i ANALYSIS OF EMISSION S 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

................................ ................................ .................... 31 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 th at 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 revise s 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 o ne 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 d ecorative 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 su pport 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 (FON SI), 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 abo ut 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 em issions 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 20 10 Final Rule adequately addresses the environmental impacts from the Proposed Rule.2 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 alter natives 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 ven ted 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 (C O 2 ) and nitrogen oxides (NO X ) at the sites where these appliances are used. Therefore, DOE calculated the effect of the performance measure on the above site

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

5 0.6

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

- 66 g/GJ for NOX. For a more detailed discussion of

how DOE calculates on

- site emissions of CO 2 and NO X , please refer to the EA for the April

2010 Final Rule. EA at 16

- 13, 16

- 14.

1.1.3 Effects on Household Emissions

Unli ke 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). R ather, their impacts on the environment result from direct emissions of CO 2 and NO X at the site of the product within the household.

Table 1.1.1 shows the total emissions reductions from all direct heating equipment under the April 2010 Final Rule (No A ction 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

Fin al Rule (Action Alternative). The tables display changes in CO 2 and NO X in selected years.

There are no SO 2 emissions impacts because the savings only come from natural gas,

combustion of which does not release SO 2 . “Mt” refers to million metric tons.3 Table 1.1.1 Alt ernative 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 20 40 204 4 Total

2013

- 204 4

2010 Heating Products difference from AEO2010 Reference Case

CO 2 (million metric tons) 0.000 0.738

- 3.193

- 6.070

- 6.957

- 6.957

- 6.957

- 6.570

- 163.8

NO X (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

- 3.9 1

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 20 40 204 4 Total

2013

- 204 4 Additional Reductions Compared to April 2010 Final Rule

CO 2 (million metric tons) 0.000 0.040 0.017

- 0.010

- 0.057

- 0.060

- 0.060

- 0.060

- 0.79

NO X (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, c umulative total is over 2015 to 204 4 for water heater s; cumulative total is

over 2013 to 2042 for direct heating equipment and pool heaters. ( 3) The AEO2010 forecast ends in 2035. To be consistent, household emission impacts past 2035 are also

assumed to be equal to the impacts in 2035

.