i ANALYSIS OF EMISSION S REDUCTIONS FROM

PROPOSED EXCLUSION O F DECORATIVE HEARTH PR ODUCTS

TABLE OF CONTENTS

1.1 INTRODUCTION

................................ ................................ ................................ ............... 1

1.1.1 Alternatives

................................ ................................ ................................ .......................... 2

1.1.2 Analytical Methods for Air Emissions

................................ ................................ ................ 2

1.1.3 Effects on Household Emissions

................................ ................................ ......................... 2

LIST OF TABLES

Table 1.1.1 Alternative 1 (No Action)

– Emissions impacts from April 2010 Final Rule, including standards for Decorative Hearth Products, as Compared to

AEO 2010 Reference Case

................................ ................................ ...................... 3

Table 1.1.2 Alternative 2 (Action Alternative)

-- Household Emissions Impacts for Hearth Products and Gas Logs Without Continuous Pilot Light or Other Source of Continuous Ignition as Compared to April 2010 Final Rule

.................. 31 1.1 INTRODUCTION

This NOPR is closely related to standards set forth in an earlier DOE rule, namely DOE’s April 16, 2010, Final Rule, Energy Conservation Standards for Residential Water Heaters, Direct Heating Equipment, and Pool Heathers. 75 FR 201112 (April 2010 Final Rule). In that

rule , DOE inter alia established exclusio ns for certain vented heating products (explicitly) and vented gas log sets (through a subsequent interpretation). The parts of this NOPR that might have an impact on the human environment do not establish new energy efficiency standards. Rather they rev ise the exclusion for certain decorative hearth products from the applicable energy conservation standards for “vented hearth heaters” in the April 2010 Final Rule. As one of the criteria to qualify for the exclusion, a decorative hearth heater is not per mitted to have a pilot light or other continuously

- burning ignition source. It is the elimination of these components that would result in additional reductions in energy consumption as compared to the reductions resulting from the April 2010 Final Rule. Decorative hearth products that qualify for the exclusion actually emit lower levels of air pollutants than products that precisely meet the existing standards.

Pursuant to the National E nvironmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et

seq. )

, the U.S. Department of Energy ( DOE ) prepared a n E nvironmental A ssessment (EA) of the potential impacts of the energy conservation st andards for h eating products in the April 2010

Final Rule. DOE included the EA as c hapter 16 of the technical support document ( TSD ) for the April 2010 Final Rule

. DOE found that the environmental effects associated with the energy conservation standards for heating products were not significant. Therefore, DOE issued a Finding of No Significant Impact (FONSI), pursuant to NEPA, the regulations of the Counc il on Environmental Quality (40 CFR parts 1500

– 1508), and DOE’ s regul ations for compliance with

NEPA ( 10 CFR part 1021). The FONSI is a vailable at DOE’s NEPA web

- site

. See http://nepa.energy.gov/documents/EA

- 1774FONSI.pdf (March 22, 2010)

.

Nothing in the instant Notice of Proposed Rulemaking (NOPR or Proposed Rule ) alters

DOE’s FONSI for the April 2010 Final Rule

. This proposed rule would have beneficial impacts on the environment, but these impacts are a fraction of those resulting from the April 2010 Final

Rule. To avoid redundancy, DOE does not here repeat qualitative information about pollutant impacts, relevan t EPA regulations

, and background information already set forth in the EA for

the April 2010 Final Rule. For that analysis, please refer to Chapter 16 of the TSD for the April

2010 Final Rule. See http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/htgp_finalrule_ch1 6.pdf (April 16, 2010). DOE’s limited purpose here is to identify additional emissions

reductions that DO E anticipates would result from the rule proposed in the NOPR

. Based on DOE’s review of these emissions reductions, DOE believes that the resulting, additional,

beneficial impacts are so insignificant that the EA for the April 2010 Final Rule adequately

a ddresses the environmental impacts from the P roposed R ule.2 1.1.1 Alternatives

DOE does not here restate or reconsider the Trial Standard Levels for heating products and associated emissions reductions that DOE analyzed in the April 2010 Final Rule. That is because this NOPR is limited to proposing an exclusion from the particular standard (TSL 2 ) that DOE adopted in the April 2010 Final Rule. Th us, the alternatives consi dered here are (1) a No

Action A lternative, which assumes that heating products, including decorative hearth heaters, are subject to the April 2010 Final Rule; and (2) an Action Alternative, which assumes that all

manufacturers of decorative hearth heaters are granted an exclusion from the standards set forth

in the April 2010 Final Rule.

1.1.2 Analytical Methods for Air Emissions

The operation of hearth products requires use of fossil fuels and results in emissions of

carbon diox ide ( CO 2 ) and nitrogen oxides ( NO X ) at the sites where these appliances are used. Therefore, DOE calculated the effect of the performance measure on the above site emissions

based on emissions factors derived from the literature. The emissions factors us ed are 50.6

- 68.6 kg/ Gigajoule ( GJ ) for CO 2 and 40

- 66 g/GJ for NO X

. For a more detailed discussion of how DOE

calculates on

- site emissions of CO2 and NOx, please refer to the EA for the April 2010 Final

Rule. EA at 16

- 13, 16

- 14.

1.1.3 Effects on Household Emissions

U nlike some of the other products subject to the April 2010 Final Rule, decorative hearth products use natural gas, not electricity, as an energy source. As such, they do not indirectly affect emissions from electric generating units (EGUs). Ra ther, their impacts on the

environment result from direct emissions of CO 2 and NO X at the site of the product within the

household.

Table 1. 1

. 1 shows the total emission s reductions from all heating products under the April 2010 Final Rule ( No Action Alter native ). Table 1.1.2 shows the additional emissions

reductions that would result when residential hearth products and gas logs that lack standing pilot lights or other continuously

- burning ignition sources are excluded from the April 2010 Final

Rule (Act ion Alternative)

. The table s display changes in CO 2 and NO X in sel ected years. There

are no S O 2 emissions impacts because the savings only come from natural gas , combustion of

which does not release S O 2

. “Mt” refers to million metric tons

.3 Table 1.1.1 Alternative 1 (No Action)

– Emissions I mpacts from April 2010 Final Rule, I ncluding S tandards for Decorative Hearth Products, as C ompared

to AEO 2010 Reference Case

Reference 2010 2015 2020 2025 2030 2035 2040 2044 Total

2013

- 2044 2010 Heating Products difference from AEO2010 Reference Case

CO 2 (million metric tons) 0 0.738

- 3.193

- 6.07

- 6.957

- 6.957

- 6.957

- 6.57

- 163.8

NO X (thousand tons) 0 0.565

- 2.513

- 4.67

- 5.272

- 5.272

- 5.272

- 4.915

- 125

Hg (tons) 0

- 0.023

- 0.087

- 0.146

- 0.148

- 0.148

- 0.148

- 0.135

- 3.91

Table 1.1.2 Alternative 2 (Action Alternative)

-- Household Emissions Impact s for Hearth Products and Gas Logs Without Continuous Pilot Light or Other Source of Continuous Ignition as C ompared to 2010 Heating Products

Final Rule

Additional Reductions Compared to April 2010 Final Rule

Reference 2010 2015 2020 2025 2030 2035 2040 2043 Total

2013

- 2043

CO 2 (million metric tons) 0

- 0.012

- 0.098

- 0.179

- 0.227

- 0.216

- 0.216

- 0.216

- 4.95

NO X (thousand tons) 0

- 0.009

- 0.077

- 0.142

- 0.180

- 0.171

- 0.171

- 0.171

- 3.91

Notes: 1) The negative values represent emissions decrease in emissions. 2) With respect to Table 1.1.1 Cumulative total is over 2015 to 204 4 for water heater s; cumulative total is over 2013

to 2042 for direct heating equipment and pool heaters. 3) The AEO 2010 forecast ends in 2035. To be consistent, household emission impacts past 2035 are also assumed
to be equal to the impacts in 2035

.