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 CO2 between 2012-2042 by Trial Standard 

Level (Million Metric Tons of CO2) .................................................................. 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 Segment 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 CO2 Emissions Reductions under IRL Trial 

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

Table 16.2.9 Estimates of Savings from CO2 Emissions Reductions under GSFL Trial 

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

EE-2006-STD-0131 COMMENT 37.2
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 Monetary Savings from Hg Emissions 

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

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

Table 16.2.13 High Emission Rate Estimates of Monetary 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 

EE-2006-STD-0131 COMMENT 37.2
CHAPTER 16. ENVIRONMENTAL ASSESSMENT 

16.1 INTRODUCTION 

 This chapter describes potential environmental 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. Therefore, none of the proposed 

standards would impact land uses, cause any direct disturbance to the land, or directly affect 

biological resources in any one area. 

 All of the potential trial standard levels (TSLs) are expected to reduce energy 

consumption in comparison to a baseline efficacy 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 energy savings can be found in the national impact 

analysis in Chapter 11 of this technical support 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, much of this chapter describes the air quality 

analysis. 

16.2 AIR EMISSIONS ANALYSIS 

 The primary focus of the environmental analysis 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 changes in power plant types 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 pollutants: nitrogen oxides 

(NOX), mercury (Hg), and sulfur dioxide (SO2). 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 gasesa

. This analysis also considers carbon dioxide (CO2). 

Sulfur Dioxide (SO2) 

 

a

 More information on air pollution characteristics and regulations is available on the U.S. Environment Protection 

Agent (EPA)’s website at http://www.epa.gov 

16-1 

EE-2006-STD-0131 COMMENT 37.2
 

 In addressing SO2 emissions, the Clean Air Act Amendments of 1990 set an SO2 

emissions cap on all power generation, but permitted flexibility among generators through the 

use of emissions allowances and tradable permits. This SO2 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 allowed emissions ceiling. Consequently, there is no 

direct SO2 environmental benefit from a reduction in electricity 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 for and price of emissions allowance permits, 

there is an environmentally related economic benefit from the proposed efficacy standards 

reducing SO2 emissions allowance demand. Furthermore, over time, if emissions decline, there 

is greater flexibility in reducing the ceiling amount. However, since DOE does not anticipate a 

change in SO2 emissions, SO2 emission results are not reported in this Chapter. 

 

Nitrogen Oxides (NOX) 

 Nitrogen oxides, or NOX, 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 (NO2), along with 

particles in the air can often be seen as a reddish-brown layer over many urban areas. NO2 is the 

specific form of NOX reported in this document. NOX 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. 

NOX also contributes to the formation of fine particles that can impair human health. 

 Nitrogen oxides form when fossil fuel is burned at high temperatures, as in a combustion 

process. The primary manmade sources of NOX are motor vehicles, electric utilities, and other 

industrial, commercial, and residential sources that burn fossil fuels. NOX can also be formed 

naturally. Electric utilities account for about 22 percent of NOX 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 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. 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 

16-2 

EE-2006-STD-0131 COMMENT 37.2
tasks, such as those measuring attention, fine motor function, language skills, visual-spatial 

abilities, and verbal memory. 

Carbon Dioxide (CO2) 

 Carbon dioxide (CO2) is not a regulated or 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, CO2, methane (CH4), nitrous oxide 

(N2O), and ozone (O3). Human activities, however, add to the levels of most of these naturally 

occurring gases. For example, CO2 is emitted to the atmosphere when solid waste, fossil fuels 

(oil, natural gas, and coal), wood, and wood products are burned. During the past 20 years, 

about three-quarters of anthropogenic (i.e., human-made) CO2 emissions resulted from burning 

fossil fuels. 

 Concentrations of CO2 in the atmosphere are naturally 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 absorb some of the anthropogenic CO2 emissions produced each year, 

billions of metric tons are added to the atmosphere annually. In the U. S., CO2 emissions from 

both energy generation and industrial processes account for 84.6 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 national air quality standards for six common pollutants (also referred to 

as “criteria” pollutants), two of which are SO2 and NOX. 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 SO2 and NOX. Title IV of the 1990 amendments established a capand-trade program for SO2 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 

SO2 and NOX in eastern States of the United States. CAIR required large reductions of SO2

and/or NOX emissions across 28 eastern states and the District 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 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 NOX 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 decisions of the D.C. Circuit change the standardsetting proposals reached in this rule. See www.epa.gov/cleanairinterstaterule. 

16-3 

EE-2006-STD-0131 COMMENT 37.2
place in 2009. Phase 1 caps for SO2 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 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). This rule, also 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,

c

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

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.d 

CAIR was the basis under which NOX 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 NOX SIP Call rule, which provided 23 jurisdictions with an option to 

implement a cap and trade emission program for NOX 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 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 (CO2), as major 

contributors to climate change. Because this Rule, if finalized, will likely decrease CO2 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 CO2 emissions and 

global warming. 

Impacts of Climate Change on the Environment 

 

c

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

d

 See www.epa.gov/cleanairinterstaterule/. e

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

f

 In the NOX SIP Call rule, EPA found that sources in the District of Columbia and 22 “upwind” states (States) were 

emitting NOX (an ozone precursor) at levels that significantly contributed to “downwind” states not attaining the 

ozone NAAQS or at levels that interfered with states in attainment maintaining the ozone NAAQS. In an effort to 

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

NOX emissions from certain large combustion sources and set a NOX emissions budget for each State. In order to 

comply with the NOX SIP Call Rule, States could elect to participate in the NOX Budget Trading Program. Under 

the NOX Budget Trading Program, each emission source is required to have one allowance for each ton of NOX

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 NOX allowances as appropriate. 

16-4 

EE-2006-STD-0131 COMMENT 37.2
 

 Climate is usually defined as the average weather, 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 variability of its properties (e.g., temperature or 

precipitation) over an extended period, typically decades or longer. 

 The World Meteorological Organization and United Nations Environment Programme 

(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. 

 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 ice 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 and more frequent heat 

waves in many locations worldwide, and numerous ecological changes. 

 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 

(CO2), other greenhouse gases (GHG)s, 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. 

 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 increasing 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 yields 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 CO2 and other long-lived 

greenhouse gases (GHGs) such as methane and nitrous oxide in the atmosphere, rather than from 

natural causes. 

 Increasing the CO2 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 IPCC 

16-5 

EE-2006-STD-0131 COMMENT 37.2
Report estimates that currently, CO2 makes up about 77% of the total CO2-equivalentg

 global 

warming potential in GHGs emitted from human activities, with the vast majority (74%) of the 

CO2 attributable to fossil fuel use. For the future, the IPCC Report describes a wide range of 

GHG emissions scenarios, but under each scenario CO2 would continue to comprise above 70% 

of the total global warming potential. 

Stabilization of CO2 Concentrations 

 Unlike many traditional air pollutants, CO2 mixes thoroughly in the entire atmosphere 

and is long-lived. The residence time of CO2 in the atmosphere is long compared to the emission 

processes. Therefore, the global cumulative emissions of CO2 over long periods determine CO2

concentrations because it takes hundreds of years for natural processes to remove the CO2. 

Globally, 49 billion metric tons of CO2 –equivalent of anthropogenic (man-made) greenhouse 

gases are emitted every year. Of this annual total, fossil fuels contribute about 29 billion metric 

tons of CO2.

h

 

 Researchers have focused on considering atmospheric CO2 concentrations that likely will 

result in some level of global climate stabilization, and the emission rates associated with 

achieving the “stabilizing” concentrations by particular dates. They associate these stabilized 

CO2 concentrations with temperature increases that plateau in a defined range. For example, at 

the low end, the IPCC Report scenarios target CO2 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 levelsi

 (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% 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 reductions 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 CO2

and GHGs in the atmosphere. 

The Beneficial Impact of the Rule on CO2 Emissions 

 If finalized, it is anticipated that the Rule will reduce energy-related CO2 emissions, 

particularly those associated with energy consumption in buildings. In the United States, the 

U.S. Energy Information Administration (EIA) reports in its 2008 Annual Energy Outlook 

(AEO2008)

1

 that U.S. annual energy-related emissions of CO2 in 2005 were about 6.0 billion 

 

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 CO2, i.e., CO2-equivalent. CO2 equivalent emission is the amount 

of CO2 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 CO2 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 2 

16-6 

EE-2006-STD-0131 COMMENT 37.2
metric tons (about 20 percent of the world energy-related CO2 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 CO2

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 CO2 emissions between 2012 and 2042 are described at about 86 billion 

metric tons. The estimated cumulative CO2 emission reductions from amended IRL and GSFL 

efficacy standards during this same 30-year period are indicated in Table 16.2.1. Estimated CO2 

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

estimated CO2 emission reductions from electricity generation are calculated using the NEMSBT model. 

Table 16.2.1 Impact of Amended IRL and GSFL Efficacy Standards on Cumulative 

Energy-Related Emissions of CO2 between 2012-2042 by Trial Standard 

Level (Million Metric Tons of CO2) 

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 CO2 from electricity generation (total emissions reported for TSL 5 in Table 16.2.1 

combining IRL and GSFL), comprise an even smaller fraction of U.S. emissions of greenhouse 

gases and of world emissions of greenhouse gases. However, the savings would likely reduce 

overall U.S. CO2 emissions, as compared to U.S. CO2 emissions absent an increase in the 

required efficacy of IRLs and GSFLs. 

 

The Incremental Impact of the Rule on Climate Change 

 It is difficult to correlate specific emission rates with atmospheric concentrations of CO2 

and specific atmospheric concentrations with future temperatures because the IPCC Report 

16-7 

EE-2006-STD-0131 COMMENT 37.2
describes a clear lag in the climate system between any given concentration of CO2 (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 climate system response to 

sustained radioactive 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 CO2 mitigation 

scenarios that aim to meet specific temperature levels. 

 

 Because of the complexity of global climate systems, it is difficult to know to what extent 

and when particular CO2 emissions rates will impact global warming. However, as Table 16.2.1 

indicates, the Rule will likely reduce CO2 emissions rates from the electric power sector. 

16.2.4 Analytical Methods for Air Emissions 

 NEMS-BT incorporates capabilities to assess compliance with SO2 restrictions specified 

in the Clean Air Act and its amendments. Clean air act provisions include New Source 

Performance Standards, and Revised New Source Performance Standards. The version of 

NEMS-BT in 2008 also included provisions for the CAIR, which imposes stricter restrictions on 

SO2 and NOX for some states, and the CAMR, which imposed a national Hg constraint. As 

discussed earlier is section 16.2.2, 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, vacating the CAIR. 531 F.3d 896 (D.C. Cir. 2008). Although the constraints 

on NOX in CAIR and Hg in CAMR have since been vacated by a court decision, the AEO2008

Reference Case assumes that emissions of NOX and Hg would decline over time as shown in 

Table 16.2.2. 

 Because the courts vacated CAIR and CAMR, the 2008 version of NEMS-BT could not 

be used directly to estimate emissions impacts for NOX and Hg. Instead, DOE established a 

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

nationwide NOX emission rate for electrical generation. DOE derived a current NOX emission 

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

tons of NOX emitted per TWh of electricity generated in the year 2006. For 2006, the NOX

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 combined-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 rate of fossil-fuel based generation that might be displaced under 

standards. To estimate the reduction in NOX 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 Chapter 14, Utility Impact Analysis). The range in 

NOX emission changes calculated using the low and 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 

EE-2006-STD-0131 COMMENT 37.2
 DOE estimated the physical quantity changes 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 tons 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 emission 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 reduction in coal-generated electricity due to the standards 

considered as determined in the utility impact analysis (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 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. 

 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 SO2 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. 

 Modeling of SO2 trading tends to imply that the physical emissions effects will be zero, 

as long as emissions are at the allowed ceiling. Because SO2 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 SO2 results here. This assumption is consistent with 

previous DOE environmental assessment documents. 

 As noted in Chapter 14, NEMS-BT model forecasts 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 Reference case emissions are the emissions shown by 

the NEMS-BT model to result if none of the TSLs are promulgated. 

16-9 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.2 Power Sector Emissions Forecast from AEO2008 Reference Case 

NEMS-BT Results*: 

 2005 2010 2015 2020 2025 2030

Total 

2012-

2042††

CO2 (Million tons)** 2,397 2,413 2,519 2,627 2,771 2,948 85,998

NOX (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 estimated changes in power plant emissions 

in selected years for all the TSLs. Changes in CO2, NOX and Hg emissions from power plants 

are shown in these tables. Compared to the anticipated 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 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.3 Power Sector Emissions Impact Forecasts IRL Under the Existing 

Technologies, Shift, Product Substitution Scenario 

IRL Existing Technologies, 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) (0.81) (0.00) (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) (1.42) (0.01) (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) (0.01) (0.00) (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) (0.16) (0.00) (0.17) (0.19) (0.20) (0.20) (0.20) (0.20) (5.7)

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

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) (5.10) (0.02) (5.57) (6.16) (6.26) (6.26) (6.26) (180.7) (6.26)

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 5

Power Sector CO2 (MMT CO2) (3.58) (0.02) (4.64) (4.59) (3.60) (3.60) (3.60) (118.8) (3.60)

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) (0.03) (0.00) (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 refer to a reduction compared with the Base 

Case.

16-11 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.4 Power Sector Emissions Impact Forecasts for IRL Under the Emerging 

Technologies, Roll-up, No Product Substitution Scenario 

IRL Emerging Technologies Roll-up 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) (0.35) (0.00) (0.42) (0.35) (0.30) (0.30) (0.30) (0.30) (10.3)

Nitrogen Oxides - Low (kt) (0.02) 0.00 (0.02) (0.02) (0.02) (0.02) (0.02) (0.02) (0.7)

Nitrogen Oxides - High (kt) (0.52) 0.00 (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) (0.84) (0.00) (0.88) (0.85) (0.76) (0.76) (0.76) (0.76) (25.1)

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

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

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 3

Power Sector CO2 (MMT CO2) (1.60) (0.00) (1.68) (1.66) (1.37) (1.37) (1.37) (1.37) (46.2)

Nitrogen Oxides - Low (kt) (0.10) 0.00 (0.09) (0.09) (0.10) (0.10) (0.10) (0.10) (3.0)

Nitrogen Oxides - High (kt) (2.40) 0.00 (2.18) (2.33) (2.53) (2.53) (2.53) (2.53) (74.9)

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 4

Power Sector CO2 (MMT CO2) (1.94) 0.00 (2.17) (2.00) (1.77) (1.77) (1.77) (1.77) (58.6)

Nitrogen Oxides - Low (kt) (0.12) 0.00 (0.11) (0.12) (0.13) (0.13) (0.13) (0.13) (3.8)

Nitrogen Oxides - High (kt) (2.96) 0.01 (2.74) (2.86) (3.19) (3.19) (3.19) (3.19) (93.9)

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 5

Power Sector CO2 (MMT CO2) (2.38) (0.01) (2.57) (2.77) (2.59) (2.59) (2.59) (2.59) (79.3)

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

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

Mercury (Hg) - Low (t) - - - - - - - - -

Mercury (Hg) - High (t) (0.02) (0.00) (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 refer to a reduction compared with the Base 

Case.

16-12 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.5 Power Sector Emissions Impact Forecasts for GSFL Under the Existing 

Technologies, Shift, High 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) (4.6) (0.1) (8.4) (9.1) (8.4) (8.4) (8.4) (8.4) (236.4)

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

Nitrogen Oxides - High (kt) (6.6) (0.0) (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) (5.2) (0.1) (8.2) (9.1) (8.1) (8.1) (8.1) (8.1) (233.7)

Nitrogen Oxides - Low (kt) (0.3) (0.0) (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) (0.6) (0.0) (0.7) (0.9) (0.9) (0.9) (0.9) (0.9) (25.2)

Nitrogen Oxides - High (kt) (13.8) (0.1) (18.2) (22.8) (23.2) (23.2) (23.2) (23.2) (623.0)

Mercury (Hg) - Low (t) - - - - - - - - -

Mercury (Hg) - High (t) (0.1) (0.0) (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) (1.2) (0.0) (1.3) (1.3) (1.2) (1.2) (1.2) (1.2) (38.5)

Nitrogen Oxides - High (kt) (30.2) (0.2) (33.1) (33.0) (30.8) (30.8) (30.8) (30.8) (950.7)

Mercury (Hg) - Low (t) - - - - - - - - -

Mercury (Hg) - High (t) (0.2) (0.0) (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) (1.3) (0.0) (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) (0.2) (0.0) (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 refer to a reduction compared with the Base 

Case.

16-13 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.6 Power Sector Emissions Impact Forecasts 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) (1.9) (2.9) (3.2) (3.1) (3.1) (3.1) (3.1) (85.7) 0.0

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

Nitrogen Oxides - High (kt) (2.7) (0.0) (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) (3.5) (0.0) (3.8) (3.8) (3.1) (3.1) (3.1) (3.1) (103.5)

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

Nitrogen Oxides - High (kt) (5.1) (0.0) (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) (5.5) 0.1 (7.4) (7.1) (5.6) (5.6) (5.6) (5.6) (184.3)

Nitrogen Oxides - Low (kt) (0.3) (0.0) (0.4) (0.4) (0.4) (0.4) (0.4) (0.4) (11.7) 

Nitrogen Oxides - High (kt) (8.0) (0.1) (8.8) (10.1) (10.2) (10.2) (10.2) (10.2) (289.4)

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 4

Power Sector CO2 (MMT CO2) (9.4) 0.1 (10.6) (9.4) (6.1) (6.1) (6.1) (6.1) (239.7)

Nitrogen Oxides - Low (kt) (0.6) (0.0) (0.5) (0.5) (0.5) (0.5) (0.5) (0.5) (16.5) 

Nitrogen Oxides - High (kt) (14.1) (0.0) (13.4) (13.3) (13.2) (13.2) (13.2) (13.2) (407.0)

Mercury (Hg) - Low (t) - - - - - - - - -

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

Trial Standard Level 5

Power Sector CO2 (MMT CO2) (11.4) 0.1 (13.7) (12.9) (8.2) (8.2) (8.2) (8.2) (312.8)

Nitrogen Oxides - Low (kt) (0.7) (0.0) (0.7) (0.7) (0.7) (0.7) (0.7) (0.7) (20.3) 

Nitrogen Oxides - High (kt) (16.5) (0.1) (16.6) (17.4) (16.3) (16.3) (16.3) (16.3) (502.5)

Mercury (Hg) - Low (t) - - - - - - - - -

Mercury (Hg) - High (t) (0.1) (0.0) (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 refer to a reduction compared with the Base 

Case.

 

16-14

EE-2006-STD-0131 COMMENT 37.2
16.2.6 Effects on Upstream Fuel-Cycle Emissions 

 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. 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 production). Thus, this analysis reports 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 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 SO2) from coal production are due to mining, preparation that 

includes cleaning the coal, and transportation from the mine to the power plant.2

 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 approximately an amount 

equal to 14 percent of emissions from natural gas production result from upstream processes. 

Emission factor estimates and corresponding percentages of contributions of upstream emissions 

from coal and natural gas production, relative to power plant emissions, are shown in Table 

16.2.7 for CO2 and NOX. 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 CO2

and NOX. Thus, very small reductions in upstream emissions of air pollutant could be expected. 

This approach does not address Hg emissions. 

Table 16.2.7 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 

CO2 2.7 11.9 

NOX 5.8 40 

16.2.7 Economic Value of Emission Reductions 

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

benefits from reduced emissions of CO2, NOX, Hg, and SO2 associated with this rulemaking. 

With regard to CO2, the monetary estimates presented 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 

EE-2006-STD-0131 COMMENT 37.2
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 potential climate impacts caused by CO2 emissions, and not 

just the effects likely to occur within the United States. As DOE considers a monetary value for 

CO2 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 currently are no consensus estimates for the U.S. 

benefits likely to result from CO2 emission reductions. However, DOE believes it is appropriate 

to use U.S. benefit values, where available, and not world benefit values 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 the proposed range as a representative range for 

domestic U.S. benefits, DOE believes 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 Working Group II’s contribution to the Fourth 

Assessment Report of the IPCC notes that: 

The large ranges of SCC are due in the large part to differences in assumptions regarding 

climate sensitivity, response lags, the treatment of risk and equity, economic and noneconomic impacts, the inclusion of potentially 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 Report, and was a comprehensive meta-analysis of 

estimates for the value of SCC. 

DOE continues to believe that the most appropriate monetary values for consideration in 

the development of efficacy standards are those drawn 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 science, the Intergovernmental Panel on 

Climate Change (IPCC) identified various estimates of the 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 CO2

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 CO2 reductions likely 

to result from standards finalized in this rulemaking. According to IPCC, the mean social 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 understand 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 the 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 

EE-2006-STD-0131 COMMENT 37.2
emission reductions and do not necessarily reflect the benefit of reductions. DOE also believes 

that the studies it relies upon generally should be studies that were the subject of a peer review 

process and were published in reputable journals. 

For this analysis, DOE is essentially proposing to rely on a range of values based on the 

values presented in the Tol’s study. Additionally, DOE has applied 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 reported 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 CO2 emissions. 

DOE is proposing to use the median estimated social cost of CO2 as an upper bound of 

the range. This value is based on the Tol study, which reviewed 103 estimates of the SCC from 

28 published studies, and concluded that when only peer-reviewed studies published in 

recognized journals are considered, “that climate change impacts may 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 ton carbon dioxide when expressed in 2007 U.S. 

dollars with a 2.4% growth rate].” 

In proposing a lower bound of $0 for the estimated range, DOE agrees with the IPCC 

Working Group II report that “significant warming across the globe and the locations of 

significant observed changes in many systems consistent with warming is very unlikely to be due 

solely to natural variability of temperatures or natural variability of the systems”,6 and, thus, 

tentatively concludes that a global value of zero for reducing emissions cannot be justified. 

However, DOE also believes that it is reasonable 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 SCC. 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, the statutory criteria in EPCA do not require 

consideration of global effects. Therefore, DOE is proposing to use a lower bound of $0 per ton 

of CO2 emissions in estimating the potential benefits of today’s proposed rule. 

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

the reduction of CO2 emissions are reflected in Tables 16.2.8 and Table 16.2.9. 

16-17 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.8 Estimates of Savings from CO2 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 CO2 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 monetary impact resulting from the impact of 

potential efficacy standards on NOX and Hg emissions. 

As discussed earlier, with respect to NOX the CAIR rule has been vacated by the courts, 

so projected annual NOX allowances from NEMS-BT are no longer relevant. Therefore, DOE’s 

estimates of NOX emissions are not controlled by a nationwide regulatory system. For the range 

of NOX reduction estimates and Hg reduction estimates, DOE estimated the national monetized 

benefits of emissions reductions based on environmental damage estimates from the literature. 

Available estimates suggest a very wide range of monetary values for NOX emissions, ranging 

from $370 per ton to $3,800 per ton of NOX from stationary sources, measured in 2001$ 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 NOX are presented in 

Tables 16.2.10 through 16.2.11. Because DOE estimated NOX emissions with high and low 

emission rate estimates, a range of results are presented for each product. 

16-18 

EE-2006-STD-0131 COMMENT 37.2
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 

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 NOX 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 the 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 American children, and subsequent loss of lifetime 

economic productivity resulting from these IQ losses. The high-end estimate is based on an 

estimate of the current aggregate cost of the loss of IQ in American 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 lifetime earnings of children exposed.9 l

 The resulting estimates of 

the potential range of the present value benefits associated with the national reduction of Hg are 

presented in Table 16.2.12 and Table 16.2.13. DOE estimated 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 

EE-2006-STD-0131 COMMENT 37.2
Table 16.2.12 High Emission Rate Estimates of Monetary Savings from Hg Emissions 

Reductions under IRL Trial Standard Levels 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 Monetary 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 SO2 emissions, unlike the other pollutants considered in this analysis, 

these emissions have for some time been subject to a national cap with corresponding annual 

allowances openly traded; therefore, 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 pressure 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 fundamentally sound (i.e., reduced electricity demand 

should ceteris paribus bring about lower SO2 allowance prices) there are a myriad of 

complications impeding any meaningful quantification of any associated benefit. While 

complexity of analysis alone clearly cannot justify 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 standard as estimated in this analysis. 

 

16-20 

EE-2006-STD-0131 COMMENT 37.2
Some of the problems to be confronted in an allowance price effect forecast are: 

• Only any 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 different from the benefit derived from a cost 

reduction for other inputs, such as fuel. When the SO2 allowance market that was created 

in 1995 under the Clean Air Act Amendments began, 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 are 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 diverse ways (e.g. as rewards to generators 

installing control equipment). In other words, the entitled generators holding emission 

rights are losers when the value of allowances declines, while the buyers of allowances 

are gainers. Before they are used, allowances may be traded many times at prices 

reflecting the marginal not average cost of compliance. 

• The trading system allows for allowance banking. Consequently, any observed change in 

a forecast year could represent the manifestation 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 efforts could further reduce the SO2 cap for some jurisdictions, creating 

regulatory uncertainty that perturbs 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 allowances can be traded freely by generators, brokers, and investors, they can 

serve as financial instruments, and, especially 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 particularly dramatic.10 11 Since there 

is no reason to believe that these conditions will alter over the 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 their net change. To believe that a simple delta 

in the prices could be used to estimate the benefit is to believe that the same numerical 

reduction in price would result from the standard whether the prevailing 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 SO2 emissions and allowance prices. 

Unfortunately, this model was released before CAIR was overturned so its forecast enforces the 

tighter CAIR cap in the affected east of country, and does not represent current conditions. Given 

16-21 

EE-2006-STD-0131 COMMENT 37.2
the timing of the CAIR ruling relative to the progress of this analysis, attaining projections 

absent CAIR has not been possible. Nonetheless, 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 products 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 develop a refined estimate, the SO2 allowance price effect is not 

considered further in this analysis. If future analysis suggests that the SO2 allowance price effect 

is both significant and estimable using NEMS-BT, it may be added to supporting material. 

16.3 WETLAND, ENDANGERED 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. Therefore, none of the proposed TSLs is expected to affect the 

quality of wetlands, or threatened or endangered species. Further, this action is not expected to 

impact cultural resources such as historical or archaeological sites. 

16.4 SOCIOECONOMIC IMPACTS 

 DOE's analysis has shown that the increase in the first cost of purchasing 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 presented in Chapter 8 of the TSD. 

 For subgroups of low-income consumers that purchase lighting products, DOE 

determined that the average LCC impact is similar to that for the full sample of consumers. 

Therefore, DOE concludes that the proposed action 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 ENVIRONMENTAL JUSTICE IMPACTS 

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

Environmental Justice in Minority 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 products related to IRL and GSFL 

and (3) small businesses operated by disadvantaged or minority populations. 

16-22 

EE-2006-STD-0131 COMMENT 37.2
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 identified only one company as a small business 

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

small business manufacturer that 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 disproportionate impacts on small businesses 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 disproportionately 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. 

16.6 NOISE AND AESTHETICS 

Improvements in the efficacy of IRL and GSFL products 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 that would meet the proposed efficacy standards are no louder than less 

efficacious products. Changes to the design to improve the efficacy levels are not anticipated to 

affect the products’ aesthetics. 

16.7 SUMMARY OF ENVIRONMENTAL IMPACTS 

 Table 16.7.1 and Table 16.7.2 summarize anticipated environmental impacts for each of 

the TSLs for IRL and GSFL. Air quality impacts were estimated for each of the TSLs. The 

summary table shows cumulative changes in emissions for CO2, NOX, and Hg over the period 

2012 to 2042. The resulting changes in emission quantities are very small. Cumulative CO2, 

NOX, and Hg emissions show a decrease compared to the reference case. 

 Upstream fuel cycle emission of CO2 and NOX 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 suggests 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. This approach does not address Hg emissions. 

 Socioeconomic impacts are presented in TSD Chapter 8. 

16-23 

EE-2006-STD-0131 COMMENT 37.2
Table 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) (114.4) (88.1) (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) (140.6) (77.6) (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) (112.4) (93.9) 

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 values in all subsequent years 2031-2042.

L 5

Table 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) (1,071.6) (950.7) 

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 

EE-2006-STD-0131 COMMENT 37.2
16-25

 

REFERENCES 

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. November, 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, Office of Information and Regulatory Affairs, 2006 

Report to Congress on the Costs and Benefits 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 Protects Children,” 1076 ANN. N.Y. ACAD. SCI. 911 (2006). 

9

 Ted Gayer and Robert Hahn, “Designing Environmental Policy: Lessons from the Regulation 

of Mercury Emissions,” Regulatory Analysis 05-01 (AEI-Brookings Joint 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), SO2 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/> 

EE-2006-STD-0131 COMMENT 37.2