DOE/EA-1530

ENVIRONMENTAL, ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARD S FOR RESIDENTIAL,

FURNACES AN BOILERS

September 2006

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency & Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585

 EE-RM/STD-01-350 COMMENT 104.2

DOE/EA-lS30 

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY 

CONSERVATION STANDARDS FOR RESIDENTIAL 

FURNACES AND BOILERS 

September 2006 

u.S. Department of Energy 

Assistant Secretary 

Office of Energy Efficiency & Renewable Energy 

Building Technologies Program 

Appliances and Commercial Equipment Standards 

Washington, DC 20585 
ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION

STANDARDS FOR RESIDENTIAL FURNACES AND BOILERS

TABLE OF CONTENTS

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

2.0 PURPOSE AND NEED ............................................... EA-2

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION ................ EA-2

3.1 No-Action Alternative .......................................... EA-2

3.2 Proposed Action ............................................... EA-3

3.3 Alternative Standards ........................................... EA-3

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT .................... EA-4

4.1 Geography ................................................... EA-4

4.2 Air Resources ................................................. EA-4

4.2.1 Assumptions ............................................ EA-5

4.2.2 Methods ............................................... EA-6

4.3 Socioeconomics ............................................... EA-8

4.4 Environmental Justice .......................................... EA-8

4.5 Energy Consumption ........................................... EA-8

4.6 Noise and Aesthetics ........................................... EA-8

4.7 Indoor Air Environment ......................................... EA-8

5.0 ENVIRONMENTAL IMPACTS ........................................ EA-9

5.1 Air Quality/Emissions Impacts ................................... EA-9

5.1.1 Power Sector and Household Emissions ...................... EA-9

5.1.2 Fuel-Cycle Emissions ................................... EA-17

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources .... EA-18

5.3 Socioeconomic Impacts ........................................ EA-18

5.4 Environmental Justice Impacts .................................. EA-18

5.5 Energy Consumption Impacts ................................... EA-18

5.6 Noise and Aesthetics .......................................... EA-19

5.7 Indoor Air Environment ........................................ EA-19

5.8 Summary of Environmental Impacts .............................. EA-19

LIST OF TABLES

Table EA.1 Current Energy Efficiency Standard Levels for Residential Furnaces

and Boilers, Base Case .......................................... EA-2

Table EA.2 Proposed Standard Levels for Residential Furnaces and Boilers ......... EA-3

Table EA.3 Trial Standard Levels for Residential Furnaces and Boilers ............. EA-4

Table EA.4 Power Sector Emissions Impacts Forecast (Metric Tons) .............. EA-11

Table EA.5 Household Emissions Impacts Forecast, Relative to the Base Case ...... EA-12

Table EA.6 Cumulative Power Sector Emissions Impacts Forecast, Relative to

the Base Case ................................................ EA-13

Table EA.7 Cumulative Household Emissions Impacts Forecast, Relative to

EA-i

 EE-RM/STD-01-350 COMMENT 104.2

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR RESIDENTIAL FURNACES AND BOILERS 

TABLE OF CONTENTS 

1.0 INTRODUCTION ................................................. " EA-l 

2.0 PURPOSE AND NEED ............................................. " EA-2 

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION ................ EA-2 

3.1 No-Action Alternative ........................................ " EA-2 

3.2 Proposed Action ............................................. " EA-3 

3.3 Alternative Standards ......................................... " EA-3 

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT .................. " EA-4 

4.1 Geography ................................................. " EA-4 

4.2 Air Resources ............................................... " EA-4 

4.2.1 Assumptions............................................ EA-5 

4.2.2 Methods ............................................... EA-6 

4.3 Socioeconomics ............................................. " EA-8 

4.4 Environmental Justice .......................................... EA-8 

4.5 Energy Consumption ......................................... " EA-8 

4.6 Noise and Aesthetics ........................................... EA-8 

4.7 Indoor Air Environment ....................................... " EA-8 

5.0 ENVIRONMENTAL IMPACTS ...................................... " EA-9 

5.1 Air Quality/Emissions Impacts ................................... EA-9 

5.1.1 Power Sector and Household Emissions .................... " EA-9 

5.1.2 Fuel-Cycle Emissions ................................... EA-17 

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources .... EA-18 

5.3 Socioeconomic Impacts ........................................ EA-18 

5.4 EnvironmentalJustice Impacts .................................. EA-18 

5.5 Energy Consumption Impacts ................................... EA-18 

5.6 Noise and Aesthetics .......................................... EA-19 

5.7 Indoor Air Environment ........................................ EA-19 

5.8 Summary of Environmental Impacts .............................. EA-19 

Table EA.1 

Table EA.2 

Table EA.3 

Table EA.4 

Table EA.5 

Table EA.6 

Table EA.7 

LIST OF TABLES 

Current Energy Efficiency Standard Levels for Residential Furnaces 

and Boilers, Base Case ........................................ " EA-2 

Proposed Standard Levels for Residential Furnaces and Boilers ......... EA-3 

Trial Standard Levels for Residential Furnaces and Boilers ........... " EA-4 

Power Sector Emissions Impacts Forecast (Metric Tons) .............. EA-11 

Household Emissions Impacts Forecast, Relative to the Base Case ...... EA-12 

Cumulative Power Sector Emissions Impacts Forecast, Relative to 

the Base Case . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. EA -13 

Cumulative Household Emissions Impacts Forecast, Relative to 

EA-i 
the Base Case ............................................... EA-14

Table EA.8 Cumulative Power Sector and Household Emissions Impacts Forecast,

Relative to the Base Case ' ...................................... EA-15

Table EA.9 Discounted Cumulative Power Sector and Household Emissions Impacts

Forecast, Relative to the Base Case ............................... EA-16

Table EA. 10 Estimated Upstream Emission Factors and Relative Percentages To

Table EA.11

Direct Power Plant Combustion Emissions .........................

Cumulative Energy Savings from Residential Furnaces and Boilers

EA-17

Standards from 2015 to 2038 .................................... EA-19

Table EA. 12 Summary of the Analysis Results ................................ EA-20

 EE-RM/STD-01-350 COMMENT 104.2

the Base Case ............................................... EA -14 

Table EA.8 Cumulative Power Sector and Household Emissions Impacts Forecast, 

Relative to the Base Casel ...................................... EA-15 

Table EA.9 Discounted Cumulative Power Sector and Household Emissions Impacts 

Forecast, Relative to the Base Case ............................... EA-16 

Table EA.l 0 Estimated Upstream Emission Factors and Relative Percentages To 

Direct Power Plant Combustion Emissions ......................... EA-17 

Table EA.ll Cumulative Energy Savings from Residential Furnaces and Boilers 

Standards from 2015 to 2038 .................................... EA-19 

Table EA.12 Summary of the Analysis Results ................................ EA-20 

EA-ii 
ABBREVIATIONS AND ACRONYMS

AEO: Annual Energy Outlook, DOE/EIA publication

ANOPR: Advance Notice of Proposed Rulemaking

ASHRAE: American Society of Heating, Refrigeration, and Air-Conditioning Engineers, Inc.

BT: DOE's Building Technologies program

Btu: British thermal unit

CO2: carbon dioxide

DOE or Department: Department of Energy

EA: Environmental Assessment

EIA: Energy Information Administration

EJ: exajoule (1018 joules)

EPA: Environmental Protection Agency

EPCA: Energy Policy and Conservation Act: Part B of Title III of the Energy Policy and

Conservation Act, Public Law 94-163, as amended by the National Energy Conservation Policy

Act, Public Law 95-619, the National Appliance Energy Conservation Act, Public Law 100-12,

the National Appliance Energy Conservation Amendments of 1988, Public Law 100-357, and

the Energy Policy Act of 1992, Public Law 102-486

FR: Federal Register

GJ: gigajoule (109 joules)

GW: gigawatt (109 watts)

kt/a: kilo (thousand) metric tons per annum (year)

kWh: kilowatt-hour (thousand watts per hour)

LCC: life-cycle cost

Mt/a: million metric tons per annum (year)

EA-iii

 EE-RM/STD-01-350 COMMENT 104.2

ABBREVIATIONS AND ACRONYMS 

AEO: Annual Energy Outlook, DOE/EIA publication 

ANOPR: Advance Notice of Proposed Rulemaking 

ASHRAE: American Society of Heating, Refrigeration, and Air-Conditioning Engineers, Inc. 

BT: DOE's Building Technologies program 

Btu: British thermal unit 

CO2: carbon dioxide 

DOE or Department: Department of Energy 

EA: Environmental Assessment 

EIA: Energy Information Administration 

EJ: exajoule (1018 joules) 

EPA: Environmental Protection Agency 

EPCA: Energy Policy and Conservation Act: Part B of Title III of the Energy Policy and 

Conservation Act, Public Law 94-163, as amended by the National Energy Conservation Policy 

Act, Public Law 95-619, the National Appliance Energy Conservation Act, Public Law 100-12, 

the National Appliance Energy Conservation Amendments of 1988, Public Law 100-357, and 

the Energy Policy Act of 1992, Public Law 102-486 

FR: Federal Register 

GJ: gigajoule (l09 joules) 

GW: gigawatt (109 watts) 

kt/a: kilo (thousand) metric tons per annum (year) 

kWh: kilowatt-hour (thousand watts per hour) 

LCC: life-cycle cost 

Mt/a: million metric tons per annum (year) 

EA-iii 
MW: megawatt (million watts)

NAECA: National Appliance Energy Conservation Act

NEMS: National Energy Modeling System

NEPA: National Environmental Policy Act of 1969

NES: National Energy Savings

NOX: nitrogen oxides

PBP: payback period

quad: quadrillion Btu (1015 Btus)

RIA: Regulatory Impact Analysis

SO2: sulfur dioxide

t: metric ton

TSL: Trial Standard Level

TSD: Technical Support Document

U.S.C.: United States Code

 EE-RM/STD-01-350 COMMENT 104.2

MW: megawatt (million watts) 

NAECA: National Appliance Energy Conservation Act 

NEMS: National Energy Modeling System 

NEP A: National Environmental Policy Act of 1969 

NES: National Energy Savings 

NOx : nitrogen oxides 

PBP: payback period 

quad: quadrillion Btu (1015 Btus) 

RIA: Regulatory Impact Analysis 

S02: sulfur dioxide 

t: metric ton 

TSL: Trial Standard Level 

TSD: Technical Support Document 

U.S.C.: United States Code 

EA-iv 
ENVIRONMENTAL ASSESSMENT FOR RESIDENTIAL FURNACES AND BOILERS

1.0 INTRODUCTION

The U.S. Department of Energy (DOE or Department) prepared this residential furnace

and boiler environmental assessment (EA) pursuant to the National Environmental Policy Act of

1969 (NEPA)(42 U.S.C. 4321 et seq.), the regulations of the Council on Environmental Quality

(40 CFR parts 1500-1508), and the DOE's regulations for compliance with NEPA (10 CFR part

1021

Title III of the Energy Policy and Conservation Act (SPCA) sets forth a variety of

provisions designed to improve energy efficiency. Part B of title III (42 U.S.C 6291-6309)

provides for the Energy Conservation Program for Consumer Products other than Automobiles.

The program covers consumer products and certain commercial products (all of which are

referred to hereafter as "covered products") including residential furnaces and boilers.

EPCA authorizes the Department to prescribe new or amended standards for residential

furnaces and boilers. (42 U.S.C 6292(a)(f)) EPCA provides criteria for prescribing new or

amended standards for covered products. As indicated above, any new or amended standard for

a covered product must be designed to achieve the maximum improvement in energy efficiency

that is technologically feasible and economically justified (42 U.S.C 6295(o)(2)(A)). EPCA

precludes the Department from adopting any standard that would not result in significant

conservation of energy. (42 U.S.C 6295(o)(3))

On June 13, 2001, the Department published a Framework Document for Residential

Furnaces and Boilers Standards Rulemaking' that described the procedural and analytical

approaches available to evaluate energy conservation standards for residential furnaces and

boilers. The Department held a Framework Workshop on July 17, 2001, to discuss the

procedural and analytical approaches for use in this rulemaking, to inform and facilitate

stakeholders' involvement in the rulemaking process, and to seek their comments on the

Framework Document. On July 29, 2004, after considering the stakeholder comments about the

technical analysis, DOE published in the Federal Register an Advance Notice of Proposed

Rulemaking (ANOPR) to solicit public comments on its preliminary analyses concerning energy

efficiency standards for residential furnaces and boilers. 69 FR 45419 DOE held a public

meeting on September 29, 2004, to present the methodology and results of the ANOPR analyses,

and to solicit oral comments from the stakeholders in attendance. Subsequently revised the

analysis and prepared a NOPR, of which the Environmental Assessment is a part.

 EE-RM/STD-01-350 COMMENT 104.2

ENVIRONMENTAL ASSESSMENT FOR RESIDENTIAL FURNACES AND BOILERS 

1.0 INTRODUCTION 

The u.s. Department of Energy (DOE or Department) prepared this residential furnace 

and boiler environmental assessment (EA) pursuant to the National Environmental Policy Act of 

1969 (NEPA)(42 U.S.c. 4321 et seq.), the regulations of the Council on Environmental Quality 

(40 CFR parts 1500-1508), and the DOE's regulations for compliance with NEPA (10 CFR part 

1021). 

Title III of the Energy Policy and Conservation Act (EPCA) sets forth a variety of 

provisions designed to improve energy efficiency. Part B of title III (42 U.S.C 6291-6309) 

provides for the Energy Conservation Program for Consumer Products other than Automobiles. 

The program covers consumer products and certain commercial products (all of which are 

referred to hereafter as "covered products") including residential furnaces and boilers. 

EPCA authorizes the Department to prescribe new or amended standards for residential 

furnaces and boilers. (42 U.S.C 6292(a)(f)) EPCA provides criteria for prescribing new or 

amended standards for covered products. As indicated above, any new or amended standard for 

a covered product must be designed to achieve the maximum improvement in energy efficiency 

that is technologically feasible and economically justified (42 U.S.C 6295(0)(2)(A)). EPCA 

precludes the Department from adopting any standard that would not result in significant 

conservation of energy. (42 U.S.C 6295(0)(3)) 

On June 13, 2001, the Department published a Framework Document for Residential 

Furnaces and Boilers Standards Rulemaking' that described the procedural and analytical 

approaches available to evaluate energy conservation standards for residential furnaces and 

boilers. The Department held a Framework Workshop on July 17,2001, to discuss the 

procedural and analytical approaches for use in this rulemaking, to inform and facilitate 

stakeholders' involvement in the rulemaking process, and to seek their comments on the 

Framework Document. On July 29,2004, after considering the stakeholder comments about the 

technical analysis, DOE published in the Federal Register an Advance Notice of Proposed 

Rulemaking (ANOPR) to solicit public comments on its preliminary analyses concerning energy 

efficiency standards for residential furnaces and boilers. 69 FR 45419 DOE held a public 

meeting on September 29,2004, to present the methodology and results of the ANOPR analyses, 

and to solicit oral comments from the stakeholders in attendance. Subsequently revised the 

analysis and prepared a NOPR, of which the Environmental Assessment is a part. 

EA-l 
2.0 PURPOSE AND NEED

In proposing the action described in the NOPR the Department is responding to the

requirements of Title III of the Energy Policy and Conservation Act (SPCA), which sets forth a

variety of provisions designed to achieve the goal of improving the energy efficiency of

consumer products.

Consistent with the EPCA requirements described in section 1.0, DOE exercises its

discretion in deciding the level for a minimum efficiency standard, not in deciding if there

should be one. More stringent energy efficiency standards for residential furnaces and boilers

will result in saving energy. The metric used to measure the efficiency of residential furnaces

and boilers is the Annual Fuel Utilization Efficiency (AFUE). An increase in the AFUE

indicates that the furnace or boiler is more efficient. Details on the technical analysis of

increased efficiency levels are provided in the Residential Furnace and Boiler Technical Support

Document (TSD) that accompanies DOE's NOPR for the proposed standards.'

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION

The Department analyzed five alternative standards levels consisting of the four TSLs

identified in the NOPR and a no-action alternative . As discussed above, DOE's proposed action

is to adopt TSL 2. The five alternatives are discussed below.

3.1 No-Action Alternative

Under a no-action alternative, DOE would not publish new minimum energy efficiency

standards for residential furnaces and boilers, and the efficiency standards would remain at

current levels (Table EA.2). (42 U.S.C 6295(f)(1)) The current standards went into effect on

January 1, 1992, with the exception of the standard for mobile home furnaces, for which the

effective date was September 1, 1990. DOE also refers to the no-action alternative as a base

case.

Table EA.1 Current Energy Efficiency Standard Levels for Residential Furnaces and

Boilers, Base Case

NWGF WGF MHF OF GB OB

AFUE % AFUE % AFUE % AFUE % AFUE % AFUE %

78 78 75 78 80 80

Product Class List:

NWGF = Non-Weatherized Gas Furnace

WGF = Weatherized Gas Furnace

MHF = Mobile Home Gas Furnace

OF = Oil-fired Furnace

GB = Gas Boiler

OB = Oil-fired Boiler

EA-2

 EE-RM/STD-01-350 COMMENT 104.2

2.0 PURPOSE AND NEED 

In proposing the action described in the NOPR the Department is responding to the 

requirements of Title III of the Energy Policy and Conservation Act (EPCA), which sets forth a 

variety of provisions designed to achieve the goal of improving the energy efficiency of 

consumer products. 

Consistent with the EPCA requirements described in section 1.0, DOE exercises its 

discretion in deciding the level for a minimum efficiency standard, not in deciding if there 

should be one. More stringent energy efficiency standards for residential furnaces and boilers 

will result in saving energy. The metric used to measure the efficiency of residential furnaces 

and boilers is the Annual Fuel Utilization Efficiency (AFUE). An increase in the AFUE 

indicates that the furnace or boiler is more efficient. Details on the technical analysis of 

increased efficiency levels are provided in the Residential Furnace and Boiler Technical Support 

Document (TSD) that accompanies DOE's NOPR for the proposed standards.2 

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION 

The Department analyzed five alternative standards levels consisting of the four TSLs 

identified in the NOPR and a no-action alternative. As discussed above, DOE's proposed action 

is to adopt TSL 2. The five alternatives are discussed below. 

3.1 No-Action Alternative 

Under a no-action alternative, DOE would not publish new minimum energy efficiency 

standards for residential furnaces and boilers, and the efficiency standards would remain at 

current levels (Table EA.2). (42 U.S.C 6295(f)(1)) The current standards went into effect on 

January 1, 1992, with the exception of the standard for mobile home furnaces, for which the 

effective date was September 1, 1990. DOE also refers to the no-action alternative as a base 

case. 

Table EA.1 Current Energy Efficiency Standard Levels for Residential Furnaces and 

Boilers, Base Case 

NWGF WGF 

AFUE% AFUE% 

78 78 

Product Class List: 

NWGF = Non-Weatherized Gas Furnace 

WGF = Weatherized Gas Furnace 

MHF = Mobile Home Gas Furnace 

OF = Oil-fired Furnace 

GB = Gas Boiler 

OB = Oil-fired Boiler 

MHF OF GB OB 

AFUE% AFUE% AFUE% AFUE% 

75 78 80 80 

EA-2 
The no-action alternative is contrary to the requirement to amend the statutory energy

efficiency standards to achieve the maximum improvement in energy efficiency for residential

furnaces and boilers that it determines is technologically feasible and economically justified. 42

U.S.C 6295(o)(2)(A) Notwithstanding, DOE addresses the no-action alternative in the TSD,

including the Residential Furnaces and Boilers Regulatory Impact Analysis (RIA), as well as

other non-regulatory policy cases and voluntary incentive programs.

3.2 Proposed Action

The DOE's proposed action is to adopt TSL 2 (see Table EA. 2). Doe selected this level

on the basis of national energy savings, reduced average life-cycle costs (LCC) to consumers, a

net national benefit (i.e., monetary savings to the Nation exceed increased equipment costs to the

Nation), and air-borne emissions reductions.

In analyzing improvements in the efficiency of residential furnaces and boilers, DOE

defined five trial standard levels (TSLs). Each TSL consists of a combination of different

AFUE levels applied to six different product classes. Of the five TSLs, DOE proposes to adopt

TSL 2. Table EA.1 summarizes the proposed standard levels.

Table EA.2 Proposed Standard Levels for Residential Furnaces and Boilers

NWGF WGF MHF OF GB OB

AFUE % AFUE % AFUE % AFUE % AFUE % AFUE %

80 83 80 82 84 83

Product Class List:

NWGF = Non-Weatherized Gas Furnace

WGF = Weatherized Gas Furnace

MHF = Mobile Home Gas Furnace

OF = Oil-fired Furnace

GB = Gas Boiler

OB = Oil-fired Boiler

3.3 Alternative Standards

This EA also examines four other TSLs besides those from DOE's proposed action (TSL

2) and the no action alternative. Each TSL is an alternative action, and is compared with the noaction alternative. The no-action alternative, also referred to as the base case, represents a

situation where no new amended standards are proposed. The TSL 1 is less stringent than

DOE's proposed action (TSL 2), while TSLs 3 and 4 are more stringent than TSL 2. Each TSL

has a unique combination of AFUE efficiency levels for each product class. The TSLs,

including DOE's proposed action, are shown in Table EA.3.

EA-3

 EE-RM/STD-01-350 COMMENT 104.2

The no-action alternative is contrary to the requirement to amend the statutory energy 

efficiency standards to achieve the maximum improvement in energy efficiency for residential 

furnaces and boilers that it determines is technologically feasible and economically justified. 42 

U.S.C 6295(0)(2)(A) Notwithstanding, DOE addresses the no-action alternative in the TSD, 

including the Residential Furnaces and Boilers Regulatory Impact Analysis (RIA), as well as 

other non-regulatory policy cases and voluntary incentive programs. 

3.2 Proposed Action 

The DOE's proposed action is to adopt TSL 2 (see Table EA.2). Doe selected this level 

on the basis of national energy savings, reduced average life-cycle costs (LCC) to consumers, a 

net national benefit (i.e., monetary savings to the Nation exceed increased equipment costs to the 

Nation), and air-borne emissions reductions. 

In analyzing improvements in the efficiency of residential furnaces and boilers, DOE 

defined five trial standard levels (TSLs). Each TSL consists of a combination of different 

AFUE levels applied to six different product classes. Of the five TSLs, DOE proposes to adopt 

TSL 2. Table EA.1 summarizes the proposed standard levels. 

T a e hI EA2 . P ropose d S d d L I tan ar eve s £ or R'd eSI entIa . IF 

NWGF WGF 

AFUE% AFUE% 

80 83 

Product Class List: 

NWGF = Non-Weatherized Gas Furnace 

WGF = Weatherized Gas Furnace 

MHF = Mobile Home Gas Furnace 

OF = Oil-fired Furnace 

GB = Gas Boiler 

OB = Oil-fired Boiler 

3.3 Alternative Standards 

MHF OF 

AFUE% AFUE% 

80 82 

urnaces an dB o il ers 

GB OB 

AFUE% AFUE% 

84 83 

This EA also examines four other TSLs besides those from DOE's proposed action (TSL 

2) and the no action alternative. Each TSL is an alternative action, and is compared with the noaction alternative. The no-action alternative, also referred to as the base case, represents a 

situation where no new amended standards are proposed. The TSL 1 is less stringent than 

DOE's proposed action (TSL 2), while TSLs 3 and 4 are more stringent than TSL 2. Each TSL 

has a unique combination of AFUE efficiency levels for each product class. The TSLs, 

including DOE's proposed action, are shown in Table EA.3. 

EA-3 
Table EA.3 Trial Standard Levels for Residential Furnaces and Boilers

NWGF WGF MHF OF GB OB

Trial Standard

Levels AFUE % AFUE % AFUE % AFUE % AFUE % AFUE %

TSL 1 80 80 80 80 82 83

TSL 2 80 83 80 82 84 83

TSL 3 81 83 81 82 84 83

TSL 4 90 83 90 84 84 84

TSL 5 96 83 90 85 99 95

Product Class List:

NWGF = Non-Weatherized Gas Furnace

WGF = Weatherized Gas Furnace

MHF = Mobile Home Gas Furnace

OF = Oil-fired Furnace

GB = Gas Boiler

OB = Oil-fired Boiler

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

4.1 Geography

The residential furnaces and boilers standards that DOE has proposed would apply to all

50 states and United States territories.

4.2 Air Resources

To analyze the effect of proposed efficiency standards on air resources, DOE used a

variant of the DOE Energy Information Administration's (DOE/EIA) National Energy Modeling

System (HEMS), called NEMS-BT (BT is DOE's Building Technologies Program)'. The

environmental analysis is similar to the utility sector analysis described in Chapter 13 of the

Residential Furnace and Boiler TSW Outputs of the environmental analysis are in a format

similar to the results of the DOE/EIA's Annual Energy Outlook 2005 (AE02005).3

For each trial standard level, DOE calculated total power sector emissions based on

output from NEMS-BT. Household emissions are also calculated, although exogenous to

' The EIA approves use of the name NEMS to describe only an official version of the model without any

modification to code or data. Because this analysis entails some minor code modifications and the model is run

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it as NEMS-BT.

NEMS-BT was previously called NEMS-BRS.

EA-4

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.3 Trial Standard Levels for Residential Furnaces and Boilers 

NWGF 

Trial Standard 

Levels AFUE% 

TSL 1 80 

TSL2 80 

TSL3 81 

TSL4 90 

TSL5 96 

Product Class List: 

NWGF = Non-Weatherized Gas Furnace 

WGF = Weatherized Gas Furnace 

MHF = Mobile Home Gas Furnace 

OF = Oil-fired Furnace 

GB = Gas Boiler 

OB = Oil-fired Boiler 

WGF MHF OF 

AFUE% AFUE% AFUE% 

80 80 80 

83 80 82 

83 81 82 

83 90 84 

83 90 85 

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT 

4.1 Geography 

GB 

AFUE% 

82 

84 

84 

84 

99 

OB 

AFUE% 

83 

83 

83 

84 

95 

The residential furnaces and boilers standards that DOE has proposed would apply to all 

50 states and United States territories. 

4.2 Air Resources 

To analyze the effect of proposed efficiency standards on air resources, DOE used a 

variant of the DOE Energy Information Administration's (DOE/EIA) National Energy Modeling 

System (NEMS), called NEMS-BT (BT is DOE's Building Technologies ProgramY. The 

environmental analysis is similar to the utility sector analysis described in Chapter 13 of the 

Residential Furnace and Boiler TSD.2 Outputs of the environmental analysis are in a format 

similar to the results of the DOE/EIA's Annual Energy Outlook 2005 (AE02005P 

For each trial standard level, DOE calculated total power sector emissions based on 

output from NEMS-BT. Household emissions are also calculated, although exogenous to 

a The EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it as NEMS-BT. 

NEMS-BT was previously called NEMS-BRS. 

EA-4 
NEMS-BT. The EA considers two pollutants, nitrogen oxides (NOX) and sulfur dioxide (SO2),

and one emission, carbon dioxide (CO2). 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 and may take

the form of solid particles, liquid droplets, or gases. The Clean Air Act Amendments of 1990 list

188 toxic air pollutants that the U.S. Environmental Protection Agency (EPA) is required to

control. The EPA has set national air quality standards for six common pollutants (also referred

to as "criteria" pollutants), two of which are SO2 and NOR. Also, the Clean Air Act Amendments

of 1990 gave authority to EPA to control acidification and require operators of electric power

plants to reduce emissions of SO2 and NOR. 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. Moreover, SO2

trading implies that physical emissions effects of a standard will be zero because emissions will

always be at, or near, the ceiling. Consequently, there is no physical SO2 environmental benefit

from electricity conservation as long as there is enforcement of the emissions ceiling.

4.2.1 Assumptions

The Department conducted the EA as a policy deviation from the Typical Meteorological

Year (TMY) System Load Reference Case, a modified AEO2005 Reference Case, using the

same basic set of assumptions in NEMS. The emissions characteristics of all electricitygenerating plants are exactly as used in AE02005. The TMY System Load Reference Case and

alternative growth scenarios are as described in the utility impact analysis of the Residential

Furnace and Boiler TSD (Chapter 13).2 The Department derived the environmental impacts

using the same higher decrement approach described in the utility impact analysis.

As in the utility impact analysis, the Department substituted the default NEMS system

load with a system load that represents weather conditions for a TMY, which is here referred to

as the TMY system load. As a result, the reference case used to judge the impacts from a

proposed residential furnace and boiler standard is no longer an exact replication of the

AE02005 Reference Case and is therefore referred to as the TMY System Load Reference Case.

The EA also includes a sensitivity analysis for the proposed standard level, using the

High and Low Economic Growth scenarios of NEMS-BT. As described in Chapter 13 of the

TSD2' these scenarios cover a range of macroeconomic growth assumptions.

All environmental impact results include a 15 percent rebound effect which is already

accounted for in the national energy savings inputs.

 EE-RM/STD-01-350 COMMENT 104.2

NEMS-BT. The EA considers two pollutants, nitrogen oxides (NOJ and sulfur dioxide (S02)' 

and one emission, carbon dioxide (C02), 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 and may take 

the form of solid particles, liquid droplets, or gases. The Clean Air Act Amendments of 1990 list 

188 toxic air pollutants that the U.S. Environmental Protection Agency (EPA) is required to 

control. The EPA has set national air quality standards for six common pollutants (also referred 

to as "criteria" pollutants), two of which are S02 and NOx ' Also, the Clean Air Act Amendments 

of 1990 gave authority to EPA to control acidification and require operators of electric power 

plants to reduce emissions of S02 and NOx ' In addressing S02 emissions, the Clean Air Act 

Amendments of 1990 set an S02 emissions cap on all power generation, but permitted flexibility 

among generators through the use of emissions allowances and tradable permits. Moreover, S02 

trading implies that physical emissions effects of a standard will be zero because emissions will 

always be at, or near, the ceiling. Consequently, there is no physical S02 environmental benefit 

from electricity conservation as long as there is enforcement of the emissions ceiling. 

4.2.1 Assumptions 

The Department conducted the EA as a policy deviation from the Typical Meteorological 

Year (TMY) System Load Reference Case, a modified AE02005 Reference Case, using the 

same basic set of assumptions in NEMS. The emissions characteristics of all electricitygenerating plants are exactly as used inAE02005. The TMY System Load Reference Case and 

alternative growth scenarios are as described in the utility impact analysis of the Residential 

Furnace and Boiler TSD (Chapter 13).2 The Department derived the environmental impacts 

using the same higher decrement approach described in the utility impact analysis. 

As in the utility impact analysis, the Department substituted the default NEMS system 

load with a system load that represents weather conditions for a TMY, which is here referred to 

as the TMY system load. As a result, the reference case used to judge the impacts from a 

proposed residential furnace and boiler standard is no longer an exact replication of the 

AE02005 Reference Case and is therefore referred to as the TMY System Load Reference Case. 

The EA also includes a sensitivity analysis for the proposed standard level, using the 

High and Low Economic Growth scenarios ofNEMS-BT. As described in Chapter 13 of the 

TSD2, these scenarios cover a range of macroeconomic growth assumptions. 

All environmental impact results include a 15 percent rebound effect which is already 

accounted for in the national energy savings inputs. 

EA-5 
4.2.2 Methods

4.2.2.1 COZ

The NEMS-BT tracks CO, emissions using a detailed CO2 module that features broad

coverage of all sectors and inclusion of interactive effects. Past experience with CO2 emissions

results from NEMS suggests that the estimated emissions reduction generated by NEMS are

somewhat lower than estimates based on simple average factors. One of the reasons for this

divergence is that NEMS tends to predict that energy conservation displaces more energyefficient generating capacity in the later years of its forecast.

4.2.2.2 Power Sector NOx

The Department evaluates emissions of two airborne pollutants, SO2 and NO, The

NEMS-BT estimates NOX emissions from power generation by conforming to all current

legislation regarding the power facility development, retrofitting, and dispatch, including

potential installations of emissions-reducing equipment. On March 10, 2005, EPA issued the

Clean Air Interstate Rule (CAIR). CAIR will permanently cap emissions of NOx across 28

eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005). As with SO2

emissions, a cap on NOX emissions would possibly result in no physical emissions effects from

equipment efficiency standards in the affected states. When NOX emissions are subject to

emissions caps, the Department's emissions reduction estimate corresponds to incremental

changes in emissions allowance credits in cap-and-trade emissions markets rather than physical

emissions reductions.

4.2.2.3 Power Sector SOZ

As explained above, accurate simulation of S02 trading tends to imply that physical

emissions effects will be zero, as long as emissions are at the ceiling. Therefore, DOE does not

report SO2 results here.

4.2.2.4 Household Emissions

While NEMS-BT contains provisions for estimating emissions of NO,, and SO2 from

power generation, it does not estimate household emissions. Because households use natural

gas, oil, and LPG, the residential sector also contributes to NOX and SO2 emissions. This

analysis therefore includes separate estimates of the effect of standards on household NOX and

SO2 emissions, based on simple emissions factors derived from the literature. Although small,

household SO2 emissions savings are reported because the SO2 emissions caps do not apply to

the residential sector. Appendix W provides a detailed description of the methodology and

sources for deriving the emissions factors for combustion processes in residential furnaces and

boilers.

EA-6

 EE-RM/STD-01-350 COMMENT 104.2

4.2.2 Methods 

4.2.2.1 CO2 

The NEMS-BT tracks CO2 emissions using a detailed CO2 module that features broad 

coverage of all sectors and inclusion of interactive effects. Past experience with CO2 emissions 

results from NEMS suggests that the estimated emissions reduction generated by NEMS are 

somewhat lower than estimates based on simple average factors. One of the reasons for this 

divergence is that NEMS tends to predict that energy conservation displaces more energyefficient generating capacity in the later years of its forecast. 

4.2.2.2 Power Sector NOx 

The Department evaluates emissions of two airborne pollutants, S02 and NOx ' The 

NEMS-BT estimates NOx emissions from power generation by conforming to all current 

legislation regarding the power facility development, retrofitting, and dispatch, including 

potential installations of emissions-reducing equipment. On March 10,2005, EPA issued the 

Clean Air Interstate Rule (CAIR). CAIR will permanently cap emissions of NO x across 28 

eastern states and the District of Columbia. 70 FR 25162 (May 12,2005). As with S02 

emissions, a cap on NOx emissions would possibly result in no physical emissions effects from 

equipment efficiency standards in the affected states. When NOx emissions are subject to 

emissions caps, the Department's emissions reduction estimate corresponds to incremental 

changes in emissions allowance credits in cap-and-trade emissions markets rather than physical 

emissions reductions. 

4.2.2.3 Power Sector S02 

As explained above, accurate simulation of S02 trading tends to imply that physical 

emissions effects will be zero, as long as emissions are at the ceiling. Therefore, DOE does not 

report S02 results here. 

4.2.2.4 Household Emissions 

While NEMS-BT contains provisions for estimating emissions of NO x and S02 from 

power generation, it does not estimate household emissions. Because households use natural 

gas, oil, and LPG, the residential sector also contributes to NOx and S02 emissions. This 

analysis therefore includes separate estimates of the effect of standards on household NOx and 

S02 emissions, based on simple emissions factors derived from the literature. Although small, 

household S02 emissions savings are reported because the S02 emissions caps do not apply to 

the residential sector. Appendix W provides a detailed description of the methodology and 

sources for deriving the emissions factors for combustion processes in residential furnaces and 

boilers. 

EA-6 
4.2.2.5 Fuel-Cycle Emissions

Fuel-cycle emissions refer to all the emissions associated with the amount of energy used

in the upstream and downstream production of energy, including energy used at the power plant.

The NEMS-BT does a thorough accounting of emissions at the power plant due to downstream

energy consumption, but does not account for upstream emissions (i.e., emissions from energy

use during coal and natural gas production). The upstream processes include the mining of coal

or extraction of natural gas, physical preparatory and cleaning processes, and transportation to

the power plant (see section 5.1.2 for further discussion).

4.2.2.6 Interpolation

Because the energy savings from residential furnace and boiler standards are too small to

produce stable power sector results in NEMS-BT, DOE estimated results for the TSLs using

interpolation. This is similar to the process it used to estimate the utility impact analysis results.

Appendix U of the Residential Furnace and Boiler TSD describes the interpolation methodology

in detail.2

4.2.2.7 Extrapolation

The current time horizon of NEMS-BT is 2025 (modeling a 10-year period, 2015-2025),

yet other parts of the appliance energy-efficiency work reach 2038. To address this concern, the

Department has developed an adjunct version of the NEMS model called NEMS-BT2 that is

capable, although in limited form, to model to year 2050. As with the AE02005 Reference Case

in general, the implicit assumption is that the regulatory environment does not change from the

current, known situation during the extrapolation period. Only changes that have been

announced with date-certain introduction are included in NEMS-BT. The NEMS-BT2 2050

extension model based on the 2004 version of NEMS-BT was developed by OnLocation, Inc.,

under a subcontract to the Department. Extensive code and input file changes were required to

allow NEMS-BT2 to run to 2050, unfortunately rendering it impossible to extend the 2005

version. Therefore, the Department used the 2005 version of NEMS-BT to conduct the analysis

through 2025 and the 2004 NEMS-BT2 2050 extension to conduct the analysis from 2026-2038.

Some assumptions and adjustments were required to ease the transition from year 2025 to 2026,

thereby removing the inherent differences between these two versions of the model (see

Appendix V for discussion). To emphasize the extrapolated results wherever they appear, they

are shaded in grey to distinguish them from actual NEMS-BT output.

4.2.2.8 Discounting Emissions

DOE also calculated discounted avoided emissions results. The Department used the

same discount rates that it used in calculating the NPV (seven percent and three percent real) to

calculate discounted cumulative emission reductions. The seven-percent and three-percent real

discount rate values are meant to capture the present value of costs and benefits associated with

projects facing an average degree of risk. Other discount rates may be more applicable to

EA-7

 EE-RM/STD-01-350 COMMENT 104.2

4.2.2.5 Fuel-Cycle Emissions 

Fuel-cycle emissions refer to all the emissions associated with the amount of energy used 

in the upstream and downstream production of energy, including energy used at the power plant. 

The NEMS-BT does a thorough accounting of emissions at the power plant due to downstream 

energy consumption, but does not account for upstream emissions (i.e., emissions from energy 

use during coal and natural gas production). The upstream processes include the mining of coal 

or extraction of natural gas, physical preparatory and cleaning processes, and transportation to 

the power plant (see section 5.1.2 for further discussion). 

4.2.2.6 Interpolation 

Because the energy savings from residential furnace and boiler standards are too small to 

produce stable power sector results in NEMS-BT, DOE estimated results for the TSLs using 

interpolation. This is similar to the process it used to estimate the utility impact analysis results. 

Appendix U of the Residential Furnace and Boiler TSD describes the interpolation methodology 

in detai1. 2 

4.2.2.7 Extrapolation 

The current time horizon ofNEMS-BT is 2025 (modeling a lO-year period, 2015-2025), 

yet other parts of the appliance energy-efficiency work reach 2038. To address this concern, the 

Department has developed an adjunct version of the NEMS model called NEMS-BT2 that is 

capable, although in limited form, to model to year 2050. As with the AE02005 Reference Case 

in general, the implicit assumption is that the regulatory environment does not change from the 

current, known situation during the extrapolation period. Only changes that have been 

announced with date-certain introduction are included in NEMS-BT. The NEMS-BT2 2050 

extension model based on the 2004 version ofNEMS-BT was developed by OnLocation, Inc., 

under a subcontract to the Department. Extensive code and input file changes were required to 

allow NEMS-BT2 to run to 2050, unfortunately rendering it impossible to extend the 2005 

version. Therefore, the Department used the 2005 version ofNEMS-BT to conduct the analysis 

through 2025 and the 2004 NEMS-BT2 2050 extension to conduct the analysis from 2026-2038. 

Some assumptions and adjustments were required to ease the transition from year 2025 to 2026, 

thereby removing the inherent differences between these two versions of the model (see 

Appendix V for discussion). To emphasize the extrapolated results wherever they appear, they 

are shaded in grey to distinguish them from actual NEMS-BT output. 

4.2.2.8 Discounting Emissions 

DOE also calculated discounted avoided emissions results. The Department used the 

same discount rates that it used in calculating the NPV (seven percent and three percent real) to 

calculate discounted cumulative emission reductions. The seven-percent and three-percent real 

discount rate values are meant to capture the present value of costs and benefits associated with 

projects facing an average degree of risk. Other discount rates may be more applicable to 

EA-7 
discount costs and benefits associated with projects facing different risks and uncertainties.

4.3 Socioeconomics

As part of the rulemaking process, DOE evaluated the socioeconomic effects of standards

for non-weatherized gas furnaces on senior and low-income households, sub-groups that DOE

identified as possibly being disproportionately affected by a national standard level. The

Department is especially concerned that increases in the purchase price of equipment could have

negative impacts on these groups that may not be able to afford significant increases in

equipment price. The analysis on consumer sub-groups included determining the differences in

LCC as well as the payback periods for the four TSLs analyzed. Chapter 11 of the Residential

Furnaces and Boilers TSD provides more details on the sub-group analysis.'

4.4 Environmental Justice

A consideration of Environmental Justice is made pursuant to the Executive Order 12898,

Federal Actions to Address Environmental Justice in Minority Populations and Low-Income

Populations. The Executive Order requires federal agencies to assess whether a proposed federal

action causes any disproportionately high and adverse human health or environmental effects on

low-income or minority populations. As mentioned above, DOE evaluated the socioeconomic

effects of standards on low-income households.

4.5 Energy Consumption

The Department used a detailed Shipments and National Energy Savings (NES)

Spreadsheet Model to determine national energy savings as a result of increases in furnaces and

boilers efficiency standards. This spreadsheet model forecasts the national shipments and energy

use of residential furnaces and boiler with and without new standards. The shipments and NES

analyses are described in detail in Chapters 9 and 10, respectively, of the Residential Furnaces

and Boilers TSD.' The NES results include a 15 percent rebound effect.

4.6 Noise and Aesthetics

The Department considered how amended energy conservation standards for residential

furnaces and boilers would affect the noise and aesthetics of the equipment. To improve the

efficiency of residential furnaces and boilers, some design changes can enlarge the size of the

equipment or necessitate the use of more efficient motors and fans. The Department determined

if noise and aesthetics were impacted by these design changes.

4.7 Indoor Air Environment

The Department considered how amended energy conservation standards for residential

furnaces and boilers would affect the indoor air environment. The Department considered the

potential for furnace and boiler standards to pose public health risks due to carbon monoxide

EA-8

 EE-RM/STD-01-350 COMMENT 104.2

discount costs and benefits associated with projects facing different risks and uncertainties. 

4.3 Socioeconomics 

As part of the rulemaking process, DOE evaluated the socioeconomic effects of standards 

for non-weatherized gas furnaces on senior and low-income households, sub-groups that DOE 

identified as possibly being disproportionately affected by a national standard level. The 

Department is especially concerned that increases in the purchase price of equipment could have 

negative impacts on these groups that may not be able to afford significant increases in 

equipment price. The analysis on consumer sub-groups included determining the differences in 

LCC as well as the payback periods for the four TSLs analyzed. Chapter 11 of the Residential 

Furnaces and Boilers TSD provides more details on the sub-group analysis. 2 

4.4 Environmental Justice 

A consideration of Environmental Justice is made pursuant to the Executive Order 12898, 

Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations. The Executive Order requires federal agencies to assess whether a proposed federal 

action causes any disproportionately high and adverse human health or environmental effects on 

low-income or minority populations. As mentioned above, DOE evaluated the socioeconomic 

effects of standards on low-income households. 

4.5 Energy Consumption 

The Department used a detailed Shipments and National Energy Savings (NES) 

Spreadsheet Model to determine national energy savings as a result of increases in furnaces and 

boilers efficiency standards. This spreadsheet model forecasts the national shipments and energy 

use of residential furnaces and boiler with and without new standards. The shipments and NES 

analyses are described in detail in Chapters 9 and 10, respectively, of the Residential Furnaces 

and Boilers TSD. 2 The NES results include a 15 percent rebound effect. 

4.6 Noise and Aesthetics 

The Department considered how amended energy conservation standards for residential 

furnaces and boilers would affect the noise and aesthetics of the equipment. To improve the 

efficiency of residential furnaces and boilers, some design changes can enlarge the size of the 

equipment or necessitate the use of more efficient motors and fans. The Department determined 

if noise and aesthetics were impacted by these design changes. 

4.7 Indoor Air Environment 

The Department considered how amended energy conservation standards for residential 

furnaces and boilers would affect the indoor air environment. The Department considered the 

potential for furnace and boiler standards to pose public health risks due to carbon monoxide 

EA-8 
release into the home as a result of venting system failure.

5.0 ENVIRONMENTAL IMPACTS

5.1 Air Quality/Emissions Impacts

5.1.1 Power Sector and Household Emissions

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

published in the AEO, and include power sector emissions for NO,, and CO2 in five-year forecast

increments extrapolated to the year 2038. The Department reports the outcome of the analysis

for each TSL as a deviation from the TMY System Load Reference Case. This is also referred to

as the base case, as well as the no-action alternative.

As discussed earlier in section 4.2, 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. Moreover, SO2 trading implies that physical

emissions effects of a standard will be zero because emissions will always be at, or near, the

ceiling. Consequently, there is no physical S02 environmental benefit from electricity

conservation as long as there is enforcement of the emissions ceiling. An economic benefit may

result if coal generation falls and the resulting reduced demand for SO2 emission allowances

lowers the allowance price. Because the SO2 effects considered here are too small to provide

reasonable estimates of impacts on allowance prices, the environmental assessment does not

attempt to estimate this benefit. If this price impact is big enough to be detectable in NEMS-BT,

the Department will report this value in future appliance standards rulemakings.

Table EA.4 shows annual total power sector CO2 and NO,, emissions for the base case

(no-action alternative) and each of the five TSLs. Table EA.5 shows the annual results for the

household emissions and shows the High and Low Economic Growth scenario results for TSL 2,

the proposed action. Table EA.6 shows the cumulative power sector emissions impacts through

2025 and 2038 for CO2 and NO, The cumulative emissions through 2038 increase from TSL 1

to TSL 5 due to a rise in electricity generation resulting from a market shift from gas to electric

heating equipment at the higher standard levels.

As discussed earlier in section 4.2, the cap on NO,, emissions would possibly result in no

physical emissions effects from equipment efficiency standards in the affected states. When

NOX emissions are subject to emissions caps, the Department's emissions reduction estimate

corresponds to incremental changes in emissions allowance credits in cap-and-trade emissions

markets rather than physical emissions reductions.

Table EA.7 shows the cumulative household emissions reductions through 2025 and

2038 for CO,, NO,,, and S02. The emissions reductions become larger from TSL 1 to TSL 5 due

to the decline in fuel consumption at these standard levels.

EA-9

 EE-RM/STD-01-350 COMMENT 104.2

release into the home as a result of venting system failure. 

5.0 ENVIRONMENTAL IMPACTS 

5.1 Air Quality/Emissions Impacts 

5.1.1 Power Sector and Household Emissions 

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

published in the AEO, and include power sector emissions for NOx and CO2 in five-year forecast 

increments extrapolated to the year 2038. The Department reports the outcome of the analysis 

for each TSL as a deviation from the TMY System Load Reference Case. This is also referred to 

as the base case, as well as the no-action alternative. 

As discussed earlier in section 4.2, the Clean Air Act Amendments of 1990 set an S02 

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

use of emissions allowances and tradable permits. Moreover, S02 trading implies that physical 

emissions effects of a standard will be zero because emissions will always be at, or near, the 

ceiling. Consequently, there is no physical S02 environmental benefit from electricity 

conservation as long as there is enforcement of the emissions ceiling. An economic benefit may 

result if coal generation falls and the resulting reduced demand for S02 emission allowances 

lowers the allowance price. Because the S02 effects considered here are too small to provide 

reasonable estimates of impacts on allowance prices, the environmental assessment does not 

attempt to estimate this benefit. If this price impact is big enough to be detectable in NEMS-BT, 

the Department will report this value in future appliance standards rulemakings. 

Table EA.4 shows annual total power sector CO2 and NOx emissions for the base case 

(no-action alternative) and each of the five TSLs. Table EA.5 shows the annual results for the 

household emissions and shows the High and Low Economic Growth scenario results for TSL 2, 

the proposed action. Table EA.6 shows the cumulative power sector emissions impacts through 

2025 and 2038 for CO2 and NOx • The cumulative emissions through 2038 increase from TSL 1 

to TSL 5 due to a rise in electricity generation resulting from a market shift from gas to electric 

heating equipment at the higher standard levels. 

As discussed earlier in section 4.2, the cap on NOx emissions would possibly result in no 

physical emissions effects from equipment efficiency standards in the affected states. When 

NOx emissions are subject to emissions caps, the Department's emissions reduction estimate 

corresponds to incremental changes in emissions allowance credits in cap-and-trade emissions 

markets rather than physical emissions reductions. 

Table EA.7 shows the cumulative household emissions reductions through 2025 and 

2038 for CO2, NOx, and S02. The emissions reductions become larger from TSL 1 to TSL 5 due 

to the decline in fuel consumption at these standard levels. 

EA-9 
Table EA.8 shows the total cumulative emissions reductions from both the power sector

and households. The emissions reductions become larger from TSL 1 to TSL 5 because the

decrease in household emissions outweighs the increase in power sector emissions.

Tables EA.4 through EA.8 also include results for the Low and High Economic Growth

cases for the proposed standard (TSL 2). The differences between the reference and sensitivity

cases are due to changes in the macroeconomic assumptions of NEMS-BT.

Table EA.9 shows the discounted cumulative emissions impacts from both the power

sector and households, using seven and three percent real discount rates.

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.8 shows the total cumulative emissions reductions from both the power sector 

and households. The emissions reductions become larger from TSL 1 to TSL 5 because the 

decrease in household emissions outweighs the increase in power sector emissions. 

Tables EA.4 through EA.8 also include results for the Low and High Economic Growth 

cases for the proposed standard (TSL 2). The differences between the reference and sensitivity 

cases are due to changes in the macroeconomic assumptions ofNEMS-BT. 

Table EA.9 shows the discounted cumulative emissions impacts from both the power 

sector and households, using seven and three percent real discount rates. 

EA-IO 
Fable EA.4 Power Sector Emissions Impacts Forecast (Metric 'Ions)'

Difference from AE02005 TMY System Load Reference Case

2000 2005 2010 2015 2020 2025 2030 2035 2038

AE02005 Reference Case with TMY System Load (Base Case) F'r polation

CO, (MUa)1'3 2,283.0 2,372.0 2,624.0 2,800.0 3,024.0 3,312.0 3.137 0 3.5'_ l 0 516,0

NOx (kt/a)''' 4,681.1 3,338.4 3,637.8 3,737.6 3,810.2 3,900.9 3.32n_1 3.3'N 6 3,317.7

Standard Level

CO,(Mt/a) 2,283.0 2,372. 0 2,624.0 2,800 . 0 3,024.0 3,311.9 3,4Y7_U 35'_1.1 3S9C._ C02(Mt/a)

NOx (kt/a) 4,681.1 3,338.4 3,637.8 3,737 . 6 3,810.2 3,901 .0 3,320.6 333X.'' 3.3=17.N NOx ( kUa)

Standard Level 2

CO, (Mt/a) 283.0 2,372. 0 2,624.0 2,800 .0 3,023.9 3,311 .8 3,427.7 i,S_l.i 1-96. 1 CO, (Mtla)

NOx (kUa) 4,681.1 3,338.4 3,637.8 3,7326 3,810.3 3,901.2 3,3207, 3,335.8 3,321.0 NOx ( kt/a)

Standard Level3

CO,(Mt/a) 21283.0 2,372.0 2,624.0 2,800 .0 3,023.9 3,311 ,7 3,427.1 ;,5'_IS 3.396.8 CO,(Mt/a)

NOx (ktla) 4,681.1 3,338.4 3,637.8 3,737 . 6 3,810.5 3,901 4 3.320.5 -,,3340 3,-,115 3 NO) (ktla)

Standard Level 4

2000 2005 2010 2015 2020 20252030 2035 2038

0.0 0.0 0.0 0.0 0.0 -0.1

0.0 0.0 0.0 0.0 0.1 0.1

1 0.0 0.0 0.0 0.0 -0.1 -0.2

0.0 0.0 0.0 0.0 0.2 0.3

0.0 0.0 0.0 0.0 -0.1 -0.3

0.0 0.0 0.0 0.0 0.3 0.5

C03 (MUa) 2,283.0 2,372 . 0 2,624.0 2,800 . 0 3,023.4 3,310 .6 3,427,(, 3,523.2 3Sn95 CO, (Mtla) 0.0 0.0 0.0 0.0 -0.6 -1.4 0

Nos (kt/a) 4,681.1 3,338.4 3,637.8 3,737 . 7 3,811.5 3,9012 322.0 3.-,40. ; 3,349 " NOx (kt/a) 0.0 0.0 0.0 01 1.3 2.3

Standard Level 5

CO, (Mt/a) 2,283.0 2,372 .0 2,624.0 2,800 .0 3,022.3 3,309.3 3,339.7 3,526.5 3;;01.5

NOx(kt/a) 14,681.1 3,338.4 3,637.8 3,738 .0 3,812.5 3,906 .2 ,,3262 ;,3-14.'_ 3,354. 1 NOx(kt/a) 9 0.0 0.0 0.0 0.4 2.3 5.3

AE02005 High Growth Ref Case with TMY System Load

CO,(Mt/a) 2,283.0 2,385.0 2,673.0 2,884.0 3,169.0 3,554.0

NOx (kUa) 4,681.1 3,356.6 3,674.1 3,773.9 3,864.6 3,973.5

Standard Level2 High Growth

_,_3z.1 =.ana(, 3.ao9a

COi(Mt/a) 2,283.0 2,385.0 2,673.0 2,884.0 3,168.9 3,553 .8 3.677.1 3,7783 3,F- C02(Mtla)

NOx(kt/a) 4,681. 1 3,356.6 3,674. 1 3,773.9 3,864.6 3,973.4 33F2.1 3A005 3,409.3 - NOx(kt/a)

AE02005 Low Growth Ref Case with TMY System Load

CO,(Mt/a) 2,283.0 2,359.0 2,573.0 2,719.0 2,887.0 3,088.0 ..195.? ..^R2.9 3.352.3

NOx(kt/a) 4,681.1 3,3203 3,583.4 3,683.2 3,755.7 3,8283 3.276.3 3.285?

Standard Level 2 Low Growth

CO, (Mt/a) 2,283.0 2,359. 0 2,573.0 2,719 .0 2,886.9 3,087 .8 3.195 3 1 1353 ^ C02 (MUa)

NOx (kt/a) 4,681.1 3,320.3 3,583.4 3,683.2 3,7559 3,828.1 i25S _i 3271, 285.'_ NOx (kt/a)

'Negative values refer to a reduction compared to the Reference forecast

2Comparable to Table At 7 of AE02005: Electric Generators

'Comparable to Table AS of AE02005: Emissions

4All results in metric tons (t), equivalent to 1.1 short tons

EA-11

04

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.4 Power Sector Emissions 

2000 2005 2010 2015 2020 

Case with TMY System Load (Base Case) 

2,283.0 2,372.0 2,624.0 2,800.0 3,024.0 

4,681.1 3,338.4 3,637.8 3,737.6 3,810.2 

2,283.0 2,372.0 2,624.0 2,800.0 3,024.0 0.0 0.0 0.0 0.0 0.0 

4,681.1 3,338.4 3,637.8 3,737.6 3,810.2 0.0 0.0 0.0 0.0 0.1 

2,283.0 2,372.0 2,624.0 2,800.0 3,023.9 0.0 0.0 0.0 0.0 -0.1 

4,681.1 3,338.4 3,637.8 3,737.6 3,810.3 0.0 0.0 0.0 0.0 0.2 

2,283.0 2,372.0 2,624.0 2,800.0 3,023.9 0.0 0.0 0.0 0.0 -0.1 

4,681.1 3,338.4 3,637.8 3,737.6 3,810.5 0.0 0.0 0.0 0.0 0.3 

2,283.0 2,372.0 2,624.0 2,800.0 3,023.4 0.0 0.0 0.0 0.0 -0.6 

4,681.1 3,338.4 3,637.8 3,737.7 3,811.5 0.0 0.0 0.0 0.1 1.3 

2,283.0 2,372.0 2,624.0 2,800.0 3,022.3 0.0 0.0 0.0 0.0 -1.7 

4,681.1 3,338.4 3,637.8 3,738.0 3,812.5 0.0 0.0 0.0 0.4 2.3 

High Growth Ref Case with TMY System Load 

(Mt/a) 12,283.0 2,385.0 2,673.0 2,884.0 3,169.0 

(ktla) 4,681.1 3,356.6 3,674.1 3,773.9 3,864.6 

2,673.0 2,884.0 3,168.9 0.0 0.0 0.0 0.0 -0.1 

4,681.1 3,356.6 3,674.1 3,773.9 3,864.6 0.0 0.0 0.0 0.0 0.0 

3,583.4 3,683.2 3,755.7 

2,359.0 2,573.0 2,719.0 2,886.9 0.0 0.0 0.0 0.0 -0.1 

4,681.1 3,320.3 3,583.4 3,683.2 3,755.7 0.0 0.0 0.0 0.0 0.0 

lNegative values refer to a reduction compared to the Reference forecast 

'Comparable to Table AI7 of AE02005: Electric Generators 

'Comparable to Table A8 of AE02005: Emissions 

'All results in metric tons (t), equivalcntto 1.1 shorttons 

EA-ll 
Table EA.5 Household Emissions Impacts Forecast, Relative to the Base Case'

Standard Level 1

COz (Mt/a)

pNOx (kt/a)

SO2 (kt/a)

Standard Level 2

CO2 (Mt/a)

NOx (kt/a)

SO2 (kt/a)

Standard Level 3

COZ (Mt/a)

'NOx (kt/a)

SOz (kt/a)

Standard Level 4

CO2 (Mt/a)

NOx (kt/a)

SO2 (kt/a)

Standard Level 5

CO2 (Mt/a)

-NOx (kt/a)

:SOz (kt/a)

Standard Leve

COz (Mt/a)

NOx (kt/a)

SO2 (kt/a)

0.00 0.00

0.00 0.00

0.00 0.00

tandard Level 2 Low Growth Scenario

CO2 (Mt/a) 0.00 0. 00

NOx (kt/a) 0.00 0.00

SO2 (kt/a) 0.00 0.00

2000 2005

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

2 High Growth Scenario

2010 2015 2020 2025 2030 2035 2038

l;xtralxilalion

0.00 0 . 00 -0.17 -0 .34 -0.53 -0.72 -0.82

0.00 0.00 -0.14 -0 .27 -0.42 -0.57 -0.65!

0.00 0 . 00 -0.01 -0.03 A04 -0.01 -0.05

0.00 0 . 00 -0.37 -0 .76 -1.17 -1.55 -1.74'.

0.00 0.00 -0.30 -0 .61 -0.93 -1.23 -1.381

0.00 0 .00 -0.03 -0.06 -O.OS -0.09 -0.101

0.00 0.00 -0.70 -1 .46 -2.23 -2.89 -3.19

0.00 0.00 -0.58 -1.17 -1.77 -2.30 -2.54

0.00 0 . 00 -0.06 -0.11 -0.16 -0.17 -0.18

0.00 0 .00 -3.24 -6.85 -10.37 -13.19 -14.40',

0.00 0 . 00 -2.66 -5 .47 -8.27 -10.49 -1 1.44

0.00 0 . 00 -0.28 -0 .54 -0.74 -0.80 -0.82

0.00 0 . 00 -6.67 -14.09 -21.42 -27.63 -30.51

0.00 0 .00 -5.37 -11.13 -16.89 -21.74 -23.99,

0.00 0 .00 -1.34 -2.71 -3.90 -4.69 -5.11

0.00 0 . 00 -0.38 -0.76 -1,16 -1.54 -1.73J.

0.00 0.00 -0.30 -0.61 -0.93 -1.23 -1.39!

0.00 0.00 -0.03 -0.06 408 -0.09 -0.10

0.00 0 .00 -0.38 -0.77 -1.19 -1.57 -1.7()',

0.00 0.00 -0.30 -0 .61 -0.93 -1.23 -1.38

0.00 0.00 -0.03 -0.06 -0.08 -0.09 -0.10

Negative values refer to a reduction compared to the Base Case

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.5 Household Emissions Impacts Forecast, Relative to the Base Casel 

2000 2005 2010 2015 2020 2025 

Standard Levell 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -0.17 -0.34 

(kt/a) 0.00 0.00 0.00 0.00 -0.14 -0.27 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.01 -0.03 

Standard Level 2 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -0.37 -0.76 

(kt/a) 0.00 0.00 0.00 0.00 -0.30 -0.61 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.03 -0.06 

Standard Level 3 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -0.70 -1.46 

(kt/a) 0.00 0.00 0.00 0.00 -0.58 -1.17 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.06 -0.11 

Standard Level 4 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -3.24 -6.85 

(kt/a) 0.00 0.00 0.00 0.00 -2.66 -5.47 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.28 -0.54 

Standard LevelS 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -6.67 -14.09 

(kt/a) 0.00 0.00 0.00 0.00 -5.37 -11.13 

S02 (kt/a) 0.00 0.00 0.00 0.00 -1.34 -2.71 

Standard Level 2 Growth Scenario 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -0.38 -0.76 

(kt/a) 0.00 0.00 0.00 0.00 -0.30 -0.61 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.03 -0.06 

Standard Level 2 Growth Scenario 

CO2 (Mt/a) 0.00 0.00 0.00 0.00 -0.38 -0.77 

(kt/a) 0.00 0.00 0.00 0.00 -0.30 -0.61 

S02 (kt/a) 0.00 0.00 0.00 0.00 -0.03 -0.06 

INegative values refer to a reduction compared to the Base Case 

EA-12 
Table EA.6 Cumulative Power Sector Emissions Impacts Forecast, Relative to the Base

Case'

Standard Level 3

CO2 NO -1.3 2.7

NOx (kt) 1 3.1 7.4

Standard Level 4

CO, (Mt) -5.9 12.3

NOx (kt) 14.5 34.2

Standard Level 5

CO, (Mt) -10.1 40.2

NOx (kt) 33.9 99.1

Standard Level 2 High Growth

CO2 (Mt) -0.7 1.5

NOx (kt) -0.6 -0.5

Standard Level 2 Low Growth

CO2 NO -0.7 1.5

NOx (kt) -1.0 -0.9

Negative values correspond to emissions reductions

EA-13

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.6 Cumulative Power Sector Emissions Impacts Forecast, Relative to the Base 

Casel 

Standard Level 1 

CO2 (Mt) -0.3 0.7 

NOx (kt) 0.7 1.8 

Standard Level 2 

CO2 (Mt) -0.7 1.5 

NOx (kt) 1.6 3.9 

Standard Level 3 

CO2 (Mt) -1.3 2.7 

NOx (kt) 3.1 7.4 

Standard Level 4 

CO2 (Mt) -5.9 12.3 

NOx (kt) 14.5 34.2 

Standard LevelS 

CO2 (Mt) -10.1 40.2 

NOx (kt) 33.9 99.1 

Standard Level 2 High Growth 

CO2 (Mt) -0.7 1.5 

NOx (kt) -0.6 -0.5 

Standard Level 2 Low Growth 

CO2 (Mt) -0.7 1.5 

NOx (kt) -1.0 -0.9 

INegative values correspond to emissions reductions 

EA-13 
Table EA.7 Cumulative Household Emissions Impacts Forecast, Relative to the Base

Case'

Cumulative 2000- Cumulative 2000

2025 2039

Standard Level 1

CO2 NO

NOx (kt)

SO2 (kt)

Standard Level 2

CO, (Mt) -4.0

NOx (kt) -3.3

SO, (kt) -0.3

Standard Level 3

CO, (Mt) 7.7 -39.7

NOx (kt) -6.4 -31.9

S02 (kt) -0.6 -2.7

Standard Level 4

C02 NO -35.6 -183.3

NOx (kt) 29.6 -147.2

SO2 (kt) -3.0 -12.7

Standard Level 5

CO2 NO -73.4

NOx (kt) -60.0

SO2 (kt) -14.8

Standard Level 2 High Growth

CO2 NO -3.9

NOx (kt) 3.3

SO2 (kt) -0.3

Standard Level 2 Low Growth

CO2 NO -4.0 -21.3

NOx (kt) -3.3 -16.9

SO2 (kt) -0.3 -1.5

'Negative values correspond to emissions reductions

EA-14

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.7 Cumulative Household Emissions Impacts Forecast, Relative to the Base 

Casel 

"1125 2038 

Standard Levell 

CO2 (Mt) -1.8 -9.7 

NOx (kt) -1.5 -7.8 

S02 (kt) -0.2 -0.7 

Standard Level 2 

CO2 (Mt) -4.0 -21.1 

NOx(kt) -3.3 -16.9 

S02 (kt) -0.3 -1.5 

Standard Level 3 

CO2 (Mt) -7.7 -39.7 

NOx (kt) -6.4 -31.9 

S02 (kt) -0.6 -2.7 

Standard Level 4 

CO2 (Mt) -35.6 -183.3 

NOx (kt) -29.6 -147.2 

S02 (kt) -3.0 -12.7 

Standard LevelS 

CO2 (Mt) -73.4 -381.2 

NOx (kt) -60.0 -302.5 

S02 (kt) -14.8 -69.0 

Standard Level 2 High Growth 

CO2 (Mt) -3.9 -20.9 

NOx (kt) -3.3 -16.9 

S02 (kt) -0.3 -1.5 

Standard Level 2 Low Growth 

CO2 (Mt) -4.0 -21.3 

NOx (kt) -3.3 -16.9 

S02 (kt) -0.3 -1.5 

'Negative values correspond to emissions reductions 

EA-14 
Table EA.8 Cumulative Power Sector and Household Emissions Impacts Forecast,

Relative to the Base Case'

Cumulative 2000-1 Cumulative 2000-

CO, (Mt) 2.1 9.0

NOx (kt) -0.8 -6.0

SO2 (kt) -0.2 -0.7

Standard Level 2

CO, (Mt) 4.7 19.6

NOx (kt) -1.7 -13.0

SO2 (kt) -0.3 -1.5

Standard Level 3

CO2 NO -8.9 -37.0

NOx (kt) -3.3 -24.5

SO2 (kt) -0.6 -2.7

Standard Level 4

CO, NO -41.5 -171.1

NOx (kt) -15.1 -113.0

SO2 (kt) -3.0 -12.7

Standard Level 5

COz NO

NOx (kt)

SOz (kt)

Standard Level 2 High Growth

CO2 NO

NOx (kt)

SO2 (kt)

Standard Level 2 Low Growth

CO2 NO

NOx (kt)

SO, (kt)

`Negative values correspond to emissions reductions

EA-15

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.8 Cumulative Power Sector and Household Emissions Impacts Forecast, 

Relative to the Base Casel 

Cumulative 20 umulative 2000 

2025 2038 

Standard Levell 

CO2 (Mt) -2.1 -9.0 

NOx(kt) -0.8 -6.0 

S02 (kt) -0.2 -0.7 

Standard Level 2 

CO2 (Mt) -4.7 -19.6 

NOx (kt) -1.7 -13.0 

S02 (kt) -0.3 -1.5 

Standard Level 3 

CO2 (Mt) -8.9 -37.0 

NOx (kt) -3.3 -24.5 

S02 (kt) -0.6 -2.7 

Standard Level 4 

CO2 (Mt) -41.5 -171.1 

NOx (kt) -15.1 -113.0 

S02 (kt) -3.0 -12.7 

Standard Level 5 

CO2 (Mt) -83.5 -341.0 

NOx (kt) -26.1 -203.4 

S02 (kt) -14.8 -69.0 

Standard Level 2 High Growth 

CO2 (Mt) -4.5 -19.4 

NOx (kt) -3.9 -17.4 

S02 (kt) -0.3 -1.5 

Standard Level 2 Low Growth 

CO2 (Mt) -4.7 -19.9 

NOx (kt) -4.3 -17.8 

S02 (kt) -0.3 -1.5 

'Negative values correspond to emissions reductions 

EA-15 
Table EA.9 Discounted Cumulative Power Sector and Household Emissions Impacts

Forecast, Relative to the Base Case

Standard Level I

CO, (Mt) -1.7

NOx (kt) -1.0

SO, (kt) -0.1

Standard Level 2

CO, (Mt) -3.6

NOx (kt) -2.2

SO2 (kt) -0.3

Standard Level 3

CO2 NO -6.9

NOx (kt) -4.1

SO2 (kt) -0.5

Standard Level 4

CO2 NO -31.8

NOx (kt) -18.9

SO2 (kt) -2.4

Standard Level 5

CO, (Mt) -63.2

NOx (kt) 33.5

SO2 (kt) -12.5

Standard Level 2 High Growth

CO2 NO 3.5

NOx (kt) -3.1

SO2 (kt) -0.3

Standard Level 2 Low Growth

CO, (Mt) -3.7

NOx (kt) -3.3

SO2 (kt) -0.3

`Negative values correspond to emissions reductions

EA-16

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.9 Discounted Cumulative Power Sector and Household Emissions Impacts 

Forecast, Relative to the Base Case 

Yo Discount 

Standard Levell 

CO2 (Mt) -1.7 -4.2 

NOx (kt) -1.0 -2.7 

S02 (kt) -0.1 -0.3 

Standard Level 2 

CO2 (Mt) -3.6 -9.2 

NOx (kt) -2.2 -5.8 

S02 (kt) -0.3 -0.7 

Standard Level 3 

CO2 (Mt) -6.9 -17.4 

NOx (kt) -4.1 -11.0 

S02 (kt) -0.5 -1.3 

Standard Level 4 

CO2 (Mt) -31.8 -80.6 

NOx(kt) -18.9 -51.0 

S02 (kt) -2.4 -6.0 

Standard LevelS 

CO2 (Mt) -63.2 -160.4 

NOx (kt) -33.5 -91.2 

S02 (kt) -12.5 -32.1 

Standard Level 2 High Growth 

CO2 (M!) -3.5 -9.1 

NOx (kt) -3.\ -8.1 

S02 (kt) -0.3 -0.7 

Standard Level 2 Low Growth 

CO2 (Mt) -3.7 -9.3 

NOx (kt) -3.3 -8.3 

S02 (kt) -0.3 -0.7 

'Negative values correspond to emissions reductions 

EA-16 
5.1.2 Fuel-Cycle Emissions

As discussed earlier, fuel-cycle emissions refer to the emissions associated with the

amount of energy used in the upstream and downstream production of energy, including energy

used at the power plant. The amount of energy used to perform the upstream processes is not

directly linked to the downstream consumption of these fuels. For this reason, changes in

upstream emissions due to proposed standards are not counted in NEMS-BT. DOE does not

report estimates of the effects of alternatives on upstream emissions, thus makes no conclusions

regarding differences in upstream impacts among the alternatives. However, the emissions

factors described here provide the reader with a sense for the possible magnitude of the effects.

Estimates of upstream emissions for C02 and NOX are taken from a study conducted in

1993 by Mark A. DeLuchi (sometimes spelled DeLucci), Ph. D., at Argonne National

Laboratory.' DeLuchi provides estimates of full fuel-cycle emissions factors for C02, methane

(CH4), carbon monoxide (CO), non-methane organic compounds (NMOC), and NOX from coal

and natural gas production.' The emission factor for S02 is taken from the Environmental

Protection Agency (EPA) Report, AP-42, Compilation of Air Pollutant Emission Factors.b The

EPA AP-42 report notes that coal cleaning is the primary source for upstream S02 emissions

from coal production, so the emission factor for S02 reflects only the coal-cleaning process.

Transportation of coal is not addressed in EPA's study.

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 EA. 10 for COD SOD and NO,,. The relative percentage to power plant emissions provides

a means to estimate upstream emission savings based on the savings from the power plant. The

values shown in Table EA.9 represent emissions from upstream processes as mass (g) per

deliverable energy in gigajoules (GJ) to end-use consumers.

Table EA.10 Estimated Upstream Emission Factors and Relative Percentages To Direct

Power Plant Combustion Emissions

Coal Natur al Gas

Emission Factor

(g/G )

% of Combustion

Emissions

Emission Factor

(g/G.)

% of Combustion

Emissions

CO, 8,147 2.7 20,000 11.9

so, 29.2 0.9 0 0

NO, 41.7 5.8 153 40

Relative to the entire fuel cycle, DeLuchi estimates that approximately eight percent by

mass of emissions from coal production are due to mining, preparation that includes cleaning the

coal, and transportation from the mine to the power plant. Transportation emissions include

emissions from the fuel used by the mode of transportation that moves the coal from the mine to

the power plant. Also, DeLuchi estimates that approximately 14 percent of emissions from

natural gas production results from upstream processes. In sum, emissions factors relative to

EA-17

 EE-RM/STD-01-350 COMMENT 104.2

5.1.2 Fuel-Cycle Emissions 

As discussed earlier, fuel-cycle emissions refer to the emissions associated with the 

amount of energy used in the upstream and downstream production of energy, including energy 

used at the power plant. The amount of energy used to perform the upstream processes is not 

directly linked to the downstream consumption of these fuels. For this reason, changes in 

upstream emissions due to proposed standards are not counted in NEMS-BT. DOE does not 

report estimates of the effects of alternatives on upstream emissions, thus makes no conclusions 

regarding differences in upstream impacts among the alternatives. However, the emissions 

factors described here provide the reader with a sense for the possible magnitude of the effects. 

Estimates of upstream emissions for CO2 and NOx are taken from a study conducted in 

1993 by Mark A. DeLuchi (sometimes spelled DeLucci), Ph. D., at Argonne National 

Laboratory.s DeLuchi provides estimates of full fuel-cycle emissions factors for CO2, methane 

(CH4), carbon monoxide (CO), non-methane organic compounds (NMOC), and NOx from coal 

and natural gas production.s The emission factor for S02 is taken from the Environmental 

Protection Agency (EPA) Report, AP-42, Compilation of Air Pollutant Emission Factors. 6 The 

EPA AP-42 report notes that coal cleaning is the primary source for upstream S02 emissions 

from coal production, so the emission factor for S02 reflects only the coal-cleaning process. 

Transportation of coal is not addressed in EPA's study. 

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 EA.1 0 for CO2, S02' and NOx ' The relative percentage to power plant emissions provides 

a means to estimate upstream emission savings based on the savings from the power plant. The 

values shown in Table EA.9 represent emissions from upstream processes as mass (g) per 

deliverable energy in gigajoules (GJ) to end-use consumers. 

Table EA.I0 Estimated Upstream Emission Factors and Relative Percentages To Direct 

Power Plant Combustion Emissions 

Coal Natural Gas 

Emission Factor % of Combustion Emission Factor % of Combustion 

(gIGJ) Emissions (gIGJ) Emissions 

CO2 8,147 2.7 20,000 11.9 

S02 29.2 0.9 0 0 

NO, 41.7 5.8 153 40 

Relative to the entire fuel cycle, DeLuchi estimates that approximately eight percent by 

mass of emissions from coal production are due to mining, preparation that includes cleaning the 

coal, and transportation from the mine to the power plant. Transportation emissions include 

emissions from the fuel used by the mode of transportation that moves the coal from the mine to 

the power plant. Also, DeLuchi estimates that approximately 14 percent of emissions from 

natural gas production results from upstream processes. In sum, emissions factors relative to 

EA-17 
power plant emissions are a relatively small proportion of the energy losses attributable to

upstream processes. With the exception of NOX emissions from natural gas production, upstream

emissions are less than 12 percent of power plant emissions.

5.2 Wetlands / Endangered and 'T'hreatened Species / Cultural Resources

This action is not site-specific, and would not affect land disturbance. Therefore, this

action is not expected to impact 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.

5.3 Socioeconomic Impacts

DOE's analysis has shown that the increase in the first cost of purchasing a more efficient

furnace or boiler at the proposed standard level is offset by a reduction in the LCC of owning a

more efficient piece of equipment. In other words, the owner will pay less operating costs over

the life of the equipment even though the first cost increases.

For the sub-group of consumers that are low-income, DOE determined that for nonweatherized gas furnaces, the proposed standard level would result in slightly less favorable

impacts compared to the full sample of consumers. For the sub-group of consumers that are

seniors, the average LCC impact is similar to that for the full sample of consumers. Therefore

the Department concludes that the proposed action would not have negative socioeconomic

impact. For a complete discussion of the LCC impacts on low-income and senior households,

see Chapter 11 of the Residential Furnaces and Boilers TSD.2

5.4 Environmental Justice Impacts

In view of Executive Order 12898 of February 11, 1994, "Federal Actions to Address

Environmental Justice in Minority Populations and Low-Income Populations," the DOE

examined the effect of more stringent energy efficiency standards on low-income households.

As described in the Life-Cycle Cost Subgroup Analysis, Chapter 11 of the TSD2, the Department

found that there were no disproportionately high and adverse human health or environmental

effects on low-income populations that would result from the proposed energy efficiency

standards. DOE believes that the above conclusion would also apply to minority populations.

5.5 Energy Consumption Impacts

The proposed standard level for furnaces and boilers (TSL 2) would result in the national

energy savings shown in Table EA. 10. Energy savings for the other four TSLs are also

provided, see Chapter 10 of the Residential Furnaces and Boilers TSD.2

EA-18

 EE-RM/STD-01-350 COMMENT 104.2

power plant emissions are a relatively small proportion of the energy losses attributable to 

upstream processes. With the exception of NO x emissions from natural gas production, upstream 

emissions are less than 12 percent of power plant emissions. 

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources 

This action is not site-specific, and would not affect land disturbance. Therefore, this 

action is not expected to impact 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. 

5.3 Socioeconomic Impacts 

DOE's analysis has shown that the increase in the first cost of purchasing a more efficient 

furnace or boiler at the proposed standard level is offset by a reduction in the LCC of owning a 

more efficient piece of equipment. In other words, the owner will pay less operating costs over 

the life of the equipment even though the first cost increases. 

For the sub-group of consumers that are low-income, DOE determined that for nonweatherized gas furnaces, the proposed standard level would result in slightly less favorable 

impacts compared to the full sample of consumers. For the sub-group of consumers that are 

seniors, the average LCC impact is similar to that for the full sample of consumers. Therefore 

the Department concludes that the proposed action would not have negative socioeconomic 

impact. For a complete discussion of the LCC impacts on low-income and senior households, 

see Chapter 11 of the Residential Furnaces and Boilers TSD. 2 

5.4 Environmental Justice Impacts 

In view of Executive Order 12898 of February 11, 1994, "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations," the DOE 

examined the effect of more stringent energy efficiency standards on low-income households. 

As described in the Life-Cycle Cost Subgroup Analysis, Chapter 11 of the TSD2

, the Department 

found that there were no disproportionately high and adverse human health or environmental 

effects on low-income populations that would result from the proposed energy efficiency 

standards. DOE believes that the above conclusion would also apply to minority populations. 

5.5 Energy Consumption Impacts 

The proposed standard level for furnaces and boilers (TSL 2) would result in the national 

energy savings shown in Table EA. 1 O. Energy savings for the other four TSLs are also 

provided, see Chapter 10 of the Residential Furnaces and Boilers TSD. 2 

EA-18 
Table EA.11 Cumulative Energy Savings from Residential Furnaces and Boilers

Standards from 2015 to 2038

Trial No Action TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Cumulative Primary

Standard

Energy

Level

Saved (Quads) 0.00 0.18 0.41 0.69 3.19 6.22

5.6 Noise and Aesthetics

The proposed action is not likely to affect the sound power levels, sound quality levels or

aesthetics associated with residential furnaces and boilers. The impact on noise or aesthetics

from the more efficient equipment covered under this EA would be virtually no different from

equipment being installed today.

5.7 Indoor Air Environment

The Department determined that none of the considered alternatives would lead to carbon

monoxide release into the home as a result of venting system failure, with the possible exception

of TSL 3. TSL 3 includes a standard for non-weatherized gas furnaces and for mobile home gas

furnaces at 81-percent AFUE. At this level, there is some risk of venting system failure due to

condensation. Based on its evaluation of all the information considered during the rulemaking,

the Department believes that the standard levels in the proposed action would not result in

negative impact on the indoor air environment.

5.8 Summary of Environmental Impacts

Table EA. 11 provides a summary of the analysis results to aid the reader in discerning

the benefits and burdens for the different TSLs as well as the no-action alternative.

 EE-RM/STD-01-350 COMMENT 104.2

Table EA.ll Cumulative Energy Savings from Residential Furnaces and Boilers 

Standards from 2015 to 2038 

Trial Standard Level No Action TSL 1 TSL2 TSL3 TSL4 

Cumulative Primary Energy Saved (Quads) 0.00 0.18 0.41 0.69 3.19 

5.6 Noise and Aesthetics 

TSL5 

6.22 

The proposed action is not likely to affect the sound power levels, sound quality levels or 

aesthetics associated with residential furnaces and boilers. The impact on noise or aesthetics 

from the more efficient equipment covered under this EA would be virtually no different from 

equipment being installed today. 

5.7 Indoor Air Environment 

The Department determined that none of the considered alternatives would lead to carbon 

monoxide release into the home as a result of venting system failure, with the possible exception 

ofTSL 3. TSL 3 includes a standard for non-weatherized gas furnaces and for mobile home gas 

furnaces at 8 I-percent AFUE. At this level, there is some risk of venting system failure due to 

condensation. Based on its evaluation of all the information considered during the rulemaking, 

the Department believes that the standard levels in the proposed action would not result in 

negative impact on the indoor air environment. 

5.8 Summary of Environmental Impacts 

Table EA.II provides a summary of the analysis results to aid the reader in discerning 

the benefits and burdens for the different TSLs as well as the no-action alternative. 

EA-19 
Table EA.12 Summary of the Analysis Results

No-Action Trial Standard Level

Alternative 1 2 3 4 5

Cumulative Emission Reductions*

C02 NO 0.0 9.0 19.6 37.0 171.1 341.0

NOx (kt) 0.0 6.0 13.0 24.5 113.0 203.4

Cumulative Primary Energy Saved (Quads)* 0.0 0.18 0.41 0.69 3.19 6.22

Socioeconomic Impacts - Non-Weatherized

Gas Furnace, Mean LCC Savings**

All Consumers NA $2 $2 $2 $5 ($731)

Low-income Sub-group NA $1 $1 ($3) ($20) ($720)

Senior Sub-group NA $2 $2 $1 ($2) ($676)

Environmental Justice Impacts None None None None None None

Wetlands/Endangered and Threatened None None None None None None Species/Cultural Resources Impacts

Fuel-Cycle (Upstream) Emissions Impacts None *** *** *** *** ***

I Noise and Aesthetics Impacts None None None None None None

* Cumulative total is over a time period starting in 2015 and ending in 2038. The reductions include impacts at power plants (both physical

reductions and emissions credits) and at the household level.

** Values refer to savings over the equipment lifetime.

*** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 5.1.2 provides a sense for the possible

magnitude of effects.

The Department has proposed energy efficiency standards for furnaces and boilers at

TSL 2. The proposed standards would not result in significant environmental impacts. The

proposed standards would apply to all covered products offered for sale in the United States and

its Territories, with a compliance date of January 1, 2015.

The Department has found the proposed standard represents the maximum improvement

in energy efficiency that is technologically feasible and economically justified. The Department

found the benefits to the Nation of the proposed standard (energy savings, consumer average

LCC savings, national NPV increase, and emission reductions) outweigh the costs (loss of

manufacturer NPV, and LCC increases for some consumers). The justification for selecting the

proposed action, TSL 2, over the other TSLs considered is fully explained in Section V.C,

Conclusions of the NOPR. The NOPR is available on the internet at:

/http://www. eere. energy. gov/buildings/appliance standards/residential/fumaces_boilers.httnl

under "Not yet known."

The proposed standards represent an improvement in energy efficiency (relative to the

baseline equipment) of 2 percent for non-weatherized gas furnaces, 5 percent for weatherized gas

furnaces, 5 percent for mobile home gas furnaces, 4 percent for oil-fired furnaces, 4 percent for

gas boilers, and 3 percent for oil boilers.

EA-20

 EE-RM/STD-01-350 COMMENT 104.2

T a e bi EA . 12 S ummaryo fth e A I . R I nalYSIS esu ts 

No-Action Trial Standard Level 

Alternative 1 2 3 4 5 

Cumulative Emission Reductions* 

CO2 (Mt) 0.0 9.0 19.6 37.0 171.1 341.0 

NOx (kt) 0.0 6.0 13.0 24.5 113.0 203.4 

Cumulative Primary Energy Saved (Quads)* 0.0 0.18 0.41 0.69 3.l9 6.22 

Socioeconomic Impacts N on-Weatherized 

Gas Furnace, Mean LCC Savings** 

All Consumers NA $2 $2 $2 $5 ($731) 

Low-income Sub-group NA $1 $1 ($3) ($20) ($720) 

Senior Sub-group NA $2 $2 $1 ($2) ($676) 

Environmental Justice Impacts None None None None None None 

Wetlands/Endangered and Threatened None None None None None None Species/Cultural Resources Impacts 

Fuel-Cycle (Upstream) Emissions Impacts None *** *** *** *** *** 

Noise and Aesthetics Impacts None None None None None None 

* Cumulative total is over a time period starting in 2015 and ending in 2038. The reductions include impacts at power plants (both physical 

reductions and emissions credits) and at the household level. 

** Values refer to savings over the equipment lifetime. 

*** DOE does not report actnal estimates of the effects of standards on upstream emissions, but section 5. J.2 provides a sense for the possible 

magnitude of effects. 

The Department has proposed energy efficiency standards for furnaces and boilers at 

TSL 2. The proposed standards would not result in significant environmental impacts. The 

proposed standards would apply to all covered products offered for sale in the United States and 

its Territories, with a compliance date of January 1,2015. 

The Department has found the proposed standard represents the maximum improvement 

in energy efficiency that is technologically feasible and economically justified. The Department 

found the benefits to the Nation of the proposed standard (energy savings, consumer average 

LCC savings, national NPV increase, and emission reductions) outweigh the costs (loss of 

manufacturer NPV, and LCC increases for some consumers). The justification for selecting the 

proposed action, TSL 2, over the other TSLs considered is fully explained in Section V.C, 

Conclusions of the NOPR. The NOPR is available on the internet at: 

/http://www .eere. energy .gov /buildings/appliance _standards/residential/furnaces _boilers .html 

under "Not yet known." 

The proposed standards represent an improvement in energy efficiency (relative to the 

baseline equipment) of 2 percent for non-weatherized gas furnaces, 5 percent for weatherized gas 

furnaces, 5 percent for mobile home gas furnaces, 4 percent for oil-fired furnaces, 4 percent for 

gas boilers, and 3 percent for oil boilers. 

EA-20 
In the 24-year period after the new standards become effective, the Nation will save

about 0.48 quads of primary energy. Additionally, these energy savings will reduce emission of

air pollutants and greenhouse gases by 22.2 Mt of CO2 and 19.4 kt of NO,

 EE-RM/STD-01-350 COMMENT 104.2

In the 24-year period after the new standards become effective, the Nation will save 

about 0.48 quads of primary energy. Additionally, these energy savings will reduce emission of 

air pollutants and greenhouse gases by 22.2 Mt of CO2 and 19.4 kt ofNOx • 

EA-21 
REFERENCES

1. U.S. Department of Energy-Office of Building Research and Standards. Notice of the

Public Workshop and Availability of the Framework Document for Residential Furnaces

and Boilers. 2001. (Posted November 5, 2001)

<http://www.cere.energy.gov/buildings/appliance_standards/>

2. U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy

Conservation Program for Consumer Products. Technical Support Document: Energy

Conservation Program for Consumer Products; Residential Furnaces and Boilers. 2005.

Washington, D.C.

3. U.S. Department of Energy - Energy Information Administration. Annual Energy

Outlook 2005: With Projections Through 2025. February, 2005. Washington, DC.

Report No. DOE/EIA-0383(2005). This material is available in Docket #83. Contact

Ms. Brenda Edwards-Jones, U.S. Department of Energy, Building Technologies

Program, Mailstop EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-

0121, telephone (202) 586-2945 for more information.

<http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2005).pdf5

4. U.S. Department of Energy-Energy Information Administration. Emissions of

Greenhouse Gases in the United States 2003. December, 2004. Washington, DC.

Report No. DOE/EIA-0573(2004).

5. 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.

6. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors,

AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources, Chapter H, Mineral

Products Industry. 1995. (Posted November)

<htip://www.epa.gov/ttn/chief/gp42cl l .html>

 EE-RM/STD-01-350 COMMENT 104.2

REFERENCES 

1. U.S. Department of Energy-Office of Building Research and Standards. Notice of the 

Public Workshop and Availability of the Framework Document for Residential Furnaces 

and Boilers. 2001. (Posted November 5,2001) 

<http://www.eere.energy.gov/buildings/appliance _ standards/> 

2. U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products. Technical Support Document: Energy 

Conservation Program for Consumer Products; Residential Furnaces and Boilers. 2005. 

Washington, D.C. 

3. U.S. Department of Energy - Energy Information Administration. Annual Energy 

Outlook 2005: With Projections Through 2025. February,2005. Washington, DC. 

Report No. DOE/EIA-0383(2005). This material is available in Docket #83. Contact 

Ms. Brenda Edwards-Jones, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-

0121, telephone (202) 586-2945 for more information. 

<http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2005).pdf> 

4. U.S. Department of Energy-Energy Information Administration. Emissions of 

Greenhouse Gases in the United States 2003. December,2004. Washington, DC. 

Report No. DOE/EIA-0573(2004). 

5. DeLuchi, M. A. Emissions of Greenhouse Gasesfrom the Use of Transportation Fuels 

and Electricity, Volume 2: Appendixes A-S. November, 1993. Argonne National 

Laboratory. Argonne,IL. Report No. ANLIESD/TM-22-Vo1.2. 

6. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources, Chapter 11, Mineral 

Products Industry. 1995. (Posted November) 

<http://www.epa.gov/ttnichief/ap42c 11.html> 

EA-22