CHAPTER 16. ENVIRONMENTAL ASSESSMENT 

TABLE OF CONTENTS 

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

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

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

16.2.1.1 Sulfur Dioxide (SO2).................................................................................... 16-2 

16.2.1.2 Nitrogen Oxides (NOx)................................................................................16-3 

16.2.1.3 Mercury........................................................................................................ 16-3 

16.2.1.4 Carbon Dioxide (CO2) .................................................................................16-3 

16.2.1.5 Particulate Matter......................................................................................... 16-4 

16.2.2 Air Quality Regulation................................................................................................... 16-5 

16.2.3 Global Climate Change.................................................................................................. 16-6 

16.2.3.1 Impacts of Climate Change on the Environment......................................... 16-6 

16.2.3.2 Causes of Climate Change ........................................................................... 16-7 

16.2.3.3 Stabilization of CO2 Concentrations............................................................16-7 

16.2.3.4 The Beneficial Impact of the Rule on CO2 Emissions................................. 16-8 

16.2.3.5 The Incremental Impact of the Rule on Climate Change ............................16-9 

16.2.4 Analytical Methods for Air Emissions ........................................................................ 16-10 

16.2.5 Effects on Power Plant Emissions ............................................................................... 16-11 

16.2.6 Effects on Building Emissions..................................................................................... 16-12 

16.2.7 Effects on Upstream Fuel-Cycle Emissions ................................................................ 16-13 

16.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND
 

CULTURAL RESOURCES ........................................................................................ 16-14 

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

16.5 ENVIRONMENTAL JUSTICE IMPACTS................................................................ 16-17 

16.6 NOISE AND AESTHETICS ....................................................................................... 16-18 

16.7 SUMMARY OF ENVIRONMENTAL IMPACTS..................................................... 16-18 

LIST OF TABLES 

Table 16.2.1 Impact of Commercial Clothes Washer Efficiency Standards on 

Cumulative Energy-Related Emissions of CO2 between 2013-2043 by 

Trial Standard Level (Million Metric Tons of CO2).......................................... 16-9 

Table 16.2.2 Power Sector Emissions Forecast from AEO2009 Reference Case................. 16-11 

Table 16.2.3 Power Sector Emissions Impact Forecasts for Commercial Clothes 

Washers............................................................................................................ 16-12 

Table 16.2.4 Change in Household Emissions from Commercial Clothes Washers............ 16-13 

Table 16.2.5 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct 

Power Plant Combustion Emissions ................................................................ 16-14 

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Table 16.3.1 Top-Loading Commercial Clothes Washers: Per-Cycle Water Use and 

Water Discharge Savings by TSL.................................................................... 16-15 

Table 16.3.2 Front-Loading Commercial Clothes Washers: Per-Cycle Water Use and 

Water Discharge Savings by TSL.................................................................... 16-16 

Table 16.3.3 Summary of National Wastewater Discharge Reductions and National 

Water Savings due to Commercial Clothes Washer Standards (Cumulative 

reductions for products sold from 2013 to 2043)............................................. 16-16 

Table 16.4.1 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, 

Commercial Clothes Washers.......................................................................... 16-17 

Table 16.7.1 Environmental Impact Analysis Results Summary for Commercial Clothes 

Washers............................................................................................................ 16-19 

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CHAPTER 16. ENVIRONMENTAL ASSESSMENT 

16.1 INTRODUCTION 

This chapter describes potential environmental effects that may result from amended 

energy conservation standards for commercial clothes washers. The U.S. Department of Energy 

(DOE)’s proposed energy conservation standards are not site-specific, and would apply to all 50 

States and U.S. territories. Therefore, none of the proposed standards would impact land uses, 

cause any direct disturbance to the land, or directly affect biological resources in any one area. 

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

consumption in comparison to a baseline efficiency level. These changes in the demand for 

electricity and the costs of achieving these savings are the primary drivers in analyzing 

environmental effects. Estimates of source energy savings can be found in the national impact 

analysis in Chapter 11 of this technical support document (TSD). Detailed discussion on TSLs 

can be found in Chapter 9 of this TSD. 

The primary impact of the TSLs is in air quality resulting from changes in power plant 

operations and capacity additions. Therefore, much of this chapter describes the air quality 

analysis. The latter part of the chapter describes potential impacts to other environmental 

resources. 

This chapter presents information and results pertaining solely to CCWs. As described in 

section 1.3 of chapter 1 of this technical support document (TSD), DOE is continuing the 

rulemaking for energy conservation standards for microwave oven standby power, and analyses 

related to these products will be published in a separate TSD. In addition, DOE issued a final 

rule1

 adopting energy conservation standards for conventional cooking products (i.e., cooktops 

and ovens) and microwave oven energy factor (EF), and details of the analyses for these products 

are contained in the corresponding final rule TSD.2 

16.2 AIR EMISSIONS ANALYSIS 

The primary focus of the environmental analysis is the impact on air quality of amended 

energy conservation standards for commercial clothes washers. The outcomes of the 

environmental analysis are driven by changes in power plant types and quantities of electricity 

generated under each of the alternatives. Changes in generation are described in the utility 

impact analysis in Chapter 14. 

16.2.1 Air Emissions Descriptions 

For each of the TSLs, DOE calculated total power-sector emissions based on output from 

NEMS-BT model (see Chapter 14). This analysis considers three pollutants: nitrogen oxides 

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EERE-2006-STD-0127 COMMENT 69.1
 

(NOx), mercury (Hg), and sulfur dioxide (SO2). An air pollutant is any substance in the air that 

can cause harm to humans or the environment. Pollutants may be natural or man-made (i.e., 

anthropogenic) and may take the form of solid particles (i.e., particulates or particulate matter), 

liquid droplets, or gasesa

. This analysis also considers carbon dioxide (CO2). 

16.2.1.1 Sulfur Dioxide (SO2) 

Sulfur dioxide, or SO2, belongs to the family of sulfur oxide gases (SOx). These gases 

dissolve easily in water. Sulfur is prevalent in all raw materials, including crude oil, coal, and ore 

that contains common metals like aluminum, copper, zinc, lead, and iron. SOx gases are formed 

when fuel containing sulfur, such as coal and oil, is burned, and when gasoline is extracted from 

oil, or metals are extracted from ore. SO2 dissolves in water vapor to form acid, and interacts 

with other gases and particles in the air to form sulfates and other products that can be harmful to 

people and their environment.3 

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that 

create uncertainty about standard’s impact on SO2 emissions. Title IV of the Clean Air Act sets 

an annual emissions cap on SO2 for all affected EGUs. SO2 emissions from 28 eastern States 

and the District of Columbia (D.C.) are also limited under the Clean Air Interstate Rule (CAIR, 

published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005), which creates 

an allowance-based trading program that will gradually replace the Title IV program in those 

States and D.C.. (The recent legal history surrounding CAIR is discussed below.) The attainment 

of the emissions caps is flexible among EGUs and is enforced through the use of emissions 

allowances and tradable permits. The standard could lead EGUs to trade allowances and 

increase SO2 emissions that offset some or all SO2 emissions reductions attributable to the 

standard. DOE is not certain that there will be reduced overall SO2 emissions from the 

standards. The NEMS-BT modeling system that DOE plans to use to forecast emissions 

reductions currently indicates that no physical reductions in power sector emissions would occur 

for SO2. However, remaining uncertainty prevents DOE from estimating SO2 reductions from 

the standards at this time. 

Even though DOE is not certain that there will be reduced overall emissions from the 

standard, there may be an economic benefit from reduced demand for SO2 emission allowances. 

Electricity savings decrease the generation of SO2 emissions from power production, which can 

lessen the need to purchase SO2 emissions allowance credits, and thereby decrease the costs of 

complying with regulatory caps on emissions. 

a

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

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

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EERE-2006-STD-0127 COMMENT 69.1
 

16.2.1.2 Nitrogen Oxides (NOx) 

 Nitrogen oxides, or NOx, are the generic term for a group of highly reactive gases, all of 

which contain nitrogen and oxygen in varying amounts. Many of the nitrogen oxides are 

colorless and odorless. However, one common pollutant, nitrogen dioxide (NO2), along with 

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

specific form of NOx reported in this document. NOx is one of the main ingredients involved in 

the formation of ground-level ozone, which can trigger serious respiratory problems. It can 

contribute to the formation of acid rain, and can impair visibility in areas such as national parks. 

NOx also contributes to the formation of fine particles that can impair human health.4 

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

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

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

naturally. Electric utilities account for about 22 percent of NOx emissions in the United States. 

16.2.1.3 Mercury 

Coal-fired power plants emit Hg found in coal during the burning process. While coalfired power plants are the largest remaining source of human-generated Hg emissions in the 

United States, they contribute very little to the global Hg pool or to contamination of U.S. 

waters. U.S. coal-fired power plants emit Hg in three different forms: oxidized Hg (likely to 

deposit within the United States); elemental Hg, which can travel thousands of miles before 

depositing to land and water; and Hg that is in particulate form. Atmospheric Hg is then 

deposited on land, lakes, rivers, and estuaries through rain, snow, and dry deposition. Once 

there, it can transform into methylmercury and accumulate in fish tissue through 

bioaccumulation. 

Americans are exposed to methylmercury primarily by eating contaminated fish. Because 

the developing fetus is the most sensitive to the toxic effects of methylmercury, women of 

childbearing age are regarded as the population of greatest concern. Children exposed to 

methylmercury before birth may be at increased risk of poor performance on neurobehavioral 

tasks, such as those measuring attention, fine motor function, language skills, visual-spatial 

abilities, and verbal memory. 

16.2.1.4 Carbon Dioxide (CO2) 

Carbon dioxide (CO2) is not a criteria pollutant (see below), but it is of interest because 

of its classification as a greenhouse gas (GHG). GHGs trap the sun’s radiation inside the Earth’s 

atmosphere and either occur naturally in the atmosphere or result from human activities. 

Naturally occurring GHGs include water vapor, CO2, methane (CH4), nitrous oxide (N2O), and 

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

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

gas, and coal), wood, and wood products are burned. During the past 20 years, about threequarters of anthropogenic (i.e., human-made) CO2 emissions resulted from burning fossil fuels.5 

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EERE-2006-STD-0127 COMMENT 69.1
Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes, 

collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and 

the land and oceans is dominated by natural processes, such as plant photosynthesis. While these 

natural processes can absorb some of the anthropogenic CO2 emissions produced each year, 

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

both energy generation and industrial processes account for 84.6 percent of total U.S. GHG 

emissions.5 

16.2.1.5 Particulate Matter 

Particulate matter (PM) also known as particle pollution, is a complex mixture of 

extremely small particles and liquid droplets. Particle pollution is made up of a number of 

components, including acids (such as nitrates and sulfates), organic chemicals, metals, and soil 

or dust particles. 

 PM impacts are of concern due to human exposures that can impact health. Particle 

pollution - especially fine particles - contains microscopic solids or liquid droplets that are so 

small that they can get deep into the lungs and cause serious health problems. Numerous 

scientific studies have linked particle pollution exposure to a variety of problems, including: 

increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty 

breathing, for example; decreased lung function; aggravated asthma; development of chronic 

bronchitis; irregular heartbeat; nonfatal heart attacks; and premature death in people with heart or 

lung disease. 

Power plant emissions can have either direct or indirect impacts on PM. A portion of the 

pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. 

These are direct PM emissions. Meanwhile other pollutants such as SO2 and NOx interact with 

other elements in the atmosphere to produce PM at some distance from the power plant. 

In general, the relative impacts of direct PM emissions reduction compared to other 

pollutants on PM exposures are much more difficult to estimate than other emissions reductions. 

This is due to the complex interactions between PM, other power plant emissions, meteorology 

and atmospheric chemistry that impact human exposure to particulates. Human exposure to PM 

usually occurs at a significant distance from the power plants that are emitting particulates and 

particulate precursors. When power plant emissions travel this distance they undergo highly 

complex atmospheric chemical reactions and the proportion of impacts and exposures 

attributable to different emissions can vary dramatically for different emissions sources and types 

of particulate precursors. These variations in emissions impacts depend on the distance to the 

source, land use and land cover, and the local and regional meteorology responsible for pollutant 

transport, deposition and atmospheric chemistry. 

The Environmental Protection Agency (EPA) has compiled and summarized technical 

studies regarding PM source apportionment.6

 In this compilation of studies, sources are 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

classified into seven categories: (1) Secondary sulfate/coal, (2) Secondary organic matter/mobile 

sources, (3) Nitrate dominated sources, (4) Biomass burning, (5) Industrial, (6) Crustal and salt 

(7) Other. In these studies, the PM exposures attributed to coal power plants are not 

disaggregated between direct particulate emissions and SO2 emissions from these power plants. 

This is because both SO2 and direct PM emissions aggregate and interact with water droplets and 

emissions from other sources to create final particulates that are a complex mixture of different 

constituents. Both the SO2 and direct PM are emitted from the power plant at the same time and 

if the final aerosol particle contains both sulfur compounds and other PM components it is not 

possible to attribute that aerosol particle to one source or the other. Therefore, DOE is not 

currently able to perform modeling that can make reliable estimates of the impact of direct PM 

emissions on air quality at this time. 

16.2.2 Air Quality Regulation 

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

to control.3 EPA has set national air quality standards for six common pollutants (also referred 

to as “criteria” pollutants), two of which are SO2 and NOx. Also, the Clean Air Act Amendments 

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

plants to reduce emissions of SO2 and NOx. Title IV of the 1990 amendments established a capand-trade program for SO2 intended to help control acid rain.3 This cap-and-trade program 

serves as a model for more recent programs with similar features. 

In 2005, EPA issued the Clean Air Interstate Rule (CAIR) under sections 110 and 111 of 

the Clean Air Act (40 CFR Parts 51, 96, and 97).7 b CAIR will permanently cap emissions of 

SO2 and NOx in eastern States of the United States. CAIR achieves large reductions of SO2 

and/or NOx emissions across 28 eastern states and the District of Columbia. States must achieve 

the required emission reductions using one of two compliance options: 1) meet an emission 

budget for each regulated state by requiring power plants to participate in an EPA-administered 

interstate cap-and-trade system that caps emissions in two stages, or 2) meet an individual state 

emissions budget through measures of the state’s choosing. Phase 1 caps for NOx are to be in 

place in 2009. Phase 1 caps for SO2 are to be in place in 2010. The Phase 2 caps for both 

pollutants are due in 2015. 

Also in 2005, EPA issued the final rule entitled “Standards of Performance for New and 

Existing Stationary Sources: Electric Steam Generating Units,” under sections 110 and 111 of 

the Clean Air Act (40 CFR Parts 60, 63, 72, and 75).8

 This rule, also called the Clean Air 

Mercury Rule (CAMR), was closely related to the CAIR and established standards of 

performance for Hg emissions from new and existing coal-fired electric utility steam generating 

units. The CAMR regulated Hg emissions from coal-fired power plants. 

b

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

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

On February 8, 2008, the U.S. Court of Appeals for the District of Columbia Circuit 

(D.C. Circuit) issued its decision in State of New Jersey, et al. v. Environmental Protection 

Agency,

c

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

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit) issued its decision in North Carolina v. Environmental Protection Agency, which 

vacated the CAIR issued by the U.S. Environmental Protection Agency on March 10, 2005.d 

CAIR was the vehicle for capping NOx emissions. 

e

 On December 23, 2008, the D.C. Circuit 

decided to allow CAIR to remain in effect until it is replaced by a rule consistent with the court’s 

earlier opinion. North Carolina v. Environmental Protection Agency, 550 F.3d 1176 (D.C. Cir. 

2008) (remand of vacatur).f 

16.2.3 Global Climate Change 

Climate change has evolved into a matter of global concern because it is expected to have 

widespread, adverse effects on natural resources and systems. A growing body of evidence 

points to anthropogenic sources of greenhouse gases, such as carbon dioxide (CO2), as major 

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

rates from the fossil fuel sector in the United States, the Department here examines the impacts 

and causes of climate change and then the potential impact of the Rule on CO2 emissions and 

global warming. 

16.2.3.1 Impacts of Climate Change on the Environment 

Climate is usually defined as the average weather, over a period ranging from months to 

many years. Climate change refers to a change in the state of the climate, which is identifiable 

through changes in the mean and/or the variability of its properties (e.g., temperature or 

precipitation) over an extended period, typically decades or longer.9 

The World Meteorological Organization and United Nations Environment Programme 

(UNEP) established the Intergovernmental Panel on Climate Change (IPCC) to provide an 

objective source of information about climate change. According to the IPCC Fourth 

Assessment Report (IPCC Report), published in 2007, climate change is consistent with 

observed changes to the world’s natural systems; the IPCC expects these changes to continue.9 

Changes that are consistent with warming include warming of the world’s oceans to a 

depth of 3000 meters; global average sea level rise at an average rate of 1.8 mm per year from 

1961 to 2003; loss of annual average Arctic sea ice at a rate of 2.7 % per decade, changes in 

c

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

d

 North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008) See http://www.epa.gov/cleanairinterstaterule/. 

e See id. at 903. 

f

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

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wind patterns that affect extra-tropical storm tracks and temperature patterns, increases in intense 

precipitation in some parts of the world, as well as increased drought and more frequent heat 

waves in many locations worldwide, and numerous ecological changes.10 

Looking forward, the IPCC describes continued global warming of about 0.2°C per 

decade for the next two decades under a wide range of emission scenarios for carbon dioxide 

(CO2), other greenhouse gases (GHG)s, and aerosols. After that period, the rate of increase is 

less certain. The IPCC Report describes increases in average global temperatures of about 1.1°C 

to 6.4°C at the end of the century relative to today. These increases vary depending on the model 

and emissions scenarios.9 

The IPCC Report describes incremental impacts associated with the rise in temperature. 

At ranges of incremental increases to the global average temperature, IPCC reports, with either 

high or very high confidence, that there is likely to be an increasing degree of impacts such as 

coral reef bleaching, loss of wildlife habitat, loss to specific ecosystems, and negative yield 

impacts for major cereal crops in the tropics, but also projects that there likely will be some 

beneficial impacts on crop yields in temperate regions. 

16.2.3.2 Causes of Climate Change 

The IPCC Report states that the world has warmed by about 0.74°C in the last 100 years. 

The IPCC Report finds that most of the temperature increase since the mid-20th century is very 

likely due to the increase in anthropogenic concentrations of CO2 and other long-lived 

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

natural causes. 

 Increasing the CO2 concentration partially blocks the earth’s re-radiation of captured 

solar energy in the infrared band, inhibits the radiant cooling of the earth, and thereby alters the 

energy balance of the planet, which gradually increases its average temperature. The IPCC 

Report estimates that currently, CO2 makes up about 77% of the total CO2-equivalentg global 

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

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

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

of the total global warming potential.9 

16.2.3.3 Stabilization of CO2 Concentrations 

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

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

g GHGs differ in their warming influence (radiative forcing) on a global climate system due to their different 

radiative properties and lifetimes in the atmosphere. These warming influences may be expressed through a 

common metric based on the radiative forcing of CO2, i.e., CO2-equivalent. CO2 equivalent emission is the amount 

of CO2 emission that would cause the same- time integrated radiative forcing, over a given time horizon, as an 

emitted amount of other long- lived GHG or mixture of GHGs. 

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

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

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

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

tons of CO2.

11 h

 Researchers have focused on considering atmospheric CO2 concentrations that likely will 

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

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

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

the low end, the IPCC Report scenarios target CO2 stabilized concentrations range between 350 

ppm and 400 ppm (essentially today’s value)—because of climate inertia, concentrations in this 

low end range would still result in temperatures projected to increase 2.0°C to 2.4°C above preindustrial levelsi

 (about 1.3°C to 1.7°C above today’s levels). To achieve concentrations 

between 350 ppm to 400 ppm, the IPCC scenarios present that there would have to be a rapid 

downward trend in total annual global emissions of greenhouse gases to levels that are 50% to 

85% below today’s annual emission rates by no later than 2050. Since it is assumed that there 

would continue to be growth in global populations and substantial increases in economic 

production, the scenarios identify required reductions in greenhouse gas emissions intensity 

(emissions per unit of output) of more than 90%. However, even at these rates, the scenarios 

describe some warming and some climate change is projected due to already accumulated CO2 

and GHGs in the atmosphere.12 

16.2.3.4 The Beneficial Impact of the Rule on CO2 Emissions 

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

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

U.S. Energy Information Administration (EIA) reports in its 2009 Annual Energy Outlook, April 

Release (AEO2009)

13 that U.S. annual energy-related emissions of CO2 in 2007 were about 5.9 

billion metric tons (about 20 percent of the world energy-related CO2 emissions and about 12 

percent of total global greenhouse gas emissions), of which 2.3 billion tons were attributed to 

residential and commercial buildings sector (including related energy–using equipment such as 

commercial clothes washers). Most of the greenhouse gas emissions attributed to residential and 

commercial buildings are emitted from fossil fuel-fired power plants that generate electricity 

used in this sector. In the AEO2009 Reference Case, EIA projected that annual energy-related 

CO2 emissions would grow from 5.9 billion metric tons in 2007 to 6.2 billion metric tons in 

2030, an increase of 4 percent (see AEO2009), while emissions attributable to buildings would 

grow to 2.6 billion tons, an increase of 13 percent. 

h

 Other non-fossil fuel contributors include CO2 emissions from deforestation and decay from agriculture biomass; 

agricultural and industrial emissions of methane; and emissions of nitrous oxide and fluorocarbons. 

i IPCC Working Group 3 Table TS 2 

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As shown in Table 16.2.2 in the AEO2009 Reference Case, the cumulative U.S. energyrelated power sector CO2 emissions between 2013 and 2043 are described at about 79 billion 

metric tons. The estimated cumulative CO2 emission reductions from a commercial clothes 

washer efficiency standard (shown as a range of alternative Trial Standard Levels) during this 

same 30-year period are indicated in Table 16.2.1. Estimated CO2 emission reductions in Table 

16.2.1 come from two sources: electricity generation (i.e., power plants) and fossil fuel-fired 

appliances. The estimated CO2 emission reductions from electricity generation are calculated 

using the NEMS-BT model. The estimated CO2 emission reductions from fossil fuel-fired 

appliances (i.e., commercial clothes washers) are derived from emissions factors for commercial 

natural gas combustion. 

Table 16.2.1	 Impact of Commercial Clothes Washer Efficiency Standards on Cumulative 

Energy-Related Emissions of CO2 between 2013-2043 by Trial Standard 

Level (Million Metric Tons of CO2) 

Trial Standard Levels 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 

Commercial Clothes Washers (CCW) * -2.36 -2.39 -5.07 -5.66 -6.11 

Percent of Total Cumulative Emissions 

Reduction from 2013 to 2043 compared 

with the AEO 2009 Reference Case 

-0.003 -0.003 -0.006 -0.007 -0.008 

* All results in million metric tons, equivalent to 1.1 short tons and negative values refer to a reduction compared with the
 

Base Case. 

The estimated savings shown in Table 16.2.1, which are at most 0.010 percent of U.S. 

energy-related emissions of CO2 (total emissions reported for TSL 5 in Table 16.2.1), comprise 

an even smaller fraction of U.S. emissions of greenhouse gases and of world emissions of 

greenhouse gases. However, the savings would likely reduce overall U.S. CO2 emissions, as 

compared to U.S. CO2 emissions absent an increase in the required efficiency of commercial 

clothes washers. 

16.2.3.5 The Incremental Impact of the Rule on Climate Change 

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

and specific atmospheric concentrations with future temperatures because the IPCC Report 

describes a clear lag in the climate system between any given concentration of CO2 (even if 

maintained for long periods) and the subsequent average worldwide and regional temperature, 

precipitation, and extreme weather regimes. For example, a major determinant of climate 

response is “equilibrium climate sensitivity”, a measure of the climate system response to 

sustained radioactive forcing. It is defined as the global average surface warming following a 

doubling of carbon dioxide concentrations. The IPCC Report describes its estimated, numeric 

value as about 3°C, but the likely range of that value is 2°C to 4.5°C, with cloud feedbacks the 

largest source of uncertainty. Further, as illustrated above, the IPCC Report scenarios for 

stabilization rates are presented in terms of a range of concentrations, which then correlates to a 

range of temperature changes. Thus, climate sensitivity is a key uncertainty for CO2 mitigation 

scenarios that aim to meet specific temperature levels. 

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Because of how complex global climate systems are, it is difficult to know to what extent 

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

indicates, the Rule will likely reduce CO2 emissions rates from the fossil fuel sector. 

16.2.4 Analytical Methods for Air Emissions 

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

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

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

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

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

discussed earlier is section 16.2.2, on December 23, 2008, the D.C. Circuit decided to allow 

CAIR to remain in effect until it is replaced by a rule consistent with the court’s earlier opinion. 

Carolina v. Environmental Protection Agency, 550 F.3d 1176 (D.C. Cir. 2008) (remand of 

vacatur). But actions taken on February 8, 2008 by the U.S. Court of Appeals for the District of 

Columbia Circuit (D.C. Circuit) issued in its decision in State of New Jersey, et al. v. 

Environmental Protection Agency, remain in effect vacating the CAMR. Although the 

constraints on Hg in CAMR have since been vacated by a court decision, the AEO2009 

Reference Case assumes that emissions of Hg would decline over time as shown in Table 16.2.2. 

Coal-fired electric generation is the single largest source of electricity in the United 

States. Because the mix of coals used significantly affects the emissions produced, the model 

includes a detailed representation of coal supply. The model considers the rank of the coal as 

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

Within the NEMS-BT model, planning options for achieving emissions restrictions in the 

Clean Air Act Amendments include installing pollution control equipment on existing power 

plants and building new power plants with low emission rates. These methods for reducing 

emission are compared to dispatching options such as fuel switching and allowance trading. 

Environmental regulations also affect capacity expansion decisions. For instance, new plants are 

not allocated SO2 emissions allowances according to the Clean Air Act Amendments. 

Consequently, the decision to build a particular capacity type must consider the cost (if any) of 

obtaining sufficient allowances. This could involve purchasing allowances or over complying at 

an existing unit. 

DOE’s initial analysis assumed the presence of nationwide emission caps on SO2 and 

caps on NOx emissions in the 28 States covered by the CAIR. In the presence of these caps, the 

NEMS-BT modeling system that DOE used to forecast emissions reduction indicated that no 

physical reductions in power sector emissions would occur for SO2, but that the standards could 

put slight downward pressure on the prices of emissions allowances in cap-and-trade markets. 

In contrast to the modeling forecasts of NEMS-BT that SO2 emissions reductions will 

remain at the cap, during the years 2007 and 2008, SO2 emissions have been below the trading 

cap.14 The difference between the emissions levels that NEMS-BT forecasts and those that EPA 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

forecasts is an indicator of the uncertainties associated with long range energy sector forecasts. 

Because of such uncertainties, DOE is unable to estimate the economic and physical benefit from 

SO2 emissions reductions at this time. 

As noted in Chapter 14, NEMS-BT model forecasts end in year 2030. Emissions impacts 

beyond 2030 were extrapolated for this rulemaking in Table 16.2.3. 

16.2.5 Effects on Power Plant Emissions 

Table 16.2.2 shows reference power plant emissions in selected years along with the 

change from the AEO2009 Reference Case. The Reference case emissions are the emissions 

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

Table 16.2.2 Power Sector Emissions Forecast from AEO2009 Reference Case 

NEMS-BT Results*: 

2005 2010 2015 2020 2025 2030 

CO2 (Million metric tons/year)** 2,397 2,343 2,381 2,466 2,535 2,636 

NOX (Thousand metric tons/year)†

 3,302 2,077 1,869 1,878 1,878 1,905 

Hg (metric tons/year)†

 51.49 43.79 29.46 28.92 29.33 28.73 

* All results in metric tons, equivalent to 1.1 short tons and negative values refer to a reduction compared with 

the Base Case 

** Comparable to Table A17 of AEO2009: Electric Generators 

† Comparable to Table A8 of AEO2009: Emissions 

Table 16.2.3 shows the estimated changes in power plant emissions in selected years for 

all the TSLs. Changes in NOX and Hg emissions from power plants are shown in these tables. 

Changes in CO2 emissions from all sources are also shown in these tables. 

Compared to the anticipated reference case emissions impacts forecast shown in Table 

16.2.2, changes in emission levels shown in Table 16.2.3 are extremely small. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Table 16.2.3 Power Sector Emissions Impact Forecasts for Commercial Clothes Washers 

NEMS-BT Results* Difference from AEO2009 Reference Case 

2013 2015 2020 2025 2030 2035 2040 2043 

Extrapolation 

Cumulative 

2013-2043 

Trial Standard Le vel 1 

CO2 (Mt/a) 0.000 0.000 -0.025 -0.030 -0.033 -0.033 -0.033 -0.033 -0.82 

NOx (kt/a) 0.000 0.000 -0.007 -0.006 -0.009 -0.009 -0.009 -0.009 -0.22 

Hg (t/a) 

Trial Standard Le vel 2 

0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00 

CO2 (Mt/a) 0.000 0.000 -0.025 -0.031 -0.034 -0.034 -0.034 -0.034 -0.84 

NOx (kt/a) 0.000 0.000 -0.007 -0.006 -0.009 -0.009 -0.009 -0.009 -0.22 

Hg (t/a) 

Trial Standard Le vel 3 

0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00 

CO2 (Mt/a) 0.000 0.000 -0.056 -0.067 -0.074 -0.074 -0.075 -0.075 -1.83 

NOx (kt/a) 0.000 0.000 -0.016 -0.013 -0.020 -0.020 -0.020 -0.020 -0.48 

Hg (t/a) 

Trial Standard Le vel 4 

0.000 0.000 0.000 -0.001 0.001 0.001 0.001 0.001 0.00 

CO2 (Mt/a) 0.000 0.000 -0.062 -0.075 -0.083 -0.083 -0.083 -0.083 -2.05 

NOx (kt/a) 0.000 0.000 -0.018 -0.014 -0.022 -0.022 -0.022 -0.022 -0.54 

Hg (t/a) 

Trial Standard Le vel 5 

0.000 0.000 0.000 -0.001 0.001 0.001 0.001 0.001 0.00 

CO2 (Mt/a) 0.000 0.000 -0.067 -0.081 -0.090 -0.090 -0.090 -0.090 -2.22 

NOx (kt/a) 0.000 0.000 -0.020 -0.015 -0.024 -0.024 -0.024 -0.024 -0.59 

Hg (t/a) 0.000 0.000 0.000 -0.001 0.001 0.001 0.001 0.001 0.00 

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

16.2.6 Effects on Building Emissions 

For commercial clothes washers, impacts on commercial building emissions at the site 

are also reported. These estimates are based on exogenous emissions factors for residential and 

commercial natural gas combustion derived by the EPA’s AP-42 report in conjunction with the 

energy savings predicted by the National Impacts Analysis (NIA) model because NEMS-BT 

does not account for these emissions at the site. 

The emissions factors DOE used are derived from what are reported in the AP-42 for 

residential water heaters because no explicit listing was provided for commercial clothes 

washers. However, the AP-42 sources does provide a method for estimating the share of 

emissions from commercial clothes washers based on natural gas deliveries specific to a given 

region, but this approach was not easily applicable to the U.S. so is not performed here.15 j

 As 

well, given that emissions rates from end-use combustion are small compared to other emissions 

j

 The AP-42 source does not list an approach for how to estimate commercial clothes washer related emissions as a 

function of the share of total gas deliveries (http://www.epa.gov/ttn/chief/eiip/techreport/volume03/ng.pdf). 

16-12 

EERE-2006-STD-0127 COMMENT 69.1
 

sources, it is not uncommon to see emissions factors from residential end uses reported in one 

general rate.16 k

 For these reasons, the Department opted to simply use the water heating 

emissions factor as a way of providing a rough estimates for the emissions savings associated 

with these efficiency standards, but acknowledging that these estimates are only general 

approximations. 

Table 16.2.4 shows the estimated changes in building emissions in selected years for the 

commercial clothes washer TSLs. 

Table 16.2.4 Change in Household Emissions from Commercial Clothes Washers 

NEMS-BT Results* Difference from AEO2009 Reference Case 

Trial Standard Le vel 1 

CO2 (Mt/a) 

NOx (kt/a) 

Trial Standard Le vel 2 

CO2 (Mt/a) 

NOx (kt/a) 

Trial Standard Le vel 3 

CO2 (Mt/a) 

NOx (kt/a) 

Trial Standard Le vel 4 

CO2 (Mt/a) 

NOx (kt/a) 

Trial Standard Le vel 5 

CO2 (Mt/a) 

NOx (kt/a) 

2013 2015 2020 2025 2030 

-0.005 -0.016 -0.045 -0.059 -0.059 

-0.004 -0.013 -0.036 -0.046 -0.046 

-0.005 -0.016 -0.046 -0.060 -0.060 

-0.004 -0.013 -0.036 -0.047 -0.047 

-0.011 -0.034 -0.095 -0.124 -0.124 

-0.009 -0.027 -0.075 -0.098 -0.098 

-0.012 -0.037 -0.106 -0.138 -0.138 

-0.010 -0.030 -0.084 -0.109 -0.109 

-0.013 -0.040 -0.114 -0.149 -0.149 

-0.010 -0.032 -0.090 -0.118 -0.118 

2035 2040 

-0.059 -0.059 

-0.046 -0.046 

-0.060 -0.060 

-0.047 -0.047 

-0.124 -0.124 

-0.098 -0.098 

-0.138 -0.138 

-0.109 -0.109 

-0.149 -0.149 

-0.118 -0.118 

Extrapolation 

2043 

-0.059 

-0.046 

-0.060 

-0.047 

-0.124 

-0.098 

-0.138 

-0.109 

-0.149 

-0.118 

Cumulative 

2013-2043 

-1.53 

-1.21 

-1.56 

-1.23 

-3.24 

-2.56 

-3.61 

-2.85 

-3.89 

-3.08 

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

16.2.7 Effects on Upstream Fuel-Cycle Emissions 

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

the upstream production and downstream consumption of electricity, including energy used at 

the power plant. Upstream processes include the mining of coal or extraction of natural gas, 

physical preparatory and cleaning processes, and transportation to the power plant. The NEMSBT does a thorough accounting of emissions at the power plant due to downstream energy 

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

during coal and natural gas production). Thus, this analysis reports only power plant emissions. 

k See section 3.2 of a AGA report. 

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EERE-2006-STD-0127 COMMENT 69.1
However, previous DOE environmental assessment documents have developed 

qualitative estimates of affects on upstream fuel-cycle emissions. These emissions factors 

provide the reader with a sense of the possible magnitude of upstream effects. These upstream 

emissions would be in addition to emissions from direct combustion. Relative to the entire fuel 

cycle, estimates based on the work of Dr. Mark DeLuchi, and reported in earlier DOE 

environmental assessment documents, find that an amount approximately equal to eight percent, 

by mass, of emissions (including SO2) from coal production are due to mining, preparation that 

includes cleaning the coal, and transportation from the mine to the power plant.17 Transportation 

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

from the mine to the power plant. 

In addition, based on Dr. DeLuchi’s work, DOE estimated that approximately an amount 

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

Emission factor estimates and corresponding percentages of contributions of upstream emissions 

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

16.2.5 for CO2 and NOx. The percentages are relative to power plant emissions and provide a 

means to estimate upstream emission savings based on changes in emissions from power plants. 

The percentage effects presented in Table 16.2.5 provides a qualitative approach to viewing 

effects on fuel cycle emissions. The previous section indicates slight overall reductions in CO2 

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

This approach does not address Hg emissions. 

Table 16.2.5	 Estimated Upstream Emissions of Air Pollutants as a Percentage of 

Direct Power Plant Combustion Emissions 

Pollutant 

Percent of Coal 

Combustion Emissions 

Percent of Natural Gas 

Combustion Emissions 

CO2 2.7 11.9 

NOx 5.8 40 

16.3	 WETLAND, ENDANGERED AND THREATENED SPECIES, AND 

CULTURAL RESOURCES 

Because commercial clothes washers are a water-consuming product, more efficient 

washers reduce the amount of water discharged into the waste stream. As a result, commercial 

clothes washer energy efficiency standards have the effect of potentially improving the quality of 

wetlands, and threatened or endangered species that reside in these wetlands. This action is not 

expected to impact cultural resources such as historical or archaeological sites. 

To determine the potential benefits to wetlands from the reductions of wastewater 

discharge due to commercial clothes washer standards, DOE estimated the amount of 

commercial clothes washer water use and the typical amount of water retention in a clothes load 

after a wash cycle. Table 16.3.1 and Table 16.3.2 show the remaining moisture content (RMC) 

and total water use as a function of clothes washer efficiency for top-loading and front-loading 

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EERE-2006-STD-0127 COMMENT 69.1
washers (both the RMC and water use were first presented in Chapter 6, section 6.3.1 of this 

TSD). Based on the RMC of the clothes after a wash cycle, DOE estimated that approximately 

two percent of washer water use is retained in the clothes load at the baseline efficiency level. 

The RMC decreases as a function of efficiency, thereby decreasing the amount of water retention 

in the clothes. But the amount of water use decreases with clothes washer efficiency as well. 

Because the rate of water use savings grows at approximately double the rate of water retention, 

the increased amount of water retained in the clothes as a percentage of the water use savings 

drops from approximately two percent to one percent over the range of clothes washer 

efficiencies considered. Therefore, assuming that water not retained in the clothes load is 

discharged into the wastewater stream, wastewater discharge savings range from 98 to 99 percent 

of the water use savings at the baseline and max-tech levels, respectively (see Tables 16.3.1 and 

16.3.2). Note that TSL 1 for top-loading washers actually yields an increase in wastewater 

discharge because the water factor of the clothes washer does not increase but less water is 

retained in the clothes due to the lower RMC. 

Table 16.3.1	 Top-Loading Commercial Clothes Washers: Per-Cycle Water Use and 

Water Discharge Savings by TSL 

Total Water Use Water Discharge 

Savings 

CSL TSL 

MEF WF 

RMC* 

Amount Savings WI** WC** 

Water 

Retention 

in 

Clothes*** Amount Savings 

as 

percent 

of Water 

Use 

Savings 

cu.ft./kWh/cyc gal/cu.ft. gal/cyc gal/cyc lbs/cyc lbs/cyc gal/cyc gal/cyc gal/cyc percent 

Baseline - 1.26 9.50 53.7% 26.6 - 7.35 11.30 0.47 26.1 - -

1 1, 2 1.42 9.50 51.2% 26.6 0.00 7.35 11.11 0.45 26.1 -0.02 Incr. 

2 3, 4, 5 1.60 8.50 48.4% 23.8 2.80 7.35 10.91 0.43 23.4 2.75 98.3% 

* Based on the relationship: RMC = -0.156* MEF + 0.734 

** WI = Initial Weight of Dry Test Load. WC = Weight of Test Load after Extraction. Values based on a container volume of 2.8 

cu.ft. and an average test-load weight of 11.7 lb/cycle. 

*** Based on water density of 8.33 lbs/gallon. 

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EERE-2006-STD-0127 COMMENT 69.1
Table 16.3.2 Front-Loading Commercial Clothes Washers: Per-Cycle Water Use and 

Water Discharge Savings by TSL 

CSL TSL 

MEF WF 

RMC* 

Total Water Use 

WI** WC** 

Water 

Retention 

in 

Clothes*** 

Water Discharge 

Amount Savings Amount Savings 

Savings 

as 

percent 

of Water 

Use 

Savings 

cu.ft./kWh/cyc gal/cu.ft. gal/cyc gal/cyc lbs/cyc lbs/cyc gal/cyc gal/cyc gal/cyc percent 

Baseline - 1.72 8.00 46.5% 22.4 - 7.35 10.77 0.41 22.0 - -

1 1 1.80 7.50 45.3% 21.0 1.40 7.35 10.68 0.40 20.6 1.39 99.2% 

2 2, 3 2.00 5.50 42.2% 15.4 7.00 7.35 10.45 0.37 15.0 6.96 99.4% 

3 4 2.20 5.10 39.0% 14.3 8.12 7.35 10.22 0.34 13.9 8.05 99.2% 

4 5 2.35 4.40 36.7% 12.3 10.08 7.35 10.55 0.32 12.0 9.99 99.1% 

* Based on the relationship: RMC = -0.156* MEF + 0.734 

** WI = Initial Weight of Dry Test Load. WC = Weight of Test Load after Extraction. Values based on a container volume of 2.8 

cu.ft. and an average test-load weight of 11.7 lb/cycle. 

*** Based on water density of 8.33 lbs/gallon. 

Table 16.3.3 shows the national wastewater discharge reductions due to the trial standard 

levels for commercial clothes washers. For comparison purposes, the national water savings due 

to the commercial clothes washer trial standard levels are also provided in the table to show how 

the wastewater discharge reductions compare to the national water savings. The national water 

savings were first presented in Chapter 11, section 11.5.2 of this TSD. 

Table 16.3.3	 Summary of National Wastewater Discharge Reductions and National 

Water Savings due to Commercial Clothes Washer Standards 

(Cumulative reductions for products sold from 2013 to 2043) 

1 2 3 4 5 

Water Savings (billion galons) 1 6 143 163 209 

Wastewater Reduction (billion gallons) 0.4 5 141 161 206 

16.4 SOCIOECONOMIC IMPACTS 

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

commercial clothes washers at the proposed standard level is completely offset by a reduction in 

the life-cycle cost (LCC) of owning a more efficient piece of equipment. In other words, the 

customer will pay less operating costs over the life of the equipment even through the first cost 

increases. The complete analysis and its conclusions are presented in Chapter 8 of the TSD. 

For subgroups of small businesses and building owners without municipal water and 

wastewater that purchase commercial clothes washers, DOE determined that the average LCC 

impact is similar to that for the full sample of consumers. Therefore, DOE concludes that the 

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EERE-2006-STD-0127 COMMENT 69.1
 

proposed action would have no significant socioeconomic impact. For a complete discussion on 

the LCC impacts on consumer subgroups, see Chapter 12 of the TSD. 

Table 16.4.1 shows the mean LCC savings for both the full sample of consumers and 

subgroup of consumers for commercial clothes washers. 

Table 16.4.1	 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, 

Commercial Clothes Washers 

Trial Standard Level 

1 2 3 4 5 

Top-Loading Washers, Multi-Family Application 

All Consumers -$8 -$8 $179 $179 $179 

Small Business Subgroup -$22 -$22 $113 $113 $113 

No Municipal Water/Wastewater Subgroup -$8 $8 $184 $184 $184 

Top-Loading Washers, Laundromat Application 

All Consumers -$18 -$18 $190 $190 $190 

Small Business Subgroup -$26 -$26 $141 $141 $141 

No Municipal Water/Wastewater Subgroup -$18 -$18 $196 $196 $196 

Front-Loading Washers, Multi-Family Application 

All Consumers $5 $19 $19 $91 $203 

Small Business Subgroup $4 $15 $15 $69 $152 

No Municipal Water/Wastewater Subgroup $5 $20 $20 $95 $210 

Front-Loading Washers, Laundromat Application 

All Consumers $5 $22 $22 $93 $216 

Small Business Subgroup $4 $15 $15 $76 $176 

No Municipal Water/Wastewater Subgroup $5 $22 $22 $96 $223 

16.5 ENVIRONMENTAL JUSTICE IMPACTS 

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

Environmental Justice in Minority Populations and Low-Income Populations,” DOE is required 

to examine the effect of more stringent energy-efficiency standards on (1) small businesses that 

either manufacture or use commercial clothes washers, (2) manufacturers of niche products 

related to commercial clothes washers, and (3) small businesses operated by disadvantaged or 

minority populations. 

DOE identified small businesses as a subgroup that possibly could be disproportionately 

affected by commercial clothes washer energy conservation standards. As described in the LifeCycle Cost Subgroup Analysis, Chapter 12 of the TSD, DOE found that there was no 

disproportionately high and adverse human health or environmental effects on small businesses 

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EERE-2006-STD-0127 COMMENT 69.1
that would result from the proposed energy conservation standards. DOE believes that above 

conclusion also applies to minority populations. 

16.6 NOISE AND AESTHETICS 

Improvements in efficiency of commercial clothes washers is expected to result from 

changes in the choice of components and other design features. These changes are described in 

Chapter 5 of this TSD. These design changes are not expected to change noise levels in 

comparison to equipment in today’s market. Equipment that is currently manufactured in the 

existing market that would meet the proposed standards is no louder than less efficient 

equipment. Changes to the design to improve the efficiency levels are not anticipated to affect 

the equipment’s aesthetics. 

16.7 SUMMARY OF ENVIRONMENTAL IMPACTS 

Table 16.7.1 summarizes anticipated environmental impacts for each of the TSLs across 

all equipment types. Air quality impacts were modeled for each of the TSLs. The summary 

table shows cumulative changes in emissions for CO2, NOx, and Hg over the period 2013 to 

2043. The resulting changes in emission quantities are very small. Cumulative CO2, NOx, and 

Hg emissions show a decrease compared to the reference case. Hg emissions show a very small 

increase in cumulative emissions. This increase may result from the combined effects of 

emissions banking, a shift in how power plants are dispatched, or the timing within the model of 

when power plants are replaced. 

Upstream fuel cycle emission of CO2 and NOx are described but not quantified in section 

16.2.7. The text describes potential reductions in fuel cycle emissions as percentage of decreases 

in power plant emissions. This qualitative approach suggests that upstream fuel cycle emissions 

would decrease and provides a sense for the magnitude of effects, however DOE does not report 

actual estimates of the effects. This approach does not address Hg emissions. 

Socioeconomic impacts are presented as changes in life cycle costs. No impacts are 

anticipated in the area of environmental justice; wetlands, endangered and threatened species, 

and cultural resources; or noise and aesthetics. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Table 16.7.1 Environmental Impact Analysis Results Summary for Commercial Clothes 

Washers 

Environmental Effects 

Reference 

Case* 

Trial Standard Level 

1 2 3 4 5 

Cumulative Total Emission Reductions** 

CO2 (Million metric tons) 86,206 -2.36 -2.39 -5.07 -5.66 -6.11 

NOX (Thousand tons) 60,796 -1.43 -1.45 -3.04 -3.39 -3.66 

Hg (tons) 519 -0.0002 -0.0002 -0.0003 -0.0004 -0.0004 

Cumulative Power Sector Emission Reductions** 

CO2 (Million metric tons) 86,206 -0.82 -0.84 -1.83 -2.05 -2.22 

NOX (Thousand tons) 60,796 0.22 0.22 0.48 0.54 0.59 

Hg (tons) 519 -0.0002 -0.0002 -0.0003 -0.0004 -0.0004 

Cumulative Building Emission Reductions** 

CO2 (Million metric tons) - -1.53 -1.56 -3.24 -3.61 -3.89 

NOX (Thousand tons) - -1.21 -1.23 -2.56 -2.85 -3.08 

Fuel-Cycle (Upstream) Emissions NA *** *** *** *** *** 

Wetlands, Endangered and Threatened Species, Cultural Resources** 

Wastewater Discharge Impact (billion gal) - -0.4 -5 -141 -161 -206 

Socioeconomic Impacts - Mean LCC Savings† 

Top-Loading Multi-Family Application 

All Consumers - -$8 -$8 $179 $179 $179 

Small Business Subgroup - -$22 -$22 $113 $113 $113 

No Municipal Water/Wastewater Subgroup - -$8 $8 $184 $184 $184 

Top-Loading Laundromat Application 

All Consumers - -$18 -$18 $190 $190 $190 

Small Business Subgroup - -$26 -$26 $141 $141 $141 

No Municipal Water/Wastewater Subgroup - -$18 -$18 $196 $196 $196 

Front-Loading Multi-Family Application 

All Consumers - $5 $19 $19 $91 $203 

Small Business Subgroup - $4 $15 $15 $69 $152 

No Municipal Water/Wastewater Subgroup - $5 $20 $20 $95 $210 

Front-Loading Multi-Family Application 

All Consumers - $5 $22 $22 $93 $216 

Small Business Subgroup - $4 $15 $15 $76 $176 

No Municipal Water/Wastewater Subgroup - $5 $22 $22 $96 $223 

Environmental Justice NA None None None None None 

Noise and Aesthetics NA None None None None None 

* The reference case values reflect total cumulative emissions in the absence of an energy standard. 

** Cumulative total is over a time period from 2013 to 2043. Negative values refer to emission/wastewater reductions. 

*** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 16.2.7 provides a sense 

for the possible magnitude of effects. 

† Values refer to life-cycle cost savings over the equipment lifetime. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Standards for Certain Consumer Products (Dishwashers, Dehumidifiers, 

Microwave Ovens, and Electric and Gas Kitchen Ranges and Ovens) and for Certain 

Commercial and Industrial Equipment (Commercial Clothes Washers); Final Rule. Federal 

Register, 2009. 74(66): pp. 16040-16096. 

2	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical 

Support Document: Energy Efficiency Program for Consumer Products and Commercial and 

Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and 

Commercial Clothes Washers, March, 2009. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_final_rul 

e_tsd.html> 

3	 U.S. Environmental Protection Agency, How Sulfur Dioxide Affects the Way We Live 

(Updated June 29st, 2009) http://www.epa.gov/oar/urbanair/so2/ 

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of NOx (Posted July 31st, 2009) <http:// www.epa.gov/air/nitrogenoxides/> 

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<http://www.epa.gov/climatechange/emissions/usinventoryreport.html> 

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SIP Call, Final Rule, May 12, 2005, 2005. 

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and Vulnerability. <http://www.ipcc-wg2.gov> 

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Climate Change 2007: The Physical Science Basis, 2007. Geneva. <http://ipccwg1.ucar.edu/wg1/docs/WG1AR4_SPM_PlenaryApproved.pdf> 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

11	 Intergovernmental Panel On Climate Change, IPCC Special Report on Land Use, Land-Use 

Change And Forestry, 2000. 

<http://www.grida.no/publications/other/ipcc_sr/?src=/Climate/ipcc/land_use/index.htm> 

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13	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

14	 U.S. Environmental Protection Agency, Emissions, Compliance, and Market Data | Acid 

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15	 U.S. Environmental Protection Agency, Emission Inventory Improvement Program, 

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<http://www.epa.gov/ttn/chief/eiip/techreport/volume03/> 

16	 American Gas Association, Source Energy and Emission Factors for Residential Energy 

Consumption, 2000. Washington, DC. August. 

<http://www.aga.org/NR/rdonlyres/F17F15FC-FC7D-4469-B8E2­

14F26FFAC440/0/0008ENERGYEMISSIONFACTORSRESCONSUMPTION.pdf> 

17	 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. 

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