from changes in the choice of components and other de sign 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. Prod ucts that are currently manufactured in the existing market that would meet the proposed efficacy standards are no louder than less efficacious products. Changes to the design to impr ove the efficacy levels are not anticipated to affect the products’ aesthetics.

1 6.7 SUMMARY OF ENVIRONMENTAL IMPACTS

Table 16.7.1 and Table 16.7.2 summarize antici pated environmental impacts for each of the TSLs for IRL and GSFL. Air quality impact s were estimated for each of the TSLs. The summary table shows cumulative changes in emissions for CO 2 

## , NO X 

## , and Hg over the period 2012 to 2042. The resulting changes in emission quantities are very small. Cumulative CO 2 

## , NO X 

## , and Hg emissions show a decrease co mpared to the reference case.

Upstream fuel cycle emission of CO 2 

## and NO X 

## are described but not quantified in section 16.2.7. The text describes potential reductions in fuel cycle emissions as a percentage of decreases in power plant emissions . This qualitative approach s uggests that upstream fuel cycle emissions would decrease and provides a sense of the magnitude of effects, however DOE does not report actual estimates of the effects. Th is approach does not a ddress Hg emissions.

Socioeconomic impacts are presented in TSD Chapter 8.

16-23

## T able 16.7.1 Environmental Impact Analysis Results Summary for IRL

NEMS-BT Results: Environmental Effects

Total Reference Case
2012-2042† TSL 1 TSL 2 TSL 3 TSL 4 TS


### IRL Existing Technologies, Shift Product Substitution Scenario

CO2 (Million metric tons) 85,998 (17.7) (44.8) (88.1) (114.4) (118.8)

NOX (kt)

Low Emission Rate 60,952 (1.2) (3.1) (5.7) (7.3) (7.8)
High Emission Rate 60,952 (29.0) (77.6) (140.6) (180.7) (193.1)
Mercury (tons)

Low Emission Rate 522

- - - - - High Emission Rate 522 (0.2) (0.6) (1.3) (1.7) (1.7)

IRL Emerging Technologies Roll-up No Product Substitution Scenario
CO2 (Million metric tons) 85,998 (10.3) (25.1) (46.2) (58.6) (79.3)
NOX (kt)

Low Emission Rate 60,952 (0.7) (1.6) (3.0) (3.8) (4.5)
High Emission Rate 60,952 (16.7) (39.3) (74.9) (93.9) (112.4)

Mercury (tons)

Low Emission Rate 522

- - - - - High Emission Rate 522 (0.1) (0.3) (0.6) (0.8) (1.3)

† 

### Extrapolated by assuming 2030 end valu es in all subsequent years 2031-2042. L 5



## T able 16.7.2 Environmental Impact Analysis Results Summary for GSFL

NEMS-BT Results: Environmental Effects
Case 2012-2042† TSL 1 TSL 2 TSL 3 TSL 4 TS


### GSFL Existing Technologies, High Lighting Expertise, Shift Scenario
CO2 (Million metric tons) 85,998 (236.4) (233.7) (395.2) (597.7) (679.7)
NOX (kt)

Low Emission Rate 60,952 (14.1) (14.6) (25.2) (38.5) (43.3)
High Emission Rate 60,952 (347.4) (361.1) (623.0) (950.7) (1,071.6)

Mercury (tons)

Low Emission Rate 522

- - - - - High Emission Rate 522 (4.2) (3.8) (6.9) (7.9) (9.1)

GSFL Emerging Technologies, Market Segment- Based Lighting Expertise, Roll-Up Scenario
CO2 (Million metric tons) 85,998 (85.7) (103.5) (184.3) (239.7) (312.8)
NOX (kt)

Low Emission Rate 60,952 (5.1) (6.8) (11.7) (16.5) (20.3)
High Emission Rate 60,952 (126.9) (167.0) (289.4) (407.0) (502.5)

Mercury (tons)

Low Emission Rate 522

- - - - - High Emission Rate 522 (1.5) (1.5) (2.9) (3.2) (4.4)

† 

### Extrapolated by assuming 2030 end values in all subsequent years 2031-2042. L 5



### 16-24

### 16-25 

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1 

## U.S. Department of Energy - Energy Information Administration, Annual Energy Outlook 2008 (Revised Early Release) with Projections to 2030 . 2008: Washington, DC.

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

2 

## DeLuchi, M. A. Emissions of Greenhouse Gases from the Use of Transportation Fuels and Electricity , Volume 2: Appendixes A-S. Nove mber, 1993. Argonne National Laboratory. Argonne, IL. Report No. ANL/ESD/TM-22-Vol.2.

3 

## Intergovernmental Panel on Climate Change (IPCC). Climate Change 2007 – Impacts, Adaptation and Vulnerability , Contribution of Working Group II to the Fourth Assessment Report to the IPCC. < http://www.ipcc-wg2.org/ >

4 

## Tol, Richard S.J. The marginal damage costs of carbon dioxide emissions: an assessment of

the uncertainties , Energy Policy 33 (2005) 2064-2074.

5 

## Intergovernmental Panel on Climate Change (IPCC). Climate Change 2007 – Impacts, Adaptation and Vulnerability , Contribution of Working Group II to the Fourth Assessment Report to the IPCC. p. 822. < http://www.ipcc-wg2.org/ >

6 

## Intergovernmental Panel on Climate Change (IPCC). Climate Change 2007 – Impacts, Adaptation and Vulnerability , Contribution of Working Group II to the Fourth Assessment Report to the IPCC. p. 9. < http://www.ipcc-wg2.org/ >

7 

## Office of Management and Budget, Offi ce of Information and Regulatory Affairs, 2006 Report to Congress on the Costs and Benefi ts of Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities , 2006. Washington, DC.

< http://www.whitehouse.gov/omb/inforeg/2006_cb/2006_cb_final_report.pdf >

8 

## Trasande, L., C. Schechter, K.A. Haynes, and P.J. Landrigan, “Applying Cost Analyses to Drive Policy that Pr otects Children,” 1076 ANN. N.Y. ACAD. SCI . 911 (2006).

9 

## Ted Gayer and Robert Hahn, “Designing Enviro nmental Policy: Lessons from the Regulation of Mercury Emissions,” Regulatory Analysis 05-01 (AEI-Brookings Jo int Center For Regulatory Studies) p. 31 ( 2004). A version of this paper was published in the Journal of Regulatory Economics in 2006.

10 

## U.S. Environmental Protection Agency, Allowance Prices (1995-2004), SO 2 

## Allowance Price

Index . Washington, DC. < http://www.epa.gov/airmarkets/progress/alprices.html >

11 

## U.S. Environmental Protection Agency, Clean Air Markets – Data and Maps . Washington,

DC. < http://camddataandmaps.epa.gov/gdm/ >