DOE/EA-1344

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARDS FOR RESIDENTIAL

CLOTHES WASHERS

December 2000

U.S. Department of Energy

Assistant Secretary,

Energy Efficiency & Renewable Energy

Office of Building Research and Standards

Washington, DC 20585
ENVIRONMENTAL ASSESSMENT FOR RESIDENTIAL CLOTHES WASHERS

TABLE OF CONTENTS

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

2. PURPOSE AND NEED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-1

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

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

3.2 Proposed Standard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-2

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

3.4 Impacts of Proposed and Alternative Standards . . . . . . . . . . . . . . . . . . . . . . EA-3

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

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

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

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

4.2.2 Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-5

4.2.2.1 Carbon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-5

4.2.2.2 Power Sector NOx . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-6

4.2.2.3 Power Sector SO2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-6

4.2.2.4 Household NOx and SO2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-6

4.2.2.5 Fuel-Cycle Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-6

4.2.2.6 Interpolation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-7

4.2.2.7 Extrapolation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-7

4.3 Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-7

4.4 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-7

4.5 Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-8

4.6 Energy Consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-8

5. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION . . . . . . . . . . . . . EA-8

5.1 Air Quality / Emissions Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-8

5.1.1 Power Sector Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-8

5.1.2 Residential Sector Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-11

5.1.3 Power and Residential Sector Emissions . . . . . . . . . . . . . . . . . . . . . EA-14

5.1.4 Fuel-Cycle Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-15

5.1.5 High and Low Sensitivity Analysis for Air Emissions . . . . . . . . . . EA-15

5.2 Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-19

5.3 Wetlands / Endangered and Threatened Species / Cultural Resources . . . . EA-21

5.4 Socioeconomic Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-21

5.5 Environmental Justice Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-21

5.6 Energy Consumption Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-21

5.7 Summary of Environmental Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-22
APPENDIX EA-1 Emission Factors for Combustion from Natural Gas, LPG, and Oil 

Fired Residential Water Heaters and Clothes Dryers . . . . . . . . . . . EA.1-i

APPENDIX EA-2 Upstream Emission Factors from Coal and Natural Gas 

Production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA.2-i

APPENDIX EA-3 Interpolation of Utility and Environmental Results from NEMS-BRS

Output . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA.3-i

TABLES

Table 1 Summary of the Analysis Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-4

Table 2 Power Sector Emissions for all Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-9

Table 3 Cumulative Emissions Reductions through 2020: Power Sector . . . . . . . . EA-11

Table 4 Change in Annual Household Emissions for MEF Standards . . . . . . . . . . . EA-12

Table 5 Cumulative Emissions Reductions through 2020: Households . . . . . . . . . . EA-13

Table 6 Cumulative Emissions Reductions through 2020: Household and Power

Sectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-14

Table 7 Cumulative Emissions Reductions through 2030: Household and Power 

Sectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-14

Table 8 High and Low Economic Growth: Annual Power Sector Emissions for Proposed

Standard (Trial Standard Level 3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-16

Table 9 High and Low Price Elasticity Scenarios: Annual Power Sector Emissions for

Proposed Standard (Trial Standard Level 3) . . . . . . . . . . . . . . . . . . . . . . . . EA-17

Table 10 High and Low Economic Growth Change in Annual Household Emissions for 

Proposed Standard (Trial Standard Level 3) . . . . . . . . . . . . . . . . . . . . . . . . EA-18

Table 11 High and Low Price Elasticity: Change in Annual Household Emissions for 

Proposed Standard (Trial Standard Level 3) . . . . . . . . . . . . . . . . . . . . . . . . EA-18

Table 12 Cumulative Power Sector and Household Emission Reductions for High & Low

Economic Growth Sensitivities to 2030 . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-19

Table 13 Cumulative Power Sector and Household Emission Reductions with Elasticity

Sensitivities to 2030 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-19

Table 14 Cumulative Reduction in Water Use to 2030 . . . . . . . . . . . . . . . . . . . . . . . EA-20

Table 15 Cumulative Water Reduction for High & Low Economic Growth Sensitivities to

2030 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA-20

Table 16 Cumulative Water Reduction with Elasticity Sensitivities to 2030 . . . . . . . EA-20

Table 17 Cumulative Energy Savings for Proposed Standard (Trial Standard Level 3)EA-22
APPENDIX TABLES

Table EA-1.1 Estimated National Average Emission Factors for Household Fuel Combustion of

Natural Gas, Fuel Oil#2, and LPG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA.1-2

Table EA-2.1 Estimated Upstream Emission Factors and Relative Percentages to Direct Power

Plant Combustion Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA.2-2

APPENDIX FIGURES

Figure EA-3.1a An Example of the Interpolation of a Trial Standard Level: Difference in 

 Coal Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EA.3-4

Figure EA-3.1b Close-Up of the Interpolation of Trial Standard Level X2 from X1 . . . . . EA.3-5

Figure EA-3.2 Example of Trial Standard Level X1: Marginal NOx Emissions . . . . . . . EA.3-6
ABBREVIATIONS AND ACRONYMS

Act or EPCA: Part B of Title III of the Energy Policy and Conservation Act, Public Law 94-163,

as amended by the National Energy Conservation Policy Act, Public Law 95-619, the National

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

Conservation Amendments of 1988, Public Law 100-357, and the Energy Policy Act of 1992, Public

Law 102-486

AEO: Annual Energy Outlook, DOE/EIA publication

BRS: DOE’s Building Research and Standards office

BTU: British Thermal Unit

C: carbon

DOE: Department of Energy

EA: Environmental Assessment 

EF: Energy Factor

EIA: Energy Information Administration

EJ: exajoule (1018 joules)

EPCA: Energy Policy and Conservation Act

GJ: gigajoule (109

 joules)

kt/a: thousand metric tons per year

kWh: kilowatt-hour

LCC: Life-Cycle Cost

LPG: liquified petroleum gas 

MEF: Modified Energy Factor (cu. ft. / kWh per cycle)

Mt/a: millions of metric tons per year

NAECA: National Appliance Energy Conservation Act 

NEMS: National Energy Modeling System
NEPA: National Environmental Policy Act of 1969

NES: National Energy Savings 

NOPR: Notice of Proposed Rulemaking

NOx: nitrogen oxides

PBP: Payback period

Quad: quadrillion Btu

RIA: Regulatory Impact Analysis

SO2: sulfur dioxide

t: metric ton

TSL: Trial Standard Level

TSD: Technical Support Document

TWh: terawatt-hour

U.S.C.: United States Code
 a

Part B of Title III of the Energy Policy and Conservation Act, as amended by the National Energy Conservation Policy Act,

the National Appliance Energy Conservation Act, the National Appliance Energy Conservation Amendments of 1988, and the

Energy Policy Act of 1992, is referred to in this notice as the "Act." Part B of Title III is codified at 42 U.S.C. 6291 et seq. Part

B of Title III of the Energy Policy and Conservation Act, as amended by the National Energy Conservation Policy Act only, is

referred to in this notice as the National Energy Conservation Policy Act.

EA-1

1.0 INTRODUCTION

The U.S. Department of Energy (DOE) prepared this clothes washer environmental

assessment (EA) pursuant to the National Environmental Policy Act of 1969 (NEPA)(42 U.S.C.

4321 et seq.), the regulations of the Council on Environmental Quality (40 CFR Parts 1500-1508),

and the Department of Energy’s regulations for compliance with NEPA (10 CFR Part 1021).

On November 14, 1994, DOE published an Advance Notice of Proposed Rulemaking

(ANOPR). 59 FR 56423. On November 19, 1998, DOE published a Supplemental ANOPR 

(Hereafter referred to as the 1998 Supplemental ANOPR.). 63 FR 64344. On October 5, 2000, DOE

published a Notice of Proposed Rulemaking (NOPR or proposed rule) for energy efficiency

standards. 65 FR 59550. For the NOPR, we analyzed the energy savings, benefits and burdens of

amended energy conservation standards for clothes washers and shared the results of these analyses

with all stakeholders. Based on these analyses, several of the major stakeholders, including clothes

washer manufacturers and energy efficiency advocates, submitted to the Department a joint proposal

for the highest standard level which they believed to be technically feasible and economically

justified. (Hereafter referred as the Joint Comment). Based on our review of the Joint Comment,

we found the proposed standards technically feasible and economically justified. Therefore, the

Department is adopting the energy conservation standards for clothes washers at Trial Standard

Level (TSL) 3 (The clothes washer energy standards for Top Loading, Standard (1.6 ft.3

 or greater

capacity) and Front Loading class clothes washers shall be 1.04 modified energy factor (MEF) in

1/1/2004 and 1.26 MEF in 1/1/2007.).

DOE proposed the clothes washer efficiency standards pursuant to Part B of Title III of the

Energy Policy and Conservation Act, Public Law (P.L.) 94-163, as amended by the National Energy

Conservation Policy Act, P.L. 95-619, by the National Appliance Energy Conservation Act, P.L.

100-12, by the National Appliance Energy Conservation Amendments of 1988, P.L. 100-357, and

the Energy Policy Act of 1992, P.L. 102-486a (the Act or EPCA), which created the Energy

Conservation Program for Consumer Products other than Automobiles. 

The proposed clothes washer efficiency standard affects consumers and manufacturers of

residential clothes washers.

2.0 PURPOSE AND NEED

The Energy Policy and Conservation Act, as amended, specifies that the Department must

consider, for new or amended conservation standards, those standards that “achieve the maximum
EA-2

improvement in energy efficiency which the Secretary determines is technologically feasible and

economically justified” and which will “result in significant conservation of energy.” Accordingly,

DOE’s proposed rule would be amending the energy conservation standard for residential clothes

washers. 

Consistent with this requirement, DOE’s purpose in the proposed action is to reduce the

consumption of energy used by clothes washers in the United States (U.S.). DOE’s discretion is in

deciding the level for a minimum efficiency standard, not if there should be one.

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION

A DOE clothes washer standard analysis includes the energy saved by the clothes washer

itself (always electrical), the energy used in an electric, gas, LPG or oil-fired water heater to heat

water for the clothes washer, and the energy required by a clothes dryer (electric, gas or LPG) to

remove the water remaining in laundry after a completed wash cycle. The metric used to measure

the efficiency is called the Modified Efficiency Factor (MEF). Details are provided in the Clothes

Washer Technical Support Document (TSD).1 

After an initial analysis of ten different efficiency levels, the analysis was reduced to six

possible TSLs. Of these, DOE proposes to set a clothes washer standard at TSL 3.

3.1 No Action Alternative

Under this alternative DOE would not publish a new minimum energy efficiency standard

for clothes washers. By taking no action, DOE would be in violation of EPCA, which requires (1)

DOE to determine whether to amend the statutory standard, and (2) that a minimum standard be set

at a level that "shall be designed to achieve the maximum improvement in energy efficiency that the

Secretary determines is technologically feasible and economically justified." EPCA, §325(l)(2)(A),

42 U.S.C. §6295(l)(2)(A). In addition to analyzing a baseline case in the TSD, a Draft Clothes

Washer Regulatory Impact Analysis (RIA) was published that examines the no action alternative as

well as other non-mandatory efficiency standards or voluntary incentive programs. It was

determined in this report that the “no action” alternative would result in less energy reductions than

the proposed standard. If “no action” were taken, the minimum efficiency requirement would remain

at its current level, an Energy Factor (EF) of 1.18. Unlike the proposed MEF, the EF does not

account for energy use in the clothes dryer. The current baseline value for EF corresponds to an

MEF of 0.817 kWh/cycle, a lower minimum efficiency level than any other level being considered.

3.2 Proposed Standard

The major stakeholders, including manufacturers and energy efficiency advocates, have

jointly submitted a proposed clothes washer efficiency standard to DOE that they feel is technically

feasible and economically justified. This proposed clothes washer efficiency standard will provide

significant energy savings and water savings to the nation. The proposed standard (TSL 3) would
EA-3

go into effect in two stages, with a lower required improved efficiency (MEF of 1.04) by the year

2004 and a higher efficiency level (MEF of 1.26) by the year 2007. Additional details of the

proposed TSL 3 and other TSL’s are provided in the Clothes Washer TSD1

. The TSD is available

on a DOE internet site at http://www.eren.doe.gov/buildings/codes_standards/applbrf/clwasher.html.

The justification for selecting the proposed standard, TSL 3, over the other trial standard

levels considered is explained in Section V.F, conclusions of the October 5, 2000 Federal Register

Notice, page 59580. This Federal Register notice is also available on a DOE internet site at

http://www.eren.doe.gov/buildings/codes_standards/applbrf/clwasher.html under “Notice of

Proposed Rulemaking.”

3.3 Alternative Standards

This EA presents the results of the environmental impacts from six clotheswasher efficiency

trial standards. Each standard is an alternative action, and is compared against the no-action

alternative. In the course of a typical appliance rulemaking, all alternatives are initially considered.

To simplify the analysis for the final detailed selection process, some alternatives are eliminated

from further analysis. Of the ten beginning standard levels, six have been analyzed in detail in this

EA and four were eliminated from further analysis. Of the four eliminated, three trial standard levels

with MEF's of 0.86 (5% energy reduction), 0.908 (10% energy reduction) and 0.961 (15% energy

were eliminated from further consideration because it was determined that an MEF of 1.021 (20%

energy reduction) was technically feasible and economically justified, making further consideration

of the less efficient trial levels unnecessary. The fourth trial standard with a MEF of 1.485 (energy

reduction of 45%) was eliminated due to its significantly higher increase in clothes washer retail

price, life-cycle-cost and payback period. It is required that the maximum technically achievable

level, in this case MEF of 1.634 (representing reduced energy use of 50%), be retained as part of the

analysis. 

3.4 Impacts of Proposed and Alternative Standards

The NOPR established that DOE determined that significant energy savings could be

achieved through the adoption of an amended conservation standard for clothes washers. DOE

considers the impacts of standards beginning with the most efficient level. Table 1 includes a

summary of the analysis results to aid the reader in the discussion of the benefits and burdens for the

different trial standard levels. DOE proposes to set a clothes washer standard at TSL 3 which is felt

to be technically feasible and economically justified. Additional information on the six trial standard

levels is provided in Section 5 of this EA, Environmental Impacts of the Proposed Action. 
b

For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration

documentation. A useful summary is National Energy Modeling System: An Overview 1998, DOE/EIA-0581(98), February 1998. 

DOE/EIA approves use of the name NEMS to describe only an official version of the model without any modification to code or

data.

EA-4

Table 1.--Summary of the Analysis Results*

Trial Standard Level 6 5 4 3 2 1

MEF 1.63 1.36 1.26 1.04 in 2004,

1.26 in 2007

1.09 1.02

Percent Reduction in Energy

Use 

50 40 35 ~22 in 2004

~35 in 2007

25 20

Total Energy Saved (Quads) 7.53 6.03 5.99 5.52 4.04 2.12

Water Savings (trillion gallons) 10.85 12.94 12.94 11.59 9.09 0.53

Emissions

Carbon Equivalent (Mt) 134.6 107.3 106.2 95.1 70.9 38.1

NOx (kt) 364 283.1 280.6 253.5 193.6 115.6

SO2 (kt) 31.41 30.31 30.31 28.11 30.31 31.41

* Values are all cummulative to 2030.

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

4.1 Geography

The clothes washer standard that DOE is proposing would apply to all 50 states and U.S.

territories.

4.2 Air Resources

The primary focus of the EA is the effect of proposed efficiency standards on air resources.

For this analysis, the EA uses a variant of DOE, Energy Information Administration’s (DOE/EIA)

National Energy Modeling System (NEMS), called NEMS-BRS (BRS is DOE’s Building Research

and Standards office), plus some additional analysis not using NEMS-BRS to determine the nonpower sector air emissions.b

 The environmental analysis is similar to the utility sector analysis

described in Chapter 12 of the Clothes Washer TSD.1 Outputs of the environmental analysis are in

a format similar to the results of the DOE/EIA’s Annual Energy Outlook 1999 (AEO99).3

For each of the standard levels, DOE calculated total power sector emissions based on output

from NEMS-BRS. DOE also conducted some additional analysis to calculate household emissions

which are not covered by NEMS-BRS. The EA considers only two pollutants, nitrogen oxides (NOx)

and sulfur dioxide (SO2), and one emission, carbon (C). Because emissions of SO2 from power

plants are capped by clean air legislation, physical emissions of this pollutant from electricity

generation will be only minimally affected by possible clothes washer standards. The maximum SO2

allowed by law will most likely still be produced, but because SO2 emissions are traded, and if SO2

emissions are lowered due to less power generation, then the cost of SO2 emission credits may

decrease slightly. Therefore, the EA does not consider changes in power sector SO2 emissions,

although it does household emissions savings. The only form of carbon tracked by NEMS-BRS is
EA-5

carbon dioxide (CO2), so the carbon discussed in this analysis is only in the form of CO2, but is

reported as mass of elemental carbon, in keeping with standard practice. 

4.2.1 Assumptions

The EA uses the same basic assumptions as AEO99 and models the changes resulting from

standards as variations from current policy. For example, the emissions characteristics of an

electricity generating plant in the environmental analysis are the same as those used in AEO99,

although the fuel mix used for generation and the construction program for new plants may deviate

slightly as a result of reduced generation requirements under the standard, which in turn affects air

emission results. As with the utility impact analysis in Chapter 12 of the TSD1

, the environmental

emissions effects are assumed to be linear in the range of the standards decrements and results are

extrapolated.

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

and Low Economic Growth scenarios of NEMS-BRS. As described in Chapter 12 of the TSD1

,

these scenarios cover a range of macro-economic growth assumptions. In addition, a separate

sensitivity assuming high and low price elasticities are analyzed. The high and low price sensitivities

have an effect on the magnitude of clothes washer shipments. Both sensitivity analyses are done for

the case of the proposed standard level (TSL 3) only. Sensitivities were not done for all possible

standard levels as they have been eliminated based on the results of the reference scenario.

4.2.2 Methods

4.2.2.1 Carbon

A detailed carbon module tracks carbon emissions in NEMS-BRS. The Carbon Module

provides good results because it covers all sectors of the economy and their interactions. Because

NEMS-BRS tracks carbon emissions based on the total energy consumption and produces

comprehensive estimates of the benefits of proposed standards, actual household emissions are

included and no external analysis is necessary. NEMS-BRS itself does not account for potential

carbon savings that result from upstream processes, as described in the fuel-cycle section below. 

Past experience with NEMS-BRS carbon results from power generation suggests that using

marginal emissions estimates are more accurate than emissions based on simple forecast average

factors for analysis of proposed appliance standards. First, the marginal fuel displaced by reduced

generation as a result of proposed standards tends to be natural gas, which releases less carbon

emissions than coal. Second, lowered electricity demand tends to slow down the construction of

power generation capacity, thereby slowing improvement in energy conversion efficiency and

emissions rates that typically result from deployment of newer technology. 
EA-6

4.2.2.2 Power Sector NOx

NEMS-BRS reports two airborne pollutant emissions, NOx and SO2. Power sector NOx

results are based on forecasts of compliance with existing legislation at the time AEO99 was released

and have proven stable and reasonable.

4.2.2.3 Power Sector SO2

The Clean Air Act Amendments of 1990 set an SO2 emissions cap on all power generation,

but permits flexibility among generators through the use of emissions allowances and tradable

permits. SO2 trading tends to imply that physical emissions effects of a standard will be zero because

emissions will always be at, or near, the ceiling. There is virtually no real possible SO2

environmental benefit from electricity conservation as long as there is enforcement of the emissions

ceiling. A slight economic benefit may result only if coal generation falls and the reduced demand

for SO2 emission allowances lowers the allowance price. Because the effects considered here are

too small to deliver reasonable estimates, the EA does not consider this possibility.

4.2.2.4 Household NOx and SO2

While NEMS-BRS has an algorithm for estimating emissions of NOx and SO2 from power

generation, it does not estimate household emissions of these pollutants. Because households use

natural gas, fuel oil, and LPG, the residential sector also contributes to NOx and SO2 emissions. This

analysis therefore includes separate estimates of the effect of standards on household NOx and SO2

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

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

residential sector. Appendix EA-1 provides a detailed description of the methodology for deriving

the emissions factors for residential combustion.

4.2.2.5 Fuel-Cycle Emissions

NEMS-BRS does not account for upstream emissions from energy losses during coal and

natural gas production. The upstream processes include the mining of coal or extraction of natural

gas, physical preparatory and cleaning processes, and transportation to the power plant. Appendix

EA-2 shows upstream emission estimates for carbon, SO2, and NOx, along with the emissions factors

and the relative percentage of upstream emissions to power plant emissions. Appendix EA-2 also

provides a detailed description of the methodology used to derive these estimates. Although DOE

does not report actual estimates of the effects of standards, the material in Appendix EA-2 provides

the reader with a feel for the possible magnitude of upstream effects. According to the study by

M.A. DeLuchi, approximately 8% of total coal fuel cycle carbon, NOx, or SO2 emissions are

attributed to upstream coal production. The equivalent value for gas is 14%.
EA-7

4.2.2.6 Interpolation

Because the size of the energy savings from standards are too small to produce stable power

sector results in NEMS-BRS, it has been necessary to estimate results in the range of the standard

levels’ effects using interpolation. Appendix EA-3 describes the interpolation methodology in detail.

A series of cases is executed in which the Residential Demand Module’s clothes washer, clothes

dryer and water heater loads are reduced for each of the fuel types (electricity, gas, oil and LPG) at

incrementally higher savings than the standards levels. Actual standard level savings are then

derived from these outputs. 

4.2.2.7 Extrapolation

The current time horizon of NEMS-BRS is 2020 (modeling a 17-year period, 2004-2020),

yet other parts of the appliance energy efficiency work reach 2030. As described in the utility

analysis in Chapter 12 of the TSD, it is not feasible to extend the forecast period of NEMS-BRS for

the purposes of this analysis, nor does EIA have an approved method for extrapolation of many

outputs beyond 2020; therefore, to ensure consistency all extrapolations beyond 2020 presented here

are simple replications of year 2020 results. As with the AEO99 Reference Case in general, the

implicit assumption is that the regulatory environment does not deviate from the current known

situation during the extrapolation period. Only changes that have been announced with date-certain

introduction are included in NEMS-BRS. Consistent with this assumption, the household emissions

factors used do not change in either the forecast or the extrapolation periods because little

compelling evidence of tightening emissions standards for household appliances was forthcoming

in the research described in Appendix EA-1. To emphasize the extrapolated results wherever they

appear, they are shaded in grey to distinguish them from actual NEMS-BRS output.

4.3 Water Resources

The efficiency level and effective dates of the proposed rulemaking (TSL 3) are analyzed as

well as the nine originally considered MEF standard levels. The original nine MEF values

considered are: 0.860, 0.908, 0.961, 1.021, 1.089, 1.257, 1.362, 1.485, and 1.634. Water usage

reduction per washer was obtained from the Association of Home Appliance Manufacturers

(AHAM) data showing the amount of water use at each clothes washer efficiency level. The amount

of national water usage reduction is determined by using a spreadsheet model that forecasts

shipments and national energy savings (NES). The NES/Shipments model is described in detail in

Chapters 9 and 10 of the Clothes Washer TSD accompanying the NOPR.

4.4 Socioeconomics

As part of the rulemaking process, the socioeconomic effect on consumers was analyzed.

Analysis included determining the differences in life-cycle cost for the standard levels analyzed. See

Chapter 7 and Appendix G of the TSD. In addition, a conjoint analysis and focus groups provided

information on consumer preferences relating to clothes washers. See Chapter 8 and Appendix J of

the TSD.
EA-8

4.5 Environmental Justice

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

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

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

action causes any disproportionately high and adverse human health or environmental effects on lowincome or minority populations. The proposed action causes no such adverse impacts.

4.6 Energy Consumption

Data from manufacturer questionnaires were used as input to a NES/Shipment spreadsheet

model that forecasted shipment of clothes washers to the year 2030 and determined the savings of

energy consumption to the nation both annually and cumulatively. Detail is provided in Chapters

4, 9 and 10 of the Clothes Washer TSD, published together with the NOPR. A sophisticated

NES/Shipments spreadsheet model is described in the Clothes Washer TSD. This spreadsheet model

forecasts the national shipments and energy use of clothes washers with and without standards.

5.0 ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

5.1 Air Quality/ Emissions Impacts

5.1.1 Power Sector Emissions

Table 2 shows the annual power sector carbon and NOx emissions for the proposed and

alternative standard levels. The total carbon emission reductions range up to 5.2 Mt/a in 2020. NOx

emissions reductions reach up to 9.8 kt/a in 2020. Cumulative emissions savings for the power

sector over the 17-year period modeled are listed in Table 3. All of the nine originally considered

MEFs are shown, as well as the proposed two stage standard level and the reference case. The six

TSL’s selected for closer analysis are labeled as TSL 1 through 6. Of these, TSL 3 is being

proposed. See details on the selection process in the Clothes Washer TSD. In Table 3 the lowest

MEF of 0.860 represents a 5% reduction in energy use, whereas the largest MEF, 1.634, represents

a 50% reduction in energy use over a baseline energy use level of 0.817, assumed to be equivalent

to the current minimum clothes washer efficiency requirement. In this analysis, the reference case

refers to cases with respect to the AEO99 Reference Case. All trial standard levels are compared to

the reference case, which represents the no action alternative. This is also referred to as the baseline

case, EF level of 1.18 and MEF level of 0.817.
EA-9

Table 2. Power Sector Emissions for all Standards

NEMS-BRS ResultsAbsolute Values of Emissions

AEO99 Ref. Case - Proposed StandardsEmission Reductions as Compared tothe No Action Alternative

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

AEO99 Reference Case (No Action Alternative, MEF = 0.817) Extrapolation

Carbon (Mt/a)1,3 588.9 612.9 653.2 704.6 744.6 0 0 0 0000

NOx (kt/a)2,3 4191.2 3547.1 3665 3819.2 3882.8 0 0 0 0000

Proposed Standard Levels

MEF = 0.860Carbon (Mt/a) 588.9 612.9 653.1 704.5 744.4 Carbon (Mt/a) 0 0 -0.1 -0.1 -0.2 -0.2 -0.2NOx (kt/a) 4191.2 3546.9 3664.8 3818.8 3882.4 NOx (kt/a) 0 -0.2 -0.3 -0.5 -0.4 -0.4 -0.4

MEF = 0.908Carbon (Mt/a) 588.9 612.8 653 704.2 744 Carbon (Mt/a) 0 -0.1 -0.2 -0.4 -0.6 -0.6 -0.6NOx (kt/a) 4191.2 3546.5 3664.2 3817.7 3881.6 NOx (kt/a) 0 -0.6 -0.8 -1.5 -1.2 -1.2 -1.2MEF = 0.961Carbon (Mt/a) 588.9 612.7 652.8 703.8 743.5 Carbon (Mt/a) 0 -0.2 -0.4 -0.8 -1.1 -1.1 -1.1NOx (kt/a) 4191.2 3546 3663.6 3816.6 3880.7 NOx (kt/a) 0 -1.1 -1.5 -2.6 -2.1 -2.1 -2.1MEF = 1.021 Trial Standard Level 1Carbon (Mt/a) 588.9 612.7 652.7 703.7 743.3 Carbon (Mt/a) 0 -0.2 -0.5 -0.9 -1.3 -1.3 -1.3NOx (kt/a) 4191.2 3545.8 3663.3 3816.1 3880.3 NOx (kt/a) 0 -1.3 -1.8 -3.1 -2.4 -2.4 -2.4MEF = 1.089 Trial Standard Level 2Carbon (Mt/a) 588.9 612.5 652.3 702.9 742.3 Carbon (Mt/a) 0 -0.4 -0.9 -1.7 -2.3 -2.3 -2.3NOx (kt/a) 4191.2 3544.3 3662.1 3813.4 3879 NOx (kt/a) 0 -2.8 -2.9 -5.8 -3.8 -3.8 -3.8
EA-10

Table 2. Power Sector Emissions for all Standards (continued)

NEMS-BRS ResultsAbsolute Values of Emissions

AEO99 Ref. Case - Proposed StandardsEmission Reductions as Compared tothe No Action Alternative

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

MEF = 1.257 Trial Standard Level 4 Extrapolation

Carbon (Mt/a) 588.9 612.3 651.7 701.8 740.8 Carbon (Mt/a) 0 -0.6 -1.5 -2.8 -3.8 -3.8 -3.8NOx (kt/a) 4191.2 3544 3660 3810.2 3876.2 NOx (kt/a) 0 -3.1 -5 -9.1 -6.5 -6.5 -6.5

MEF = 1.362 Trial Standard Level 5Carbon (Mt/a) 588.9 612.2 651.7 701.8 740.8 Carbon (Mt/a) 0 -0.7 -1.5 -2.8 -3.8 -3.8 -3.8 NOx(kt/a) 4191.2 3542.8 3660.1 3809.8 3876.2 NOx (kt/a) 0 -4.2 -5 -9.4 -6.5 -6.5 -6.5MEF = 1.485Carbon (Mt/a) 588.9 612 651.5 701.2 739.7 Carbon (Mt/a) 0 -0.9 -1.7 -3.4 -4.9 -4.9 -4.9NOx (kt/ a) 4191.2 3541.3 3659.9 3807.6 3873.6 NOx (kt/a) 0 -5.8 -5.1 -11.6 -9.1 -9.1 -9.1MEF = 1.634 Trial Standard Level 6Carbon (Mt/a) 588.9 611.9 651.4 700.9 739.4 Carbon (Mt/a) 0 -1 -1.8 -3.7 -5.2 -5.2 -5.2NOx (kt/a) 4191.2 3540.8 3659.5 3806.8 3872.9 NOx (kt/a) 0 -6.3 -5.5 -12.5 -9.8 -9.8 -9.8PROPOSED LEVEL: MEF = 1.04 in 2004 & 1.26 in 2007 (TSL 3)Carbon (Mt/a) 588.9 612.7 652.1 702.2 741 Carbon (Mt/a) 0 -0.2 -1.1 -2.4 -3.6 -3.6 -3.6NOx (kt/a) 4191.2 3545.5 3661.2 3811.4 3876.1 NOx (kt/a) 0 -1.3 -3.9 -7.8 -6.6 -6.6 -6.6

1 Comparable to Table A19 of AEO99: Electric Generators2 Comparable to Table A8 of AEO99: Emissions3 All results to metric tons (t), equivalent to 1.1 short tons
EA-11

Table 3. Cumulative Emissions Reductions through 2020: Power Sector

Emission

MEF (cu. ft. / kWh per cycle)

0.86 0.908 0.961 1.021

TSL 1

1.089

TSL 2

1.257

TSL 4

1.362

TSL 5

1.485 1.634

TSL 6

 1.04 in 2004 

1.26 in 2007

TSL 3

(PROPOSED

MEF)

Carbon (Mt) 1.9 5.8 10.1 12 22.2 36.3 36.9 44.8 48.1 29.8

NOx (kt) 6.2 19.1 33.3 39.6 72.2 114 116.3 144.8 155.5 93.5

5.1.2 Residential Sector (Household) Emissions

In the emissions reductions analysis, reductions in emissions resulting from a clothes washer

standard, are separated into two parts: power sector and residential. The power sector consists of

emissions emitted outside of the household and include primarily emissions generated at power

plants used to generate electricity. Residential sector emissions (also referred to as household

emissions) are those emitted physically at the residence. All emissions due to the generation of

electricity are considered power sector. All emissions due to combustion at the physical location of

the residence are considered residential sector emissions.

Included as part of the clothes washer measure of energy use, is the energy needed to heat

the water that is used by the clothes washer and the energy used to dry the clothes in the clothes

dryer. This is in addition to the electrical energy used to run the washer and dryer electric motors.

Where a natural gas, oil or LPG fuel is used by the water heater, combustion emissions are emitted

at the residence or household. Similarly, for those households having a gas-fired clothes dryer,

emissions from the dryer’s gas burner are also located at the residence. Emissions at the location of

the residence are referred to as residential sector emissions. Details on the emission factors for

combustion from natural gas, LPG, and oil-fired residential water heaters and clothes dryers are

provided in Appendix EA-1. 

Total household carbon, NOx and SO2 emissions savings are presented in Table 4 for all MEF

standard levels. These figures represent the sum of emissions reductions that result from reduced

combustion of natural gas, fuel oil and LPG at residences due to the different trial standard levels.

The annual emissions savings in 2020 range from 0.06 to 1.73 Mt/a for carbon, 0.21 to 5.59 kt/a for

NOx and 0.06 to 1.59 kt/a for SO2. These savings are in addition to the power sector savings reported

above. Table 5 shows cumulative emissions savings for households over the 17-year period (2004-

2020) modeled in NEMS-BRS. 
EA-12

Table 4. Change in Annual Household Emissions for MEF Standards

Year  2000 2005 2010 2015 2020 2025 2030

MEF = 0.860 Extrapolation

Carbon (Mt/a) 0 0 -0.03 -0.05 -0.06 -0.06 -0.06

NOx (kt/a) 0 0 -0.1 -0.18 -0.21 -0.21 -0.21

SO2 (kt/a) 0 0 -0.03 -0.05 -0.06 -0.06 -0.06

MEF = 0.908

Carbon (Mt/a) 0 0 -0.11 -0.19 -0.23 -0.23 -0.23

NOx (kt/a) 0 -0.11 -0.4 -0.69 -0.82 -0.82 -0.82

SO2 (kt/a) 0 0 -0.12 -0.2 -0.24 -0.24 -0.24

MEF = 0.961

Carbon (Mt/a) 0 -0.1 -0.23 -0.38 -0.46 -0.46 -0.46

NOx (kt/a) 0 -0.23 -0.8 -1.39 -1.66 -1.66 -1.66

SO2 (kt/a) 0 -0.1 -0.25 -0.42 -0.51 -0.51 -0.51

MEF = 1.021 Trial Standard Level 1

Carbon (Mt/a) 0 -0.1 -0.33 -0.56 -0.67 -0.67 -0.67

NOx (kt/a) 0 -0.35 -1.21 -2.12 -2.57 -2.57 -2.57

SO2 (kt/a) 0 -0.2 -0.7 -1.27 -1.59 -1.59 -1.59

MEF = 1.089 Trial Standard Level 2

Carbon (Mt/a) 0 -0.18 -0.61 -1.05 -1.28 -1.28 -1.28

NOx (kt/a) 0 -0.56 -1.97 -3.44 -4.17 -4.17 -4.17

SO2 (kt/a) 0 -0.2 -0.69 -1.24 -1.52 -1.52 -1.52

MEF = 1.257 Trial Standard Level 4

Carbon (Mt/a) 0 -0.22 -0.74 -1.3 -1.6 -1.6 -1.6

NOx (kt/a) 0 -0.67 -2.31 -4.13 -5.08 -5.08 -5.08

SO2 (kt/a) 0 -0.2 -0.69 -1.24 -1.52 -1.52 -1.52

MEF = 1.326 Trial Standard Level 5

Carbon (Mt/a) 0 -0.22 -0.74 -1.29 -1.6 -1.6 -1.6

NOx (kt/a) 0 -0.67 -2.31 -4.14 -5.09 -5.09 -5.09

SO2 (kt/a) 0 -0.2 -0.69 -1.24 -1.52 -1.52 -1.52
EA-13

Table 4. Change in Annual Household Emissions for MEF Standards (Continued)

Year  2000 2005 2010 2015 2020 2025 2030

MEF = 1.485 Extrapolation

Carbon (Mt/a) 0 -0.23 -0.75 -1.34 -1.68 -1.68 -1.68

NOx (kt/a) 0 -0.69 -2.39 -4.34 -5.43 -5.43 -5.43

SO2 (kt/a) 0 -0.2 -0.69 -1.25 -1.56 -1.56 -1.56

MEF = 1.634 Trial Standard Level 6

Carbon (Mt/a) 0 -0.24 -0.77 -1.38 -1.73 -1.73 -1.73

NOx (kt/a) 0 -0.71 -2.45 -4.46 -5.59 -5.59 -5.59

SO2 (kt/a) 0 -0.2 -0.7 -1.27 -1.59 -1.59 -1.59

PROPOSED MEF = 1.04 in 2004 & 1.26 in 2007 Trial Standard Level 3

Carbon (Mt/a) 0 -0.12 -0.6 -1.15 -1.58 -1.58 -1.58

NOx (kt/a) 0 -0.35 -1.87 -3.66 -4.97 -4.97 -4.97

SO2 (kt/a) 0 -0.11 -0.56 -1.1 -1.49 -1.49 -1.49

Table 5. Cumulative Emissions Reductions through 2020: Households

Emission

MEF

0.86 0.908 0.961 1.021

TSL 1

1.089

TSL 2

1.257

TSL 4

1.362

TSL 5

1.485 1.634

TSL 6

 1.04 in 2004 

1.26 in 2007

TSL3

(PROPOSED

MEF)

Carbon (Mt) 0.6 2.3 4.7 6.8 12.9 15.9 15.9 16.5 16.9 13.9

NOx (kt) 2.2 8.4 16.9 25.8 42 50.4 50.5 53 54.4 43.9

SO2 (kt) 0.6 2.5 5.2 15.5 15.1 15.1 15.1 15.3 15.5 13.2
EA-14

5.1.3 Power and Residential Sector Emissions

Cumulative emissions reduction for the power sector and households (excluding upstream

emissions) over the 17-year period modeled are presented in Table 6 below.

Table 6. Cumulative Emissions Reductions through 2020: Household and Power Sectors

Emission

MEF

0.86 0.908 0.961 1.021

TSL 1

1.089

TSL 2

1.257

TSL 4

1.362

TSL 5

1.485 1.634

TSL 6

1.04 in 2004 

1.26 in 2007

TSL 3

(PROPOSED

MEF)

Carbon (Mt) 2.5 8.1 14.8 18.9 35.2 52.3 52.8 61.3 65 43.7

NOx (kt) 8.4 27.5 50.3 65.4 114.2 164.4 166.7 197.8 209.9 137.4

SO2 (kt) 0.6* 2.5* 5.2* 15.5* 15.1* 15.1* 15.1* 15.3* 15.5* 13.2*

*Results include only household emissions reductions because the power sector emissions cap implies that savings from

electricity generation will be negligible.

 Cumulative emissions reductions for the power sector and households (excluding upstream

emissions) with the forecast extended through 2030 are in Table 7.

Table 7. Cumulative Emissions Reductions through 2030: Household and Power Sectors

Emission

MEF

0.86 0.908 0.961 1.021

TSL 1

1.089

TSL 2

1.257

TSL 4

1.362

TSL 5

1.485 1.634

TSL 6

 1.04 in 2004 

1.26 in 2007

TSL 3

(PROPOSED

MEF)

Carbon (Mt) 5.1 16.4 30 38.1 70.9 106 107 127 135 95.1

NOx (kt) 14.4 47.4 87.4 116 194 281 283 344 364 253.5

SO2 (kt) 1.2* 4.9* 4.9* 31.4* 30.3* 30.3* 30.3* 30.9* 31.4* 28.1*

*Results include only household emissions reductions because the power sector emissions cap implies that savings from

electricity generation will be negligible.
EA-15

5.1.4 Fuel-Cycle Emissions

The effects of standards on upstream emissions are not reported here. Please refer to

Appendix EA-2 for a general description of the possible magnitude of these effects.

5.1.5 High and Low Sensitivity Analysis for Air Emissions

The Annual Energy Outlook (AEO), a document produced yearly by DOE/EIA, forecasts

emission outputs. As part of its analysis, the AEO analyzes sensitivities for assumptions of high and

low economic growth for the nation. These assumptions of economic activity in turn produce

differences in fuel use and fuel prices. The Reference Case, refers to the emissions predicted in

AEO99, i.e., without a new clothes washer standard.

In Tables 8 and 10, DOE reports the equivalent results for the High and Low Economic

Growth Cases for the proposed TSL 3. Table 8 shows the annual emissions savings from the power

sector with the corresponding annual change in household emissions shown in Table 10. 

In addition to the high and low economic activity AEO scenarios, additional sensitivities

were analyzed based on predictions of how much clothes washer shipments would decrease for an

increase in clothes washer price (i.e., high and low assumptions for price elasticity) that may

accompany an increase in clothes washer efficiency. Detailed analysis is reported in Chapter 9 of

the TSD. DOE reported the equivalent results for assumptions of high and low price elasticity

scenarios for the proposed standard level. Table 9 shows the annual emissions savings from the

power sector with the corresponding annual change in household emissions shown in Table 11.

Shown in Tables 12 and 13 are the low and high sensitivities for the proposed proposed

rulemaking scenario. Table 12 shows results for the low and high economic growth cases.

Generally, the carbon savings for the Low Economic Growth Cases are slightly lower than those

reported for the comparable Reference Case standards scenario while the savings for the High

Economic Growth Cases are slightly higher than those reported for the Reference Case. Table 13

covers high and low price elasticities with MEFs of 1.04 and 1.26 in the years 2004 and 2007,

respectively. The price elasticity sensitivities are chosen to represent a relatively large drop and a

relatively small drop in forecasted shipments when a new minimum efficiency standard takes affect.

See the Shipments and National Energy Savings in Chapters 9 and 10 of the TSD for more detailed

discussion. 
EA-16

Table 8. High and Low Economic Growth: Annual Power Sector Emissions for Proposed Standard (Trial Standard Level 3)

NEMS-BRS Results Difference from AEO99 Reference

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

AEO99 High Economic Growth Reference Case Difference from AEO99 Reference Case ExtrapolationCarbon (Mt/a)1,3 590.6 628.9 679 741.8 799 4.5 32.6 46.6 71.7 104

NOx (kt/a)2,3 4200 3628.7 3764.8 3937.2 4000.7 18 163 163 236 263

MEF = 1.04 in 2004 & 1.26 in 2007 High Economic GrowthCarbon (Mt/a) 590.6 628.7 677.8 739.4 795.1 Carbon (Mt/a) 0 -0.2 -1.2 -2.4 -3.9 -3.9 -3.9NOx (kt/a) 4200.3 3626.2 3760.3 3929.1 3994.6 NOx (kt/a) 0 -2.5 -4.5 -8.06 -6.1 -6.1 -6.1

AEO99 Low Economic Growth Reference Case Difference from AEO99 ReferenceCarbon (Mt/a)1,3 586.1 596.3 632.4 670.1 694.6 -1.8 -17 -21 -34.5 -50

NOx (kt/a)2,3 4182 3465.4 3601.5 3701.3 3737.6 -9 -82 -64 -118 -145

MEF = 1.04 in 2004 & 1.26 in 2007 Low Economic Growth Carbon (Mt/a) 586.1 596.1 631 667.8 691.3 Carbon (Mt/a) 0 -0.2 -1.4 -2.3 -3.3 -3.3 -3.3NOx (kt/a) 4182.1 3464.6 3593.7 3693.3 3728.9 NOx (kt/a) 0 -0.8 -7.8 -8 -8.7 -8.7 -8.7

1 Comparable to Table B19 of AEO99: Electric Generators2 Comparable to Table B8 of AEO99: Emissions3 All results to metric tons (t), equivalent to 1.1 short tons
EA-17

Table 9. High and Low Price Elasticity Scenarios: Annual Power Sector Emissions for Proposed Standard 

(Trial Standard Level 3)

NEMS-BRS Results Difference from AEO99

Reference

2000 2005 2010 2015 2020 2000 2005 2010 201 2020 2025 2030

MEF = 1.04 in 2004 & 1.26 in 2007 Level with Low Price ElasticityCarbon (Mt/a) 588.9 612.7 652.1 702.2 741 Carbon (Mt/a) 0 -0.2 -1.1 -2.4 -3.6 -3.6 -3.6NOx (kt/a) 4191.2 3545.5 3661.2 3811.4 3876.1 NOx (kt/a) 0 -1.6 -3.9 -7.8 -6.6 -6.6 -6.6

MEF = 1.04 in 2004 & 1.26 in 2007 Level with High Price Elasticity

Carbon (Mt/a) 588.9 612.7 652.2 702.3 741 Carbon (Mt/a) 0 -0.2 -1 -2.3 -3.6 -3.6 -3.6NOx (kt/a) 4191.2 3545.8 3661.2 3811.4 3875.5 NOx (kt/a) 0 -1.3 -3.9 -7.8 -7.2 -7.2 -7.2
c

As used here , low price elasticity means the medium price/income elasticity option in the Shipment/NES

spreadsheet model discussed in Chapter 9 of the TSD.

EA-18

Table 10. High and Low Economic Growth: Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3)

Results

2000 2005 2010 2015 2020 2025 2030

 MEF = 1.04 in 2004 & 1.26 in 2007 High Economic Growth

Carbon (Mt/a) 0 -0.12 -0.6 -1.12 -1.54 -1.54 -1.54

NOx (kt/a) 0 -0.35 -1.88 -3.66 -4.97 -4.97 -4.97

SO2 (kt/a) 0 -0.11 -0.56 -1.1 -1.49 -1.49 -1.49

 MEF = 1.04 in 2004 & 1.26 in 2007 Low Economic Growth

Carbon (Mt/a) 0 -0.11 -0.6 -1.18 -1.62 -1.62 -1.62

NOx (kt/a) 0 -0.35 -1.87 -3.66 -4.97 -4.97 -4.97

SO2 (kt/a) 0 -0.11 -0.56 -1.1 -1.49 -1.49 -1.49

Table 11. High and Low Price Elasticity: Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3)

Results

2000 2005 2010 2015 2020 2025 2030

 MEF = 1.04 in 2004 & 1.26 in 2007 Level with Low Price Elasticityc

Carbon (Mt/a) 0 -0.12 -0.61 -1.19 -1.6 -1.6 -1.6

NOx (kt/a) 0 -0.36 -1.94 -3.78 -5.04 -5.04 -5.04

SO2 (kt/a) 0 -0.11 -0.58 -1.13 -1.51 -1.51 -1.51

 MEF = 1.04 in 2004 & 1.26 in 2007 Level with High Price Elasticity

Carbon (Mt/a) 0 -0.12 -0.56 -1.11 -1.58 -1.58 -1.58

NOx (kt/a) 0 -0.35 -1.78 -3.52 -4.95 -4.95 -4.95

SO2 (kt/a) 0 -0.11 -0.53 -1.06 -1.48 -1.48 -1.48
EA-19

Table 12. Cumulative Power Sector and Household Emission Reductions for High & Low

Economic Growth Sensitivities to 2030

Shipment Drop AEO99 Low Economic

Growth

AEO99 Reference Economic

Growth

AEO99 High Economic

Growth

MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF)

Carbon (Mt) 93.8 95.1 98.6

NOx (kt) 292.7 253.5 248.5

SO2 (kt) 28.1 28.1 28.1

Table 13. Cumulative Power Sector and Household Emission Reduction with Elasticity

Sensitivities to 2030 

Shipment Drop Sensitivity

Price / Income = medium

Price Elasticity = none

Reference Case

Price Elasticity =

medium

Price / Income = none

Sensitivity

Price Elasticity = high

Price / Income = none

MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF)

Carbon (Mt) 97.3 95.1 94.4

NOx (kt) 256.2 253.5 254.3

SO2 (kt) 28.7 28.1 27.6

5.2 Water Resources 

The measurement of the MEF and the DOE minimum efficiency level do not have as a

condition a set maximum water usage. However, energy savings are often achieved by reducing

the hot water consumption and in some cases the total water consumption for a wash cycle. 

Table 14 lists the cumulative reduction in water use through 2020 for each of the efficiency

levels. Water savings are based on the results of a manufacturer questionnaire detailing energy

and water use of clothes washers under the various efficiency standard scenarios.
EA-20

Table 14. Cumulative Reduction in Water Use to 2030

Parameter

MEF

0.86 0.908 0.961 1.021

TSL 1

1.089

TSL 2

1.257

TSL 4

1.362

TSL 5

1.485 1.634

TSL 6

 1.04 in 2004 

1.26 in 2007

TSL 3

(PROPOSED

MEF)

Trillion

Gallons

0.41 0.41 0.41 0.53 9.09 12.9 12.9 10.9 10.9 11.59

The proposed standard would result in significant water savings which amounts to 11.59

trillion gallons through the period 2004 - 2030. This means less water needs to be pumped from

U.S. aquifers and rivers, and less strain on many of the nation’s overtaxed water and sewer

systems. The standards will save enough in less use water to supply the needs of 7.3 million

households for 25 years (based on indoor water use). Results of a sensitivity analysis for high

and low economic growth and high and low forecasts of price elasticity (i.e., number of washer

shipments) are shown below in Tables 15 and 16.

 Table 15. Cumulative Water Reduction for High & Low Economic Growth Sensitivities

to 2030

Shipment Drop AEO99 Low Economic

Growth

AEO99 Reference Economic

Growth

AEO99 High Economic

Growth

MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF)

Trillion Gals Water 11.58 11.59 11.59

Table 16. Cumulative Water Reduction with Elasticity Sensitivities to 2030 

Shipment Drop Price / Income = medium

Price Elasticity = none

Reference Case

Price Elasticity =

medium

Price / Income = none

Price Elasticity = high

Price / Income = none

MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF)

Trillion Gals Water 11.8 11.59 11.5
EA-21

5.3 Wetlands / Endangered and Threatened Species / Cultural Resources

As this action is not a site-specific action, nor would it change land disturbance due to

clothes washer placement, impacts to these resources are not expected. Therefore, this action is

not expected to impact the quality of wetlands, or threatened or endangered species, although

lowered national water use and reduced air pollution could have a positive impact, if any at all. 

This action is not expected to impact cultural resources such as historical or archaeological sites. 

5.4 Socioeconomic Impacts

Analysis has shown that the possible increase in the first cost of purchasing a more

efficient clothes washer is on average offset by a reduction in the life-cycle cost of owning a

more efficient washer. This is true for every standard level considered. Although the proposed

standard may increase the initial cost of a clothes washer, the proposed standard level has a

decrease in life-cycle cost (due to reduced energy and water costs) for 90% of consumers at the

first stage in 2004 and for 80% of consumers at the second level of the standard becoming

effective in 2007. See chapter 7 and Appendix G of the TSD for details.

5.5 Environmental Justice Impacts

The proposed action, a new minimum efficiency standard for clothes washers, would not

cause any adverse environmental impacts, and therefore would not cause any disproportionately

high and adverse human health or environmental impacts. Positive impacts, such as decreased

air emissions and water conservation, would be equally shared among all populations. However,

the department did conduct a consumer utility analysis that looked at economic impacts to lowincome and elderly populations. For a complete discussion see chapter 8 and Appendix K of the

TSD at the DOE internet site at

http://www.eren.doe.gov/buildings/codes_standards/applbrf/clwasher.html.

5.6 Energy Consumption Impacts

The proposed standard level of a 1.04 MEF in 2004 and a second higher level of 1.26

MEF in 2007 (TSL 3) would result in the energy savings through the year 2030 shown in Table

17, when compared against the no-action alternative.
EA-22

Table 17. Cumulative Energy Savings for Trial Standard Level 3 (Proposed MEF)

Cumulative Energy Savings in Quads

Total Electric Gas Oil LPG

from 2004

to 2010 0.39 0.23 0.14 0.01 0.01

to 2020 2.51 1.47 0.93 0.06 0.05

To 2030 5.52 3.23 2.05 0.14 0.1

5.7 Summary of Environmental Impacts

This EA provides information on the effects new clothes washer standards would have on

pollutants and other emissions as well as on water use. Analysis of carbon and NOx emissions

from the power sector and households indicates that each of the proposed trial standard levels

would have a positive impact on the environment. Cumulative power sector and household

emissions reductions through 2020 for the proposed standards range from 2.5-65 Mt for carbon

and 8.4-210 kt for NOx. Through 2030, the cumulative emissions reductions range from 5.1-135

Mt for carbon and 14.4-364 kt of NOx. The reduction in SO2 emissions ranges from 0.6-15.5 kt

through 2020 and from 1.2-31.4 kt through 2030. The corresponding reduction in water use

through 2030 ranges from 0.41-12.94 trillion gallons of water. 

The major stakeholders, including manufacturers and energy efficiency advocates, have

jointly submitted a proposed clothes washer efficiency standard to DOE that they both feel is

technically feasible and economically justified. The proposed standard, which is the

Department’s proposed action for purposes of this EA, would go into effect in two stages. The

proposed standard level of a 1.04 MEF (Modified Energy Factor) in 2004 and a second higher

level of 1.26 MEF in 2007 would have the following cumulative reductions in emissions. By the

year 2025, the annual reduction in fuel needed to generate electricity will be equivalent to the

amount needed to run five large coal-fired power plants. (This is equivalent to an annual savings

of 0.18 quads of source energy, 0.086 quads of site energy or 24 Tera watt-hours (TWh) of

electricity sales). The proposed standard will save enough electricity to light 16 million U.S.

homes for 25 years, while cutting greenhouse gas emissions by an amount equal to that produced

by three million cars every year. The proposed standard has significant environmental benefits. 

Cumulative emissions reductions through 2030 are 95.1 Mt (million metric tons) for carbon,

253.5 kt (thousand metric tons) for NOx, 28.1 kt for SO2. Water use reductions are 11.59 trillion

gallons cumulative to 2030. This means less water needs to be pumped from America's aquifers

and rivers, and less strain on many of the nation’s overtaxed water and sewer systems. The

standards will save enough water to supply the indoor water usage needs of 7.3 million

households for 25 years. 
EA-23

REFERENCES

1. U.S. Department of Energy-Office of Building Research and Standards, Technical

Support Document: Energy Efficiency Standards for Consumer Products: Clothes

Washers, September, 2000. Washington, DC. 

2. Title, Code of Federal Regulations, Part 430, Docket No. EE-RM-94-403, RIN 1904-

AA67, Energy Conservation Program for Consumer Products: Clothes Washer Energy

Conservation Standards; Proposed Rule, October 5, 2000, Federal Register. 

3. U.S. Department of Energy - Energy Information Administration, Annual Energy Outlook

1999: With Projections Through 2020, December, 1998. Washington, DC. Report No.

DOE/EIA-0383(99). <http://www.eia.doe.gov/oiaf/aeo99/homepage.html>