15-i

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR SMALL ELECTRIC MOTORS 

TABLE OF CONTENTS 

15.1 INTRODUCTION ...............................................................................................................1 

15.2 AIR EMISSIONS ANALYSIS............................................................................................1 

15.2.1 Air Emissions Descriptions......................................................................................1 

15.2.1.1 Sulfur Dioxide................................................................................................... 2 

15.2.1.2 Nitrogen Oxides................................................................................................ 2 

15.2.1.3 Mercury............................................................................................................. 3 

15.2.1.4 Carbon Dioxide (CO2) ...................................................................................... 3 

15.2.1.5 Particulate Matter.............................................................................................. 4

6

7

7

8

9

15.2.2 Air Quality Regulation.............................................................................................5 

15.2.3 Global Climate Change............................................................................................6 

15.2.3.1 Impacts of Climate Change on the Environment.............................................. 

15.2.3.2 Causes of Climate Change ................................................................................ 

15.2.3.3 Stabilization of CO2 Concentrations................................................................. 

15.2.3.4 The Beneficial Impact of the Rule on CO2 Emissions...................................... 

15.2.3.5 The Incremental Impact of the Rule on Climate Change ................................. 

15.2.4 Analytical Methods for Air Emissions ....................................................................9 

15.2.5 Effects on Power Plant Emissions.........................................................................10 

15.2.6 Effects on Upstream Fuel-Cycle Emissions ..........................................................14 

15.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND 

CULTURAL RESOURCES ..............................................................................................15 

15.4 SOCIOECONOMIC IMPACTS........................................................................................15 

15.5 ENVIRONMENTAL JUSTICE IMPACTS......................................................................15 

15.6 NOISE AND AESTHETICS .............................................................................................16 

15.7 SUMMARY OF ENVIRONMENTAL IMPACTS...........................................................16 

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ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR SMALL ELECTRIC MOTORS 

15.1 INTRODUCTION 

This chapter describes potential environmental effects that may result from energy 

conservation standards for small electric motors. The U.S. Department of Energy (DOE)’s proposed 

energy conservation standards are not site-specific and would apply to all 50 states and U.S. 

territories. Therefore, none of the proposed standards would impact land uses, cause any direct 

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

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

comparison to the baseline efficiency levels. These changes in the demand for electricity are the 

primary drivers in analyzing environmental effects. Estimates of source energy savings can be found 

in the utility impact analysis in chapter 13 of this technical support document (TSD). 

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

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

and the latter part describes potential impacts to other environmental resources. 

15.2 AIR EMISSIONS ANALYSIS 

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

conservation standards for small electric motors. The outcomes of the environmental analysis are 

driven by changes in power plant types and quantities of electricity generated under each of the 

alternatives. Changes in generation are described in the utility impact analysis in TSD chapter 13.

15.2.1 Air Emissions Descriptions 

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

NEMS-BT model (see chapter 13 for description of the model). This analysis considers three 

pollutants: sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury (Hg). An air pollutant is 

any substance in the air that can cause harm to humans or the environment. Pollutants may be 

natural or man-made (i.e., anthropogenic) and may take the form of solid particles (i.e., 

particulates or particulate matter), liquid droplets, or gasesa

. This analysis also considers carbon 

dioxide (CO2). 

a

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

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

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15.2.1.1 Sulfur Dioxide 

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

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

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

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

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

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

people and their environment.1

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

the standards at this time. 

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

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

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

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

complying with regulatory caps on emissions. 

15.2.1.2 Nitrogen Oxides 

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

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

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

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

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

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

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

NOx also contributes to the formation of fine particles that can impair human health.2

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

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

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

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

15.2.1.3 Mercury 

 Coal-fired power plants emit mercury (Hg) found in coal during the burning process. 

While coal-fired power plants are the largest remaining source of human-generated Hg emissions 

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

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

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

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

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

it can transform into methylmercury and accumulate in fish tissue through bioaccumulation. 

 

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

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

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

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

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

abilities, and verbal memory. 

15.2.1.4 Carbon Dioxide (CO2) 

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

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

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

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

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

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

gas, and coal), wood, and wood products are burned. In 2007, over 90 percent of anthropogenic 

(i.e., human-made) CO2 emissions resulted from burning fossil fuels.3

 

 Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes, 

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

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

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

billions of metric tons are added to the atmosphere annually. In the United States, in 2007, CO2

emissions from electricity generation accounted for 39 percent of total U.S. GHG emissions.3

 

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15.2.1.5 Particulate Matter 

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

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

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

or dust particles. 

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

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

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

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

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

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

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

lung disease. 

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

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

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

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

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

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

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

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

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

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

complex atmospheric chemical reactions and the proportion of impacts and exposures 

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

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

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

transport, deposition and atmospheric chemistry. 

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

studies regarding PM source apportionment. In this compilation of studies, sources are 

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

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

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

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

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

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

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

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

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

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e 

stered 

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

emissions on air quality at this time. 

15.2.2 Air Quality Regulation 

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

to control.1 EPA has set national air quality standards for six common pollutants (also referred to 

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

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

plants to reduce emissions of SO2 and NOx. Title IV of the 1990 amendments established a capand-trade program for SO2 intended to help control acid rain.1

 This cap-and-trade program serves 

as a model for more recent programs with similar features. 

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

the Clean Air Act (40 CFR Parts 51, 96, and 97).4 b CAIR will permanently cap emissions of 

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

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

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

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

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

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

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

and SO2 are due in 2015. 

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

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

the Clean Air Act (40 CFR Parts 60, 63, 72, and 75) 5. This rule, called the Clean Air Mercury 

Rule (CAMR), was closely related to the CAIR and established standards of performance for Hg 

emissions from new and existing coal-fired electric utility steam generating units. The CAMR 

regulated Hg emissions from coal-fired power plants. 

 

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

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

Agency,

c

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

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

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

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

 

b

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

c

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

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

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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. EPA, 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur).f

 

15.2.3 Global Climate Change 

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

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

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

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

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

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

global warming. 

15.2.3.1 Impacts of Climate Change on the Environment 

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

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

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

precipitation) over an extended period, typically decades or longer.7 

 The World Meteorological Organization and United Nations Environment Programme 

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

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

Report (IPCC Report), published in 2007, climate change is consistent with observed changes to 

the world’s natural systems; the IPCC expects these changes to continue.7

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

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

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

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

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

waves in many locations worldwide, and numerous ecological changes.6

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

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

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

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

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

and emissions scenarios.6

 

e See id. at 903. 

f

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

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

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

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

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

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

beneficial impacts on crop yields in temperate regions. 

15.2.3.2 Causes of Climate Change 

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

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

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

greenhouse gases such as methane and nitrous oxide in the atmosphere, rather than from natural 

causes. 

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

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

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

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

global warming potential in GHGs emitted from human activities, with the vast majority (74 

percent) of the CO2 attributable to fossil fuel use.7 For the future, the IPCC Report describes a 

wide range of GHG emissions scenarios, but under each scenario CO2 would continue to 

comprise above 70 percent of the total global warming potential.7

15.2.3.3 Stabilization of CO2 Concentrations 

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

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

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

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

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

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

tons of CO2.

8 h

 

 

 

 Researchers have focused on considering atmospheric CO2 concentrations that likely will 

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

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

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

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

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

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

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

h

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

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

EERE-2007-BT-STD-0007 COMMENT 17
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CO2 concentrations with temperature increases that plateau in a defined range. For example, at 

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

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

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

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

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

downward trend in total annual global emissions of greenhouse gases to levels that are 50 to 85 

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

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

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

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

scenarios describe some warming and some climate change is projected due to already 

accumulated CO2 and GHGs in the atmosphere.9

15.2.3.4 The Beneficial Impact of the Rule on CO2 Emissions 

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

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

Energy Information Administration (EIA) reports in its 2009 Annual Energy Outlook 

(AEO2009)

11 that U.S. annual energy-related emissions of CO2 in 2006 were about 6.0 billion 

metric tons, of which 2.3 billion tons were attributed to the electricity consumption (including 

related energy–using products such as small electric motors). Most of the greenhouse gas 

emissions attributed to commercial and industrial electricity are emitted from fossil fuel-fired 

power plants that generate the electricity used in these sectors. In the AEO2009 Reference Case, 

EIA projected that annual energy-related CO2 emissions would grow from 5.7 billion metric tons 

in 2010 to 6.2 billion metric tons in 2030, an increase of 8 percent (see AEO2009), while 

electricity-related emissions would grow to from 2.3 billion metric tons to 2.6 billion metric tons, 

an increase of 13 percent. 

 The estimated cumulative CO2 emission reductions from a small electric motors 

efficiency standard (shown as a range of alternative TSLs) during the 30-year forecast period are 

indicated in Table EA.2.1. Estimated CO2 emission reductions in Table EA.2.1 come from 

electricity generation (i.e., power plants). The estimated CO2 emission reductions from electricity 

generation are calculated using the NEMS-BT model. 

i

 IPCC Working Group 3 Table TS 2 

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Table 15.2.1 Impact of Small Electric Motors Efficiency Standards on 

Cumulative Electricity-Related Emissions of CO2 between 2010 

and 2045 (Million Metric Tons of CO2) 

Trial Standard Levels 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 TSL 7 TSL 8 

Polyphase Motors* -2.2 -5.2 -9.7 -11.1 -18.6 -20.5 -23.8 N/A 

Capacitor Start Motors* -57.9 -73.8 -83.6 -84.6 -85.3 -105.8 -106.2 -122.6 

Total* -60.1 -79.0 -92.3 -95.7 -103.9 -126.3 -130.0 N/A 

Percent of Total 

Cumulative Power 

Sector Emissions from 

2010 to 2045 compared 

with the AEO 2009 

Reference Case 

-0.08% -0.10% -0.12% -0.12% -0.13% -0.16% -0.16% N/A 

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

15.2.3.5 The Incremental Impact of the Rule on Climate Change 

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

and specific atmospheric concentrations with future temperatures because the IPCC Report 

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

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

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

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

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

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

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

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

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

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

scenarios that aim to meet specific temperature levels. 

 

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

and when particular CO2 emissions rates will impact global warming. However, as Table 15.2.1 

indicates, the proposed rule is expected to reduce CO2 emissions from the electricity-generation 

sector. 

15.2.4 Analytical Methods for Air Emissions 

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

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

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

NEMS-BT in 2008 included provisions for the CAIR, which imposes stricter restrictions on SO2

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

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earlier is section EA.2.2, on December 23, 2008, the D.C. Circuit decided to allow CAIR to 

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

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

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

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

Protection Agency, remain in effect vacating the CAMR. Thus, the version of NEMS-BT in 

2009 used in this analysis does not include provisions for the CAMR. 

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

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

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

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

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

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

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

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

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

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

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

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

an existing unit. 

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

NOx emissions in the 28 States covered by the CAIR. In the presence of these caps, the NEMSBT modeling system that DOE used to forecast emissions reduction indicated that no physical 

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

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

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

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

cap.

11 The difference between the emissions levels that NEMS-BT forecasts and those that EPA 

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

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

SO2 emissions reductions at this time. 

 As noted in chapter 13, NEMS-BT model forecasts end in year 2030. Emissions impacts 

beyond 2030 were extrapolated for this rulemaking in Table EA.2.3 through EA.2.4. 

15.2.5 Effects on Power Plant Emissions 

 Table EA.2.2 shows AEO2009 reference case power plant emissions in selected years. 

The Reference Case emissions are the emissions shown by the NEMS-BT model to result if none 

of the TSLs are promulgated (the base case). 

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Table 15.2.2 Power Sector Emissions Forecast from AEO2009 Reference Case 

NEMS-BT Results* 

 2005 2010 2015 2020 2025 2030

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

NOX (Million metric tons/year)† 3.30 2.07 1.87 1.88 1.88 1.91

Hg (metric tons/year)† 51.5 43.8 29.5 28.9 29.3 28.7

* 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 15.2.3 through Table 15.2.4 show the estimated changes in power plant emissions 

in selected years for all the TSLs. Changes in NOx and Hg emissions from power plants 

calculated by NEMS-BT are shown in these tables. Changes in CO2 emissions from all sources 

are also shown in these tables. 

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

15.2.2, changes in emission levels shown in Table 15.2.3 though 15.2.4 are extremely small. 

EERE-2007-BT-STD-0007 COMMENT 17
Table 15.2.3 Power Sector Emissions Impact Forecasts for Polyphase Small Electric 

Motors 

NEMS-BT Results Difference from AEO 2009 Reference Case Extrapolation Cumulative

2010 2015 2020 2025 2030 2035 2040 2045 2010-2045

Standard Level 1

CO2 (Mt/a) 0.02 0.03 -0.04 -0.09 -0.10 -0.10 -0.10 -0.10 -2.3

NOx (kt/a) 0.0000 0.0000 0.0000 -0.0001 -0.0001 -0.0001 -0.0001 -0.0001 -0.0016

Hg (t/a) -0.0001 -0.0002 -0.0003 -0.0004 -0.0004 -0.0004 -0.0004 -0.0004 -0.0123

Standard Level 2

CO2 (Mt/a) 0.04 0.07 -0.10 -0.22 -0.23 -0.23 -0.23 -0.23 -5.2

NOx (kt/a) 0.0000 0.0001 -0.0001 -0.0002 -0.0002 -0.0002 -0.0002 -0.0002 -0.0037

Hg (t/a) -0.0003 -0.0004 -0.0007 -0.0008 -0.0008 -0.0008 -0.0008 -0.0008 -0.0282

Standard Level 3

CO2 (Mt/a) 0.07 0.13 -0.19 -0.40 -0.44 -0.44 -0.44 -0.44 -9.7

NOx (kt/a) 0.0001 0.0001 -0.0001 -0.0003 -0.0003 -0.0003 -0.0003 -0.0003 -0.0069

Hg (t/a) -0.0005 -0.0008 -0.0014 -0.0015 -0.0015 -0.0015 -0.0015 -0.0015 -0.0529

Standard Level 4

CO2 (Mt/a) 0.08 0.15 -0.21 -0.46 -0.50 -0.50 -0.50 -0.50 -11.1

NOx (kt/a) 0.0001 0.0001 -0.0002 -0.0003 -0.0004 -0.0004 -0.0004 -0.0004 -0.0080

Hg (t/a) -0.0005 -0.0009 -0.0016 -0.0017 -0.0018 -0.0018 -0.0018 -0.0018 -0.0606

Standard Level 5

CO2 (Mt/a) 0.13 0.25 -0.36 -0.77 -0.84 -0.84 -0.84 -0.84 -18.6

NOx (kt/a) 0.0001 0.0002 -0.0003 -0.0006 -0.0006 -0.0006 -0.0006 -0.0006 -0.0133

Hg (t/a) -0.0009 -0.0016 -0.0027 -0.0029 -0.0030 -0.0030 -0.0030 -0.0030 -0.1016

Standard Level 6

CO2 (Mt/a) 0.14 0.27 -0.39 -0.85 -0.92 -0.92 -0.92 -0.92 -20.5

NOx (kt/a) 0.0001 0.0002 -0.0003 -0.0006 -0.0007 -0.0007 -0.0007 -0.0007 -0.0147

Hg (t/a) -0.0010 -0.0018 -0.0030 -0.0032 -0.0033 -0.0033 -0.0033 -0.0033 -0.1118

Standard Level 7

CO2 (Mt/a) 0.16 0.31 -0.46 -0.99 -1.08 -1.08 -1.08 -1.08 -23.8

NOx (kt/a) 0.0001 0.0002 -0.0003 -0.0007 -0.0008 -0.0008 -0.0008 -0.0008 -0.0171

Hg (t/a) -0.0012 -0.0020 -0.0034 -0.0037 -0.0038 -0.0038 -0.0038 -0.0038 -0.1300

15-12 

EERE-2007-BT-STD-0007 COMMENT 17
Table 15.2.4 Power Sector Emissions Impact Forecasts for Capacitor Start Small Electric 

Motors 

NEMS-BT Difference from AEO 2009 Reference Case Extrapolation Cumulative

2010 2015 2020 2025 2030 2035 2040 2045 2010-2045

Standard Level 1

CO2 (Mt/a) 0.42 0.68 -1.48 -2.33 -2.50 -2.50 -2.50 -2.50 -57.9

NOx (kt/a) 0.0004 0.0005 -0.0011 -0.0017 -0.0018 -0.0018 -0.0018 -0.0018 -0.0416

Hg (t/a) -0.0022 -0.0053 -0.0073 -0.0124 -0.0058 -0.0058 -0.0058 -0.0058 -0.2428

Standard Level 2

CO2 (Mt/a) 0.53 0.86 -1.88 -2.96 -3.18 -3.18 -3.18 -3.18 -73.8

NOx (kt/a) 0.0005 0.0007 -0.0014 -0.0022 -0.0023 -0.0023 -0.0023 -0.0023 -0.0530

Hg (t/a) -0.0027 -0.0067 -0.0093 -0.0158 -0.0073 -0.0073 -0.0073 -0.0073 -0.3090

Standard Level 3

CO2 (Mt/a) 0.60 0.98 -2.13 -3.35 -3.60 -3.60 -3.60 -3.60 -83.6

NOx (kt/a) 0.0005 0.0008 -0.0016 -0.0025 -0.0026 -0.0026 -0.0026 -0.0026 -0.0600

Hg (t/a) -0.0031 -0.0076 -0.0105 -0.0179 -0.0083 -0.0083 -0.0083 -0.0083 -0.3497

Standard Level 4

CO2 (Mt/a) 0.60 0.97 -2.13 -3.38 -3.65 -3.65 -3.65 -3.65 -84.6

NOx (kt/a) 0.0005 0.0008 -0.0016 -0.0025 -0.0026 -0.0026 -0.0026 -0.0026 -0.0608

Hg (t/a) -0.0031 -0.0075 -0.0105 -0.0180 -0.0084 -0.0084 -0.0084 -0.0084 -0.3529

Standard Level 5

CO2 (Mt/a) 0.60 0.98 -2.14 -3.40 -3.68 -3.68 -3.68 -3.68 -85.3

NOx (kt/a) 0.0005 0.0008 -0.0016 -0.0025 -0.0027 -0.0027 -0.0027 -0.0027 -0.0612

Hg (t/a) -0.0031 -0.0075 -0.0106 -0.0182 -0.0085 -0.0085 -0.0085 -0.0085 -0.3551

Standard Level 6

CO2 (Mt/a) 0.76 1.24 -2.70 -4.25 -4.56 -4.56 -4.56 -4.56 -105.8

NOx (kt/a) 0.0007 0.0010 -0.0021 -0.0031 -0.0033 -0.0033 -0.0033 -0.0033 -0.0760

Hg (t/a) -0.0039 -0.0096 -0.0133 -0.0227 -0.0105 -0.0105 -0.0105 -0.0105 -0.4427

Standard Level 7

CO2 (Mt/a) 0.74 1.22 -2.67 -4.24 -4.58 -4.58 -4.58 -4.58 -106.2

NOx (kt/a) 0.0007 0.0010 -0.0020 -0.0031 -0.0033 -0.0033 -0.0033 -0.0033 -0.0763

Hg (t/a) -0.0038 -0.0094 -0.0132 -0.0226 -0.0106 -0.0106 -0.0106 -0.0106 -0.4427

Standard Level 8

CO2 (Mt/a) 0.77 1.25 -2.85 -4.76 -5.30 -5.32 -5.32 -5.32 -122.6

NOx (kt/a) 0.0007 0.0010 -0.0022 -0.0035 -0.0038 -0.0038 -0.0038 -0.0038 -0.0882

Hg (t/a) -0.0039 -0.0097 -0.0141 -0.0254 -0.0122 -0.0123 -0.0123 -0.0123 -0.4988

15-13 

EERE-2007-BT-STD-0007 COMMENT 17
15-14 

15.2.6 Effects on Upstream Fuel-Cycle Emissions 

 Upstream fuel-cycle emissions refer to the emissions associated with the amount of 

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

energy used at the power plant. Upstream processes include the mining of coal or extraction of 

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

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

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

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

emissions. 

 However, previous DOE environmental assessment documents have developed 

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

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

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

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

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

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

includes cleaning the coal, and transportation from the mine to the power plant.10 Transportation 

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

from the mine to the power plant. In addition, based on Dr. DeLuchi’s work, DOE estimated that 

approximately an amount equal to 14 percent of emissions from natural gas production result 

from upstream processes. 

 Emission factor estimates and corresponding percentages of contributions of upstream 

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

Table EA.2.5 for CO2 and NOx. The percentages provide a means to estimate upstream emission 

savings based on changes in emissions from power plants. The percentage effects presented in 

Table EA.2.5 provide a qualitative approach to viewing effects on fuel cycle emissions. The 

previous section indicates slight overall reductions in CO2 and NOx. Thus, very small reductions 

in upstream emissions of air pollutant could be expected. This approach does not address Hg 

emissions. 

Table 15.2.5 Estimated Upstream Emissions of Air Pollutants as a Percentage 

of Direct Power Plant Combustion Emissions 

Pollutant 

Percent of Coal 

Combustion Emissions 

Percent of Natural Gas 

Combustion Emissions 

CO2 2.7 11.9 

NOx 5.8 40 

 

EERE-2007-BT-STD-0007 COMMENT 17
15-15 

15.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND 

CULTURAL RESOURCES 

 Because small electric motors are not water-consuming products, more efficient motors 

would not reduce the amount of water discharged into the waste stream. As a result, small 

electric motor energy conservation standards do not have the effect of improving the quality of 

wetlands, nor threatened or endangered species that reside in these wetlands. This action is also 

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

15.4 SOCIOECONOMIC IMPACTS 

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

small electric motors at the proposed standard levels is largely offset by a reduction in the lifecycle cost (LCC) of owning a more efficient product for the average consumer. In other words, 

the consumer will pay less operating costs over the life of the product even through the first cost 

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

 The primary purchasers of small electric motors are commercial and industrial 

businesses. Subgroups of space-constrained motor owners will primarily be affected by the 

standard through impacts on initial cost which DOE estimates can be very large when more 

efficient motors have difficulty satisfying space constraints. DOE estimates that such costs 

should be distributed throughout the economy and should not affect any particular socioeconomic group more than others. Therefore, DOE concludes that the proposed action would 

have no significant socioeconomic impact. For a complete discussion on the consumer and 

national impacts of the proposed standard, see chapters 8 and 10 of the TSD respectively. 

15.5 ENVIRONMENTAL JUSTICE IMPACTS 

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

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

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

either manufacture or use small electric motors, (2) manufacturers of niche products related to 

small electric motors, and (3) small businesses operated by disadvantaged or minority 

populations. 

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

affected by small electric motors energy conservation standards. As described in the 

Manufacturer Subgroup Analysis, Chapter 12 of the TSD, DOE found that there was no 

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

that would result from the proposed energy conservation standards. DOE believes that above 

conclusion also applies to minority populations. 

EERE-2007-BT-STD-0007 COMMENT 17
15-16 

15.6 NOISE AND AESTHETICS 

 Improvements in efficiency of small electric motors are expected to result from changes 

in the choice of components and other design features. These changes are described in chapter 5 

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

products in today’s market. DOE considered noise and aesthetics when evaluating different 

engineering design options and found that products that meet the proposed standard can maintain 

the same noise levels as products currently in the market. Products that are currently 

manufactured in the existing market that would meet the proposed standards are no louder than 

less efficient products. Changes to the design to improve the efficiency levels are not anticipated 

to affect the product aesthetics. 

15.7 SUMMARY OF ENVIRONMENTAL IMPACTS 

 Table 15.7.1 through Table 15.7.2 summarize anticipated environmental impacts for each 

of the TSLs across all product types. Air quality impacts were modeled for each of the TSLs. 

The summary table shows cumulative changes in emissions for CO2, NOx, and Hg from 2015 to 

2045 for small electric motors. Cumulative CO2, NOx, and Hg emissions show a decrease 

compared to the reference case. 

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

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

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

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

actual estimates of the effects. 

 No impacts are anticipated in the area of environmental justice, wetlands, endangered and 

threatened species, and cultural resources; or noise and aesthetics. 

EERE-2007-BT-STD-0007 COMMENT 17
15-17 

Table 15.7.1 Environmental Impact Analysis Results Summary, Polyphase 

Small Electric Motors 

Environmental Effects TSL 

1 2 3 4 5 6 7 

Cumulative Emissions Reductions**

CO2, Mt 2.2 5.2 9.7 11.1 18.6 20.5 23.8 

NOx, kt 0.002 0.004 0.007 0.008 0.013 0.015 0.017 

Hg, t 0.012 0.028 0.053 0.061 0.102 0.112 0.130 

Fuel-Cycle (Upstream) Emissions †† †† †† †† †† †† †† 

Wetlands, Endangered and 

Threatened Species; Cultural 

Resources 

-- -- -- -- -- -- -- 

Socioeconomic Impacts–

Weighted Mean LCC Savings‡

-- -- -- -- -- -- -- 

All Motors $0 $9 $21 $19 ($38) ($85) ($818) 

Space-Constrained Motors $0 $9 $21 $19 ($150) ($151) ($2,937) 

Environmental Justice -- -- -- -- -- -- -- 

Noise and Aesthetics -- -- -- -- -- -- -- *

 The reference case values reflect total cumulative emissions and life cycle costs in the absence of an 

energy conservation standard. 

** Cumulative total is from 2010–2045 for standard implemented in 2015. 

†† DOE does not report actual estimates of the effects of standards on upstream emissions, but section 

EA.2.6 provides a sense for the possible magnitude of effects. 

‡

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

EERE-2007-BT-STD-0007 COMMENT 17
15-18 

Table 15.7.2 Environmental Impact Analysis Results Summary, CapacitorStart Small Electric Motors 

Environmental Effects TSL 

1 2 3 4 5 6 7 8 

Cumulative Emissions Reductions**

CO2, Mt 57.0 57.9 73.8 84.6 85.3 105.8 106.2 122.6 

NOx, kt 0.042 0.053 0.060 0.061 0.061 0.076 0.076 0.088 

Hg, t 0.243 0.309 0.350 0.353 0.355 0.443 0.443 0.499 

Fuel-Cycle (Upstream) Emissions †† †† †† †† †† †† †† 

Wetlands, Endangered and 

Threatened Species; Cultural 

Resources 

-- -- -- -- -- -- -- 

Socioeconomic Impacts–

Weighted Mean LCC Savings‡

-- -- -- -- -- -- -- 

All Motors: 

 CSIR 

 CSCR 

$55 

$23 

$55 

$28 

$54 

$28 

$21 

$10 

$21 

$28 

($346) 

($846) 

($346) 

$28 

($346) 

($47) 

Space-Constrained Motors: 

 CSIR 

 CSCR 

$49 

$8 

$49 

$11 

$54 

$11 

($48) 

$7 

($48) 

$11 

($1,891)

($2,937)

($1,891) 

$11 

($1,891) 

($157) 

Environmental Justice -- -- -- -- -- -- -- 

Noise and Aesthetics -- -- -- -- -- -- -- *

 The reference case values reflect total cumulative emissions and life cycle costs in the absence of an energy 

conservation standard. 

** Cumulative total is from 2010–2045 for standard implemented in 2015. 

†† DOE does not report actual estimates of the effects of standards on upstream emissions, but section EA.2.6 

provides a sense for the possible magnitude of effects. 

‡

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

EERE-2007-BT-STD-0007 COMMENT 17
15-19 

REFERENCES 

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

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

2. U.S. Environmental Protection Agency, Nitrogen Oxides Health and Environmental 

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

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

2009. <http://www.epa.gov/climatechange/emissions/usinventoryreport.html> 

4. 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. 

5. U.S. Federal Register, Standards of Performance for New and Existing Stationary 

Sources: Electric Utility Steam Generating Units, Final Rule, May 18, 2005, 2005. 

Report No. 70 FR 28606. 

6. Intergovernmental Panel On Climate Change, IPCC WGI Fourth Assessment Report: 

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

7. Intergovernmental Panel On Climate Change, Climate Change 2007 – Impacts, 

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

8. Intergovernmental Panel On Climate Change, IPCC Special Report on Land Use, LandUse Change And Forestry, 2000. 

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

9. 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/assessment-report/ar4/wg3/ar4-wg3-ts.pdf> 

10. DeLuchi, M. A., Emissions of Greenhouse Gases from the Use of Transportation Fuels 

and Electricity, Volume 2: Appendixes A-S, November, 1993. Argonne National 

Laboratory. Argonne, IL. Report No. ANL/ESD/TM-22-Vol.2. 

11. 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> 

EERE-2007-BT-STD-0007 COMMENT 17
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12. U.S. Environmental Protection Agency, Compilation of Existing Studies on Source 

Apportionment for PM2.5, Emissions, Monitoring, and Analysis 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> 

EERE-2007-BT-STD-0007 COMMENT 17