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ANALYSIS OF EMISSIONS REDUCTIONS RELATE TO AN

EXCLUSION FOR PRIMARILY DECORATIVE VENTED HEARTH PRODUCTS

TABLE OF CONTENTS

1.1 INTRODUCTION ...............................................................................................................1

1.1.1 Alternatives..........................................................................................................................2

1.1.2 Analytical Methods for Air Emissions ................................................................................2

1.1.3 Effects on Household Emissions .........................................................................................2

LIST OF TABLES

Table 1.1.1 Alternative 1 (No Action) – Emissions Impacts from April 2010 Final 

Rule, Including Standards for Primarily Decorative Vented Hearth 

Products, as Compared to AEO 2010 Reference Case ............................................3

Table 1.1.2 Alternative 2 (Action Alternative) -- Household Emissions Impacts for 

Primarily Decorative Vented Hearth Products Without Continuous Pilot 

Light or Other Source of Continuous Ignition as Compared to 2010 

Heating Products Final Rule ....................................................................................3
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1.1 INTRODUCTION

 This Final Rule is closely related to standards set forth in an earlier DOE rule, namely 

DOE’s April 16, 2010, Final Rule, Energy Conservation Standards for Residential Water 

Heaters, Direct Heating Equipment, and Pool Heathers. 75 FR 20112 (April 2010 Final Rule). 

In that rule, DOE inter alia established exclusions for certain vented heating products (explicitly) 

and vented gas log sets (through a subsequent interpretation). The parts of this Final Rule that 

might have an impact on the human environment do not establish new energy efficiency 

standards. Rather, the rule revises the exclusion for certain primarily decorative hearth products 

from the otherwise applicable energy conservation standards for “vented hearth heaters” 

contained in the April 2010 Final Rule. As one of the criteria to qualify for the exclusion, a 

primarily decorative hearth product is not permitted to have a standing pilot light or other 

continuously-burning ignition source. It is the elimination of these components that would result 

in additional reductions in energy consumption, as compared to the reductions attributable to the 

April 2010 Final Rule. Primarily decorative hearth products that qualify for the exclusion 

actually emit lower levels of air pollutants than products that precisely meet the existing 

standards.

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

seq.), the U.S. Department of Energy (DOE) prepared an Environmental Assessment (EA) of the 

potential impacts of the energy conservation standards for direct heating equipment in the April 

2010 Final Rule. DOE included the EA as chapter 16 of the technical support document (TSD) 

for the April 2010 Final Rule. DOE found that the environmental effects associated with the 

energy conservation standards for vented heating equipment were not significant. Therefore, 

DOE issued a Finding of No Significant Impact (FONSI), pursuant to NEPA, the regulations of 

the Council on Environmental Quality (40 CFR parts 1500–1508), and DOE’s regulations for 

compliance with NEPA (10 CFR part 1021). The FONSI is available on DOE’s NEPA website. 

See 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/fonsi_direct_heating_equipme

nt.pdf (November 08, 2011)

Nothing in the instant Final Rule alters DOE’s FONSI for the April 2010 Final Rule. This 

rule would have further beneficial impacts on the environment, but these impacts are a fraction 

of those resulting from the April 2010 Final Rule. To avoid redundancy, DOE does not here 

repeat qualitative information about pollutant impacts, relevant EPA regulations, and background 

information already set forth in the EA for the April 2010 Final Rule. For that analysis, please 

refer to Chapter 16 of the TSD for the April 2010 Final Rule. See 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/htgp_finalrule_ch1

6.pdf (April 16, 2010). DOE’s limited purpose here is to identify additional emissions reductions 

that DOE anticipates would result from the rule proposed in the NOPR. Based on DOE’s review 

of these emissions reductions, DOE believes that the resulting, additional, beneficial impacts are 

so insignificant that the EA for the April 2010 Final Rule adequately addresses the 

environmental impacts from the Proposed Rule. 
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1.1.1 Alternatives

DOE does not here restate or reconsider the Trial Standard Levels for direct heating 

equipment and associated emissions reductions that DOE analyzed in the April 2010 Final Rule. 

That is because this rule is limited to considering a revised exclusion from the particular standard 

(TSL 2) that DOE adopted in the April 2010 Final Rule. Thus, the alternatives considered here 

are: (1) a No Action Alternative, which assumes that vented heating equipment, including 

decorative hearth heaters, are subject to the April 2010 Final Rule; and (2) an Action Alternative, 

which assumes that all manufacturers of vented hearth products are granted an exclusion from 

the standards set forth in the April 2010 Final Rule.

1.1.2 Analytical Methods for Air Emissions

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

emissions of carbon dioxide (CO2) and nitrogen oxides (NOX) at the sites where these appliances 

are used. Therefore, DOE calculated the effect of the performance measure on the above site 

emissions based on emissions factors derived from the literature. The emissions factors used are 

50.6-68.6 kg/Gigajoule (GJ) for CO2 and 40-66 g/GJ for NOX. For a more detailed discussion of 

how DOE calculates on-site emissions of CO2 and NOX, please refer to the EA for the April 

2010 Final Rule. EA at 16-13, 16-14. 

1.1.3 Effects on Household Emissions

Unlike some of the other products subject to the April 2010 Final Rule, primarily 

decorative vented hearth products use natural gas, not electricity, as an energy source. As such, 

they do not indirectly affect emissions from electric generating units (EGUs). Rather, their 

impacts on the environment result from direct emissions of CO2 and NOX at the site of the 

product within the household. 

Table 1.1.1 shows the total emissions reductions from all direct heating equipment under 

the April 2010 Final Rule (No Action Alternative). Table 1.1.2 shows the additional emissions 

reductions that would result when primarily decorative vented hearth products that lack standing 

pilot lights or other continuously-burning ignition sources are excluded from the April 2010 

Final Rule (Action Alternative). The tables display changes in CO2 and NOX in selected years. 

There are no SO2 emissions impacts because the savings only come from natural gas, 

combustion of which does not release SO2. “Mt” refers to million metric tons.
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Table 1.1.1 Alternative 1 (No Action) – Emissions Impacts from April 2010 Final 

Rule, Including Standards for Primarily Decorative Vented Hearth 

Products, as Compared to AEO 2010 Reference Case

Reference 2010 2015 2020 2025 2030 2035 2040 2044

Total 

2013-

2044

2010 Heating Products difference from AEO2010 Reference Case

CO2 (million metric tons) 0.000 0.738 -3.193 -6.070 -6.957 -6.957 -6.957 -6.570 -163.8

NOX (thousand tons) 0.000 0.565 -2.513 -4.670 -5.272 -5.272 -5.272 -4.915 -125.0

Hg (tons) 0.000 -0.023 -0.087 -0.146 -0.148 -0.148 -0.148 -0.135 -3.91

Table 1.1.2 Alternative 2 (Action Alternative) -- Household Emissions Impacts for 

Primarily Decorative Vented Hearth Products Without Continuous Pilot 

Light or Other Source of Continuous Ignition as Compared to 2010 

Heating Products Final Rule

Reference 2010 2015 2020 2025 2030 2035 2040 2044

Total 

2013-

2044

Additional Reductions Compared to April 2010 Final Rule

CO2 (million metric tons) 0.000 0.040 0.017 -0.010 -0.057 -0.060 -0.060 -0.060 -0.79

NOX (thousand tons) 0.000 0.032 0.013 -0.008 -0.045 -0.047 -0.047 -0.047 -0.63

Notes: (1) The negative values represent decrease in emissions.

(2) With respect to Table 1.1.1, cumulative total is over 2015 to 2044 for water heaters; cumulative total is 

over 2013 to 2042 for direct heating equipment and pool heaters.

 (3) The AEO2010 forecast ends in 2035. To be consistent, household emission impacts past 2035 are also 

assumed to be equal to the impacts in 2035.