CHAPTER 16. ENVIRO NMENTAL 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 (SO 2 )

.................................................................................... 16-2 16.2.1.2 Nitrogen Oxides (NOx)

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

........................................................................................................ 16-3 16.2.1.4 Carbon Dioxide (CO 2 )

................................................................................. 16-3 16.2.1.5 Particulate Matter

......................................................................................... 16-4 16.2.2 Air Quality Regulation

.................................................................................................. . 16-5 16.2.3 Global Climate Change

.................................................................................................. 1 6-6 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 CO 2 Concentrations

............................................................ 16-7 16.2.3.4 The Beneficial Impact of the Rule on CO 2 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 Clot hes Washer Efficiency Standards on Cumulative Energy-Related Emissions of CO 2 between 2013-2043 by Trial Standard Level (Million Metric Tons of CO 2 )

.......................................... 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 Cl othes Washers

............ 16-13 Table 16.2.5 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct Power Plant Combustion Emissions

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

16-iTable 16.3.1 Top-Loading Commercial Clothe s Washers: Per-Cycle Water Use and Water Discharge Savings by TSL

.................................................................... 16-15 Table 16.3.2 Front-Loading Comm ercial Clothes Washers: Per-Cycle Water Use and Water Discharge Savings by TSL

.................................................................... 16-16 Table 16.3.3 Summary of National Wastewat er 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 Sa vings 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

16-iiCHAPTER 16. ENVIRONMENTAL ASSESSMENT

16.1 INTRODUCTION
This chapter describes potential environmen tal 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 ar e 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 leve ls (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 ener gy savings can be found in the national impact analysis in Chapter 11 of this technical suppor t document (TSD). Detailed discussion on TSLs can be found in Chapter 9 of this TSD.

The primary impact of the TSLs is in air quality resulting from changes in power plant operations and capacity additions. Therefore, mu ch of this chapter describes the air quality analysis. The latter part of the chapter desc ribes potential impacts to other environmental

resources.
This chapter presents information and result s pertaining solely to CCWs. As described in section 1.3 of chapter 1 of this technical s upport document (TSD), DOE is continuing the rulemaking for energy conservation standards fo r microwave oven standby power, and analyses related to these products will be published in a separate TSD. In addition, DOE issued a final rule 1 adopting energy conservation standard s 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 co rresponding final rule TSD. 2

16.2 AIR EMISSIONS ANALYSIS
The primary focus of the environmental analys is 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 qu antities of electricity generated under each of the alternatives. Cha nges in generation are described in the utility impact analysis in Chapter 14.

16.2.1 Air Emissions Descriptions
For each of the TSLs, DOE calculated total power-sector emissions based on output from NEMS-BT model (see Chapter 14). This analysis considers three pollutant s: nitrogen oxides

16-1(NO x ), mercury (Hg), and sulfur dioxide (SO 2 ). An air pollutant is a ny substance in the air that can cause harm to humans or the environment. Pollutants may be natural or man-made (i.e., anthropogenic) and may take the form of solid part icles (i.e., particulates or particulate matter), liquid droplets, or gases a . This analysis also considers carbon dioxide (CO 2 ).

16.2.1.1 Sulfur Dioxide (SO 2 )
Sulfur dioxide, or SO 2 , belongs to the family of sulfur oxide gases (SOx). These gases dissolve easily in water. Sulfur is prevalent in al l raw materials, including crude oil, coal, and ore that contains common metals like alum inum, copper, zinc, lead, and iron. SO x 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. SO 2 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 SO 2 emissions from affected Electric Generating Units (EGUs) are subject to nationwide and regi onal emissions cap and trading programs that create uncertainty about standard’s impact on SO 2 emissions. Title IV of the Clean Air Act sets an annual emissions cap on SO 2 for all affected EGUs. SO 2 emissions from 28 eastern States and the District of Columbia (D.C.) are also li mited under the Clean Air In terstate 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 gr adually replace the Titl e IV program in those States and D.C.. (The recent legal history surr ounding 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 SO 2 emissions that offset some or all SO 2 emissions reductions attributable to the standard. DOE is not certain that there will be reduced overall SO 2 emissions from the standards. The NEMS-BT modeling system th at DOE plans to use to forecast emissions reductions currently indicates that no physical re ductions in power sector emissions would occur for SO 2 . However, remaining uncertainty prevents DOE from estimating SO 2 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 fr om 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 allowa nce credits, and thereby decrease the costs of complying with regulatory caps on emissions.

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

16-216.2.1.2 Nitrogen Oxides (NO x )
Nitrogen oxides , or NO x , are the generic term for a group of highly reactive gases, all of which contain nitrogen and oxygen in varying amounts. Many of the nitrogen oxides are colorless and odorless. However, one common pollutant, nitrogen dioxide (NO 2 ), along with particles in the air can often be seen as a reddish-brown la yer over many urban areas. NO 2 is the specific form of NOx reported in this document. NO x is one of the main ingredients involved in the formation of ground-level ozone, which can tr igger serious respiratory problems. It can contribute to the formation of acid rain, and can impair visibility in areas such as national parks. NO x also contributes to the fo rmation of fine particles that can impair human health. 4

Nitrogen oxides form when fossil fuel is bur ned at high temperatures, as in a combustion process. The primary manmade sources of NO x are motor vehicles, electric utilities, and other industrial, commercial, and residentia l sources that burn fossil fuels. NO x can also be formed naturally. Electric utilities acc ount for about 22 percent of NO x emissions in the United States.

16.2.1.3 Mercury
Coal-fired power plants emit Hg found in co al during the burning pr ocess. While coalfired power plants are the largest remaining s ource of human-generated Hg emissions in the United States, they contribute very little to th e global Hg pool or to contamination of U.S. waters. U.S. coal-fired power plants emit Hg in three different forms: oxidized Hg (likely to deposit within the United States); elemental H g, which can travel thousands of miles before depositing to land and water; and Hg that is in particulate form. Atmospheric Hg is then deposited on land, lakes, rivers, and estuarie s through rain, snow, and dry deposition. Once there, it can transform into methylmercur y and accumulate in fish tissue through bioaccumulation.

Americans are exposed to methylmercury pr imarily by eating contaminated fish. Because the developing fetus is the most sensitive to the toxic effects of methylmercury, women of childbearing age are regarded as the population of greatest concern. Children exposed to methylmercury before birth may be at increased risk of poor performa nce on neurobehavioral tasks, such as those measuring attention, fine motor function, language skills, visual-spatial abilities, and verbal memory.

16.2.1.4 Carbon Dioxide (CO 2 )
Carbon dioxide (CO 2 ) is not a criteria pollutant (see belo w), but it is of interest because of its classification as a greenhous e gas (GHG). GHGs trap the sun’ s radiation inside the Earth’s atmosphere and either occur na turally in the atmosphere or result from human activities. Naturally occurring GHGs include water vapor, CO 2 , methane (CH 4 ), nitrous oxide (N 2 O), and ozone (O 3 ). Human activities, however, add to the leve ls of most of these naturally occurring gases. For example, CO 2 is emitted to the atmosphere when solid waste, fossil fuels (oil, natural gas, and coal), wood, and wood products are burne d. During the past 20 years, about threequarters of anthropogenic (i.e., human-made) CO 2 emissions resulted from burning fossil fuels. 5

16-3Concentrations of CO 2 in the atmosphere are naturally regulated by numerous processes, collectively known as the “carbon cycle.” The m ovement of carbon between the atmosphere and the land and oceans is dominated by natural processe s, such as plant photosynthesis. While these natural processes can absorb some of the anthropogenic CO 2 emissions produced each year, billions of metric tons are added to th e atmosphere annually. In the U. S., CO 2 emissions from both energy generation and industr ial processes account for 8 4.6 percent of total U.S. GHG emissions. 5

16.2.1.5 Particulate Matter
Particulate matter (PM) also known as pa rticle pollution, is a complex mixture of extremely small particles and liquid droplets. Pa rticle pollution is made up of a number of components, including acids (such as nitrates an d sulfates), organic chemicals, metals, and soil or dust particles.

PM impacts are of concern due to human e xposures that can impact health. Particle pollution - especially fine particles - contains microscopic solids or liqui d droplets that are so small that they can get deep into the lungs and cause serious health problems. Numerous scientific studies have linked particle polluti on exposure to a variety of problems, including: increased respiratory symptoms, such as irrita tion of the airways, coughing, or difficulty breathing, for example; decreased lung function; aggravated asthma; de velopment of chronic bronchitis; irregular heartbeat; nonfat al 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 SO 2 and NO x 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 difficu lt to estimate than other emissions reductions. This is due to the complex interactions betw een PM, other power plan t emissions, meteorology and atmospheric chemistry that impact human e xposure to particulates. Human exposure to PM usually occurs at a significant distance from th e power plants that are emitting particulates and particulate precursors. When power plant emi ssions travel this distance they undergo highly complex atmospheric chemical reactions a nd the proportion of impacts and exposures attributable to different emissions can vary dramatically for different emissions sources and types of particulate precursors. Thes e variations in emissions impact s 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

16-4classified into seven categories: (1) Secondary sulfate/coal, (2) Secondary organic matter/mobile sources, (3) Nitrate dominated sour ces, (4) Biomass burning, (5) Indus trial, (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 SO 2 emissions from these power plants. This is because both SO 2 and direct PM emissions aggregate and interact with water droplets and emissions from other sources to create final particulates that ar e a complex mixture of different constituents. Both the SO 2 and direct PM are emitted from th e power plant at the same time and if the final aerosol particle contains both su lfur 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 co mmon pollutants (also referred to as “criteria” pollutant s), two of which are SO 2 and NO x . Also, the Clean Air Act Amendments of 1990 gave EPA the authority to control acidificat ion and to require operators of electric power plants to reduce emissions of SO 2 and NO x . Title IV of the 1990 amendments established a capand-trade program for SO 2 intended to help control acid rain. 3 This cap-and-trade program serves as a model for more recen t 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 SO 2 and NOx in eastern States of the United St ates. CAIR achieves large reductions of SO 2 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 partic ipate in an EPA-administered interstate cap-and-trade system th at caps emissions in two stages, or 2) meet an individual state emissions budget through measures of th e state’s choosing. Phase 1 caps for NO x are to be in place in 2009. Phase 1 caps for SO 2 are to be in place in 2010. The Phase 2 caps for both pollutants are due in 2015.

Also in 2005, EPA issued the final rule en titled “Standards of Performance for New and Existing Stationary Sources: Electric Steam Ge nerating Units,” under sections 110 and 111 of the Clean Air Act (40 CFR Parts 60, 63, 72, and 75). 8 This rule, also called the Clean Air Mercury Rule (CAMR), was closely related to the CAIR and estab lished standards of performance for Hg emissions from new and existing coal-fired electric utility steam generating units. The CAMR regulated Hg emissions from coal-fired power plants.

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

16-5On February 8, 2008, the U.S. Court of App eals for the District of Columbia Circuit (D.C. Circuit) issued its deci sion in State of New Jersey, et al. v. Environmental Protection Agency

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

On July 11, 2008, the U.S. Court of Appeals fo r the District of Columbia Circuit (D.C. Circuit) issued its decision in North Carolina v. Environmental Protection Agency

, which vacated the CAIR issued by the U.S. Envi ronmental Protection Agency on March 10, 2005. d CAIR was the 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 gl obal concern because it is expected to have widespread, adverse effects on natural resour ces and systems. A growing body of evidence points to anthropogenic sources of gree nhouse gases, such as carbon dioxide (CO 2 ), as major contributors to climate change. Because this Rule, if finalized, will likely decrease CO 2 emission rates from the fossil fuel sector in the United St ates, the Department here examines the impacts and causes of climate change and then the potential impact of the Rule on CO 2 emissions and global warming.

16.2.3.1 Impacts of Climate Change on the Environment
Climate is usually defined as the average we ather, over a period ranging from months to many years. Climate change refers to a change in the state of the climate, which is identifiable through changes in the mean and/or the variabil ity of its properties (e.g., temperature or precipitation) over an extended peri od, typically decades or longer. 9

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

e See id. at 903.

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

16-6wind patterns that affect extra-tropical storm tracks and temperature patterns, increases in intense precipitation in some parts of the world, as well as increased drought a nd more frequent heat waves in many locations worldwide, and numerous ecological changes. 10

Looking forward, the IPCC describes con tinued global warming of about 0.2°C per decade for the next two decades under a wide range of emission scenarios for carbon dioxide (CO 2 ), other greenhouse gases (GHG)s, and aerosols. After that period, the ra te of increase is less certain. The IPCC Report describes increases in average global temperatures of about 1.1°C to 6.4°C at the end of the century relative to t oday. These increases vary depending on the model and emissions scenarios. 9

The IPCC Report describes incremental impacts a ssociated with the rise in temperature. At ranges of incremental increases to the global average temperature, IPCC reports, with either high or very high confidence, that there is likely to be an increas ing degree of impacts such as coral reef bleaching, loss of wild life habitat, loss to specific ecosystems, and negative yield impacts for major cereal crops in the tropics, but al so projects that there likely will be some beneficial impacts on crop yields in temperate regions.

16.2.3.2 Causes of Climate Change
The IPCC Report states that the world has wa rmed by about 0.74°C in the last 100 years. The IPCC Report finds that most of the temperat ure increase since the mi d-20th century is very likely due to the increase in anth ropogenic concentrations of CO 2 and other long-lived greenhouse gases (GHGs) such as methane and nitrous oxide in the atmosphere, rather than from natural causes.

Increasing the CO 2 concentration partially blocks the earth’s re-radiation of captured solar energy in the infrared band, inhibits the radiant cooling of the earth, and ther eby alters the energy balance of the planet, which gradually increases its average temperature. The IPCC Report estimates that currently, CO 2 makes up about 77% of the total CO 2 -equivalent g global warming potential in GHGs emitted from human activit ies, with the vast ma jority (74%) of the CO 2 attributable to fossil fuel use. For the fu ture, the IPCC Report describes a wide range of GHG emissions scenarios, but under each scenario CO 2 would continue to comprise above 70% of the total global warming potential. 9

16.2.3.3 Stabilization of CO 2 Concentrations
Unlike many traditional air pollutants, CO 2 mixes thoroughly in the entire atmosphere and is long-lived. Th e residence time of CO 2 in the atmosphere is long compared to the emission

g GHGs differ in their warming influence (radiative forci ng) on a global climate syst em due to their different radiative properties and lifetimes in the atmosphere. These warming influences may be expressed through a common metric based on the radiative forcing of CO 2 , i.e., CO 2 -equivalent. CO 2 equivalent emission is the amount of CO 2 emission that would cause the same- time integrated radiative forcing, over a given time horizon, as an emitted amount of other long- lived GHG or mixture of GHGs.

16-7processes. Therefore, the gl obal cumulative emissions of CO 2 over long periods determine CO 2 concentrations because it takes hundreds of y ears for natural processes to remove the CO 2
. Globally, 49 billion metric tons of CO 2 –equivalent of anthropogenic (man-made) greenhouse gases are emitted every year. Of this annual total, fossil fuels contribute about 29 billion metric tons of CO 2
. 11 h

Researchers have focused on considering atmospheric CO 2 concentrations that likely will result in some level of globa l climate stabilization, and the emission rates associated with achieving the “stabilizing” concentrations by partic ular dates. They associate these stabilized CO 2 concentrations with temperature increases that plateau in a defined range. For example, at the low end, the IPCC Report scenarios target CO 2 stabilized concentrations range between 350 ppm and 400 ppm (essentially today’s value)—because of climate inertia, concentrations in this low end range would still result in temperatures projected to increase 2.0°C to 2.4°C above preindustrial levels i (about 1.3°C to 1.7°C above today’s leve ls). To achieve concentrations between 350 ppm to 400 ppm, the IPCC scenarios pr esent that there would have to be a rapid downward trend in total annual gl obal emissions of greenhouse gase s to levels that are 50% to 85% below today’s annual emission rates by no later than 2050. Since it is assumed that there would continue to be growth in global populations and substantial increases in economic production, the scenarios identify required re ductions in greenhouse gas emissions intensity (emissions per unit of output) of more than 90%. However, even at these rates, the scenarios describe some warming and some climate cha nge is projected due to already accumulated CO 2 and GHGs in the atmosphere. 12

16.2.3.4 The Beneficial Impact of the Rule on CO 2 Emissions
If finalized, it is anticipated thatthe Rule will reduce energy-related CO 2 emissions, particularly those associated with energy consum ption in buildings. In the United States, the U.S. Energy Information Administration (EIA) reports in its 2009 A nnual Energy Outlook, April Release ( AEO2009 ) 13 that U.S. annual energy-related emissions of CO 2 in 2007 were about 5.9 billion metric tons (about 20 perc ent of the world energy-related CO 2 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 (i ncluding 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-f ired power plants that generate electricity used in this sector. In the AEO2009 Reference Case, EIA projected that annual energy-related CO 2 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 CO 2 emissions from deforest ation and decay from agriculture biomass; agricultural and industrial emissions of methane; and emissions of nitrous oxide and fluorocarbons.

i IPCC Working Group 3 Table TS 2

16-8As shown in Table 16.2.2 in the AEO2009 Reference Case, the cumulative U.S. energyrelated power sector CO 2 emissions between 2013 and 2043 are described at about 79 billion metric tons. The estimated cumulative CO 2 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 indicate d in Table 16.2.1. Estimated CO 2 emission reductions in Table 16.2.1 come from two sources: electricity generati on (i.e., power plants) and fossil fuel-fired appliances. The estimated CO 2 emission reductions from electrici ty generation are calculated using the NEMS-BT model. The estimated CO 2 emission reductions from fossil fuel-fired appliances (i.e., commercial clothes washers) ar e derived from emissions factors for commercial natural gas combustion.

Table 16.2.1 Impact of Commercial Clothes Washer E fficiency Standards on Cumulative Energy-Related Emissions of CO 2 between 2013-2043 by Trial Standard Level (Million Metric Tons of CO 2 ) 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, equi valent 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 CO 2 (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. CO 2 emissions, as compared to U.S. CO 2 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 emissi on rates with atmospheri c concentrations of CO 2 and specific atmospheric concentrations with future temperatures because the IPCC Report describes a clear lag in the climate syst em between any given concentration of CO 2 (even if maintained for long periods) and the subsequent average worldwide and regional temperature, precipitation, and extreme weathe r regimes. For example, a major determinant of climate response is “equilibrium climate sensitivity”, a measure of the climate system response to sustained radioactive forcing. It is defined as the global average surface warming following a doubling of carbon dioxide concentrations. Th e IPCC Report describes its estimated, numeric value as about 3°C, but the likely range of that value is 2°C to 4.5°C, with cloud feedbacks the largest source of uncertainty. Further, as illustrated above, the IPCC Report scenarios for stabilization rates are presented in terms of a range of concentrations, which then correlates to a range of temperature changes. Thus, climate sensitivity is a key uncertainty for CO 2 mitigation scenarios that aim to meet sp ecific temperature levels.

16-9Because of how complex global climate systems ar e, it is difficult to know to what extent and when particular CO 2 emissions rates will impact glob al warming. However, as Table 16.2.1 indicates, the Rule will likely reduce CO 2 emissions rates from the fossil fuel sector.

16.2.4 Analytical Methods for Air Emissions
NEMS-BT incorporates capabilit ies to assess compliance with SO 2 restrictions specified in the Clean Air Act and its amendments. Clean air act provisi ons include New Source Performance Standards, and Re vised New Source Performance St andards. The version of NEMS-BT in 2008 also included provisions for the CAIR, which imposes stricter restrictions on SO 2 and NO X for some states, and the CAMR, which imposed a national Hg constraint. As discussed earlier is section 16.2.2, on 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 vaca ting the CAMR. Although the constraints on Hg in CAMR have sin ce been vacated by a court decision, the AEO2009 Reference Case assumes that emissions of Hg wo uld 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 signifi cantly affects the emissions produced, the model includes a detailed representation of coal suppl y. The model considers the rank of the coal as well as the sulfur contents of the fuel us ed when determining optimal dispatch.

Within the NEMS-BT model, pl anning options for achieving em issions restrictions in the Clean Air Act Amendments include installing pollution control equipment on existing power plants and building new power plants with lo w emission rates. These methods for reducing emission are compared to dispatching options su ch as fuel switching and allowance trading. Environmental regulations also a ffect capacity expansion decisions. For instance, new plants are not allocated SO 2 emissions allowances according to the Clean Air Act Amendments. Consequently, the decision to build a particular capacity type must consider the cost (if any) of obtaining sufficient allowances. This could invo lve purchasing allowances or over complying at an existing unit.

DOE’s initial analysis assumed the pr esence of nationwide emission caps on SO 2 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 fo recast emissions reduction indicated that no physical reductions in power sect or emissions would occur for SO 2 , 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 SO 2 emissions reductions will remain at the cap, during the years 2007 and 2008, SO 2 emissions have been below the trading
cap. 14 The difference between the emissions levels that NEMS-BT forecasts and those that EPA

16-10forecasts is an indicator of the uncertainties as sociated with long range energy sector forecasts. Because of such uncertainties, DOE is unable to estimate the economic and physical benefit from SO 2 emissions reductions at this time.

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

16.2.5 Effects on Power Plant Emissions
Table 16.2.2 shows reference power plant emi ssions in selected y ears 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
CO 2 (Million metric tons/year)** 2,39 7 2,343 2,381 2,466 2,535 2,636
NO X (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 pow er plant emissions in selected years for all the TSLs. Changes in NO X and Hg emissions from power plan ts are shown in these tables. Changes in CO 2 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.

16-11Table 16.2.3 Power Sector Emissions Impact Foreca sts 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 Imp acts Analysis (NIA) model because NEMS-BT does not account for these emissions at the site.

The emissions factors DOE used are derive d from what are reported in the AP-42 for residential water heaters because no explic it listing was provided for commercial clothes washers. However, the AP-42 sources does pr ovide a method for estimating the share of emissions from commercial clothes washers base d 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 co mbustion are small compared to other emissions

j The AP-42 source does not list an ap proach 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/tech report/volume03/ng.pdf).

16-12sources, it is not uncommon to see emissions factor s from residential end uses reported in one general rate. 16 k For these reasons, the Department opt ed 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 acknowle dging that these estimates are only general approximations.

Table 16.2.4 shows the estimated changes in bu ilding 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 am ount of energy used in the upstream production and downstream consumpti on of electricity, including energy used at the power plant. Upstream processes include the mining of coal or extraction of natural gas, physical preparatory and cleaning processes, and transportation to the power plant. The NEMSBT does a thorough accounting of emissions at the power plant due to downstream energy consumption, but does not account for upstream emissions (i.e., emissions from energy losses during coal and natural gas produc tion). Thus, this analysis re ports only power plant emissions.

k See section 3.2 of a AGA report.

16-13However, previous DOE environmental assessment documents have developed qualitative estimates of affects on upstream fuel -cycle emissions. These emissions factors provide the reader with a sense of the possible ma gnitude of upstream effects. These upstream emissions would be in addition to emissions from direct combustion. Relativ e to the entire fuel cycle, estimates based on the work of Dr. Mark DeLuchi, and reported in earlier DOE environmental assessment documents, find that an amount approximately equal to eight percent, by mass, of emissions (including SO 2 ) from coal production are due to mining, preparation that includes cleaning the coal, and transporta tion from the mine to the power plant. 17 Transportation emissions include emissions from the fuel used by the mode of transportati on that moves the coal from the mine to the power plant.

In addition, based on Dr. DeLu chi’s work, DOE estimated that approximately an amount equal to 14 percent of emissions from natural ga s production result from upstream processes. Emission factor estimates and corresponding percen tages of contributions of upstream emissions from coal and natural gas production, relative to power plant emissions, are shown in Table 16.2.5 for CO 2 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 CO 2 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 Ai r Pollutants as a Percentage of Direct Power Plant Combustion Emissions

Pollutant Percent of Coal Combustion Emissions Percent of Natural Gas Combustion Emissions
CO 2 2.7 11.9
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 in to the waste stream. As a result, commercial clothes washer energy efficiency standards have the effect of pot entially improving the quality of wetlands, and threatened or endange red species that reside in thes e wetlands. This action is not expected to impact cultural resources such as historical or ar chaeological 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 retent ion 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

16-14washers (both the RMC and water use were firs t 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 th e clothes load at the baseline efficiency level. The RMC decreases as a function of efficiency, thereby decreasi ng the amount of water retention in the clothes. But the amount of water use decr eases with clothes washer efficiency as well. Because the rate of water use sa vings grows at approximately doubl e the rate of water retention, the increased amount of water reta ined in the clothes as a percen tage of the water use savings drops from approximately two percent to one percent over the range of clothes washer efficiencies considered. Therefore, assuming th at water not retained in the clothes load is discharged into the wastewater stream, wastewat er discharge savings range from 98 to 99 percent of the water use savings at the baseline and ma x-tech levels, respectiv ely (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 clot hes 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 Was hers: 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 Extracti on. 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.

16-15Table 16.3.2 Front-Loading Commercial Clothes Was hers: 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 Extracti on. 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 disc harge reductions due to the trial standard levels for commercial clothes washers. For co mparison purposes, the national water savings due to the commercial clothes washer trial standard le vels 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 Chap ter 11, section 11.5.2 of this TSD.

Table 16.3.3 Summary of National Wastewater Di scharge Reductions and National Water Savings due to Commercial Clothes Washer Standards (Cumulative reductions for pro ducts 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 pur chasing 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 effici ent piece of equipment. In other words, the customer will pay less operating costs over the lif e 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 bu ilding owners without municipal water and wastewater that purchase commerc ial clothes washers, DOE determined that the average LCC impact is similar to that for the full sample of consumers. Therefore, DOE concludes that the

16-16proposed action would have no significant socioe conomic 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 fo r 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/Wastew ater 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 Febr uary 11, 1994, “Federal Actions to Address Environmental Justice in Minorit y Populations and Low-Income Populations,” DOE is required to examine the effect of more stringent energy -efficiency standards on (1 ) small businesses that either manufacture or use commercial clothes wa shers, (2) manufacturer s 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 conser vation standards. As described in the LifeCycle Cost Subgroup Analysis, Chapter 12 of the TSD, DOE found that there was no disproportionately high and advers e human health or environmental effects on small businesses

16-17that would result from the proposed energy cons ervation standards. DOE believes that above conclusion also applies to minority populations.

16.6 NOISE AND AESTHETICS
Improvements in efficiency of commercial cl othes washers is expect ed to result from changes in the choice of components and other de sign features. These changes are described in Chapter 5 of this TSD. These design changes are not expected to change noise levels in comparison to equipment in today’s market. Equi pment 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 environm ental 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 CO 2 , NOx, and Hg over the period 2013 to 2043. The resulting changes in emission quant ities are very small. Cumulative CO 2 , NO x , and Hg emissions show a decrease compared to the re ference case. Hg emissions show a very small increase in cumulative emissions. This incr ease may result from the combined effects of emissions banking, a shift in how power plants are dispatched, or the timi ng within the model of when power plants are replaced.

Upstream fuel cycle emission of CO 2 and NO x are described but not quantified in section 16.2.7. The text describes potential reductions in fuel cycle emissions as percentage of decreases in power plant emissions. This qualitative approa ch suggests that upstrea m fuel cycle emissions would decrease and provides a sense for the ma gnitude of effects, how ever DOE does not report actual estimates of the effects. This a pproach does not address Hg emissions.

Socioeconomic impacts are presented as changes in life cycle costs. No impacts are anticipated in the area of envir onmental justice; wetlands, enda ngered and threatened species, and cultural resources; or noise and aesthetics.

16-18Table 16.7.1 Environmental Impact Analysis Resu lts Summary for Commercial Clothes Washers

Environmental Effects Reference Case* Trial Standard Level 1 2 3 4 5 Cumulative Total Emission Reductions** CO 2 (Million metric tons) 86,206 -2.36 -2.39 -5.07 -5.66 -6.11 NO X (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** CO 2 (Million metric tons) 86,206 -0.82 -0.84 -1.83 -2.05 -2.22 NO X (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** CO 2 (Million metric tons)

- -1.53 -1.56 -3.24 -3.61 -3.89 NO X (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 em ission/wastewater reductions. *** DOE does not report actual estimates of the effects of standards on upstream em issions, but section 16.2.7 provides a sens e for the possible magnitude of effects. † Values refer to life-cycle cost savings over the equipment lifetime.

16-19REFERENCES

1 U.S. Department of Energy-Office of En ergy Efficiency and Re newable Energy, Energy Conservation Standards for Certain Consumer Products (Dishwashers, Dehumidifiers, Microwave Ovens, and Electric and Gas K itchen Ranges and Ovens) and for Certain Commercial and Industrial Equipment (Com mercial 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 Dishwa shers, Dehumidifiers, Cooking Products, and Commercial Clothes Washers , March, 2009. Washington, DC.

< http://www1.eere.energy.gov/buildings/appliance_standards/residentia l/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 /

4 U.S. Environmental Protection Agency, Nitrogen Oxides Health and Environmental Impacts of NOx (Posted July 31st, 2009) < http:// www.epa.gov/air/nitrogenoxides / >

5 U.S. Environmental Protection Agency, 2009 U.S. Greenhouse Gas Inventory Report , 2009.

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

6 U.S. Environmental Protection Agency, Compilation of Existing Studies on Source Apportionment for PM 2.5 , Emissions, Monitoring, and An alysis Division, Office of Air Quality Planning and Standards, U.S. EPA, Research Triangle Park, North Carolina 27711, August 22, 2003, 2003. < http://www.epa.gov/airtrends/specialstudies/compsareports.pdf >

7 U.S. Federal Register, Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NOX SIP Call, Final Rule, May 12, 2005, 2005.

8 U.S. Federal Register, Standards of Perfor mance for New and Existing Stationary Sources: Electric Utility Steam Generating Units, Fi nal Rule, May 18, 2005, 2005. Report No. 70 FR 28606.

9 Intergovernmental Panel On Climate Change, Climate Change 2007 – Impacts, Adaptation and Vulnerability . < http://www.ipcc-wg2.gov >

10 Intergovernmental Panel On Climate Ch ange, IPCC WGI Fourth Assessment Report: Climate Change 2007: The Physical Science Basis, 2007. Geneva. < http://ipccwg1.ucar.edu/wg1/docs/WG1AR4_SPM_PlenaryApproved.pdf >

16-2011 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 >

12 Intergovernmental Panel On Climate Change, IPCC Fourth Assessment Report Climate Change 2007: Working Group III Report "Mitigation of Climate Change" , 2007.

< http://www.ipcc.ch/pdf/assessmen t-report/ar4/wg3/ar4-wg3-ts.pdf >

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 Change s 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 Rain Program Program 2008 Progress Reports | Progress Reports | Clean Air Markets, 2009. < http://www.epa.gov/airmarkt/progress/ARP_1.html >

15 U.S. Environmental Protection Agency, Emission Inventory Improvement Program, Technical Report Series Volume 3, Area Sources . Washington, DC.

< 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

­ 14F26FFAC440/0/0008ENER GYEMISSIONFACTORSRE SCONSUMPTION.pdf >

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

16-21