9-i

CHAPTER 9. EMISSIONS MONETIZATION

TABLE OF CONTENTS

9.1 INTRODUCTION ............................................................................................................... 9-2

9.2 ECONOMIC VALUATION OF EMISSIONS REDUCTIONS ......................................... 9-2

REFERENCES .......................................................................................................................... 9-10

LIST OF TABLES

Table 9.2.1 Cumulative Present Value for Emissions Reductions from Commercial 

Boilers from 2012 to 2042 for Adopting ASHRAE Standard 90.1-2007 

over the Market Baseline, Seven Percent Discount Rate ..................................... 9-6

Table 9.2.2 Cumulative Present Value for Emissions Reductions from Commercial 

Boilers from 2012 to 2042 for Adopting ASHRAE Standard 90.1-2007 

over the Market Baseline, Three Percent Discount Rate ..................................... 9-7

Table 9.2.3 Cumulative Present Value of National Emissions Reductions for 

Commercial Boilers from 2012 to 2042 for Adoption of Analyzed Higher 

Standards over ASHRAE 90.1-2007 Baseline, Seven Percent Discount 

Rate ...................................................................................................................... 9-8

Table 9.2.4 Cumulative Present Value of National Emissions Reductions for 

Commercial Boilers from 2012 to 2042 for Adoption of Analyzed Higher 

Standards over ASHRAE 90.1-2007 Baseline, Three Percent Discount 

Rate ...................................................................................................................... 9-9

EERE-2008-BT-STD-0013 COMMENT 06
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CHAPTER 9. EMISSIONS MONETIZATION

9.1 INTRODUCTION

This chapter describes potential economic benefits that may result from reductions in 

environmental emissions due to amended energy conservation standards for commercial 

packaged boilers. 

All of the potential standard levels analyzed are expected to result in reductions in 

environmental emissions in comparison to a baseline. (For the purposes of this EA, the baseline 

is defined as a scenario where DOE does not adopt any standard for commercial boilers). The 

changes in the demand for fossil fuel (including fuel oil and natural gas) and the costs of 

achieving these savings are the primary drivers for the reduction of environmental emissions. 

These emission reductions are then monetized using calculated values for the economic impacts 

to the nation of per-unit reductions in SO2, NOx and CO2. Cumulative monetary benefits were 

determined using discount rates of 3 and 7 percent. 

9.2 ECONOMIC VALUATION OF EMISSIONS REDUCTIONS

In addition to the estimation of reductions in physical emissions from an energy 

conservation standard, the analysis also considered the monetary benefits associated with these 

reductions. 

Carbon Dioxide (CO2) 

During the preparation of its most recent review of the state of climate science, the 

Intergovernmental Panel on Climate Change (IPCC) identified various estimates of the present 

value of reducing carbon dioxide emissions by one ton over the life that these emissions would 

remain in the atmosphere. The estimates reviewed by the IPCC spanned a range of values. In the 

absence of a consensus on any single estimate of the monetary value of CO2 emissions, DOE 

used an estimate identified by the study cited in Summary for Policymakers prepared by 

Working Group II of the IPCC’s Fourth Assessment Report to calculate the potential monetary 

value of the CO2 reductions likely to result from the standards under consideration in this 

rulemaking. 

To put the potential monetary benefits from reduced CO2 emissions into a form that is 

likely to be most useful to decision makers and interested parties, the estimated year-by-year 

reductions in CO2 emissions were converted into monetary values and these resulting annual 

values were then discounted over the life of the affected equipment to the present using both 3 

percent and 7 percent discount rates. DOE applied an annual growth rate of 2.4 percent to the 

value of the Social Cost of Carbon (SCC), as suggested by the IPCC Working Group II (2007, p. 

822), based on estimated increases in damages from future emissions reported in published 

studies. As a result, DOE assigned a range for the SCC of $0 to $20 (2007$) per ton of CO2

emissions. These estimates were based on an assumption of no benefit to an average benefit 

value reported by the IPCC as the SCC.a

 

a

 According to IPCC, the mean social cost of carbon (SCC) reported in studies published in peer-reviewed journals 

was $43 per ton of carbon. This translates into about $12 per ton of carbon dioxide. The literature review (Tol 

 

EERE-2008-BT-STD-0013 COMMENT 06
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The IPCC estimate used as the upper bound value was derived from an estimate of the 

mean value of worldwide impacts from potential climate impacts caused by CO2 emissions, and 

not just the effects likely to occur within the United States. In previous rulemakings, DOE 

considered that in estimating a monetary value for CO2 emission reductions, the values should be 

restricted to a representation of those costs/benefits likely to be experienced in the United States 

and further expected that such values would be lower than comparable global values. DOE, in 

cooperation with other Federal agencies, is now reviewing whether this previous approach 

should be modified. Regardless, there currently are no consensus estimates for the U.S. benefits 

likely to result from CO2 emission reductions. Because U.S.-specific estimates are unavailable 

and because DOE has not received any additional information that would help narrow the range 

of domestic benefits, DOE used the global mean value as an upper bound U.S. value.b

The Department of Energy, together with other Federal agencies, is reviewing various 

methodologies for estimating the monetary value of reductions in CO2 and other greenhouse gas 

emissions. This review will consider the comments on this subject that are part of the public 

record for this and other rulemakings, as well as other methodological assumptions and issues, 

such as whether the appropriate values should represent domestic U.S. or global benefits (and 

costs). Given the complexity of the many issues involved, this review is ongoing. However, 

consistent with DOE’s legal obligations, and taking into account the uncertainty involved with 

this particular issue, DOE has included in the proposed rulemaking the values and analyses 

previously conducted.

 

Given the uncertainty surrounding estimates of the SCC, relying on any single study may 

be inadvisable since its estimate of the SCC will depend on many assumptions made by its 

authors. The Working Group II’s contribution to the Fourth Assessment Report of the IPCC 

notes that: 

The large ranges of SCC are due in the large part to differences in assumptions 

regarding climate sensitivity, response lags, the treatment of risk and equity, 

economic and non-economic impacts, the inclusion of potentially catastrophic 

losses, and discount rates.1

Because of this uncertainty, DOE previously used the SCC value from Tol (2005), which 

was presented in the IPCC’s “Fourth Assessment Report” and provided a comprehensive metaanalysis of estimates for the value of SCC. Tol released an update of his 2005 meta-analysis in 

September 2007 that reported an increase in the mean estimate of SCC from $43 to $71 per ton 

carbon. Although the Tol study was updated in 2007, the IPCC has not adopted the update. As a 

result, DOE previously decided to continue to rely on the study cited by the IPCC. DOE notes 

that the conclusions of Tol in 2007 are similar to the conclusions of Tol in 2005. In 2007, Tol 

continues to indicate that there is no consensus regarding the monetary value of reducing CO2

emissions by 1 ton. The broad range of values in both Tol studies are the result of significant 

differences in the methodologies used in the studies Tol summarized. According to Tol, all of 

 2005) from which this mean was derived did not report the year in which these dollars were denominated. However, 

we understand this estimate was denominated in 1995 dollars. 

b In contrast, most of the estimates of costs and benefits of increasing the efficiency of commercial packaged boilers 

include only economic values of impacts that would be experienced in the U.S. DOE generally does not consider 

impacts on manufacturers that occur solely outside of the United States. 

EERE-2008-BT-STD-0013 COMMENT 06
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the studies have shortcomings, largely because the subject is inherently complex and uncertain 

and requires broad multidisciplinary knowledge. Thus, it was not certain that the values reported 

in Tol in 2007 are more accurate or representative than the values reported in Tol in 2005. 

For the ASHRAE NOPR, DOE used the range of values based on the values presented in Tol 

(2005) as proposed. Additionally, DOE applied an annual growth rate of 2.4 percent to the value 

of SCC, as suggested by the IPCC Working Group II (2007, p. 822). This growth rate is based on 

estimated increases in damage from future emissions that published studies have reported. 

Because the values in Tol (2005) were presented in 1995$, DOE calculated more current values, 

assigning a range for SCC of $0 to $20 (2007$) per ton of CO2 emissions.

DOE believes that the most appropriate monetary values for consideration in the 

development of efficiency standards are those drawn from studies that attempt to estimate the 

present value of the marginal economic benefits likely to result from reducing greenhouse gas 

emissions, rather than estimates that are based on the market value of emission allowances under 

existing cap and trade programs or estimates that are based on the cost of reducing emissions—

both of which are largely determined by policy decisions that set the timing and extent of 

emission reductions and do not necessarily reflect the benefit of reductions. The marginal social 

cost of carbon is an estimate of the monetary value to society of the environmental damage of 

CO2 emissions. DOE also believes that the studies it relies upon generally should be studies that 

were the subject of a peer review process and were published in reputable journals. 

The upper bound of the range used by DOE is based on Tol (2005)2

In setting a lower bound of $0, DOE agrees with the IPCC Working Group II (2007) 

report that “significant warming across the globe and the locations of significant observed 

changes in many systems consistent with warming is very unlikely to be due solely to natural 

variability of temperatures or natural variability of the systems” (pp. 9), and, thus, tentatively 

concludes that a global value of zero for reducing emissions cannot be justified. However, DOE 

also believes that it is reasonable to allow for the possibility that the U.S. portion of the global 

cost of carbon dioxide emissions may be quite low. In fact, some of the studies looked at in Tol 

(2005) reported negative values for the SCC. DOE is using U.S. benefit values, and not world 

benefit values, in its analysis and, further, DOE believes that U.S. domestic values will be lower 

than the global values. Additionally, the statutory criteria in EPCA do not require consideration 

of global effects. Therefore, DOE is using a lower bound of $0 per ton of CO2 emissions in 

estimating the potential benefits.

, which reviewed 103 

estimates of the SCC from 28 published studies, and concluded that when only peer-reviewed 

studies published in recognized journals are considered, “that climate change impacts may be 

very uncertain but [it] is unlikely that the marginal damage costs of carbon dioxide emissions 

exceed $50 per ton carbon [comparable to a value of $20 per ton carbon dioxide when expressed 

in 2007$ with a 2.4 percent growth rate.]” 

The Department is well aware that scientific and economic knowledge about the 

contribution of CO2 and other green house gas (GHG) emissions to changes in the future global 

climate and the potential resulting damages to the world economy continues to evolve rapidly. 

Thus, any value placed in this rulemaking on reducing CO2 emissions is subject to likely change. 

DOE recognizes the importance of continuing to monitor current research on the potential 

economic damages resulting from climate change, and of periodically updating estimates of the 

EERE-2008-BT-STD-0013 COMMENT 06
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value of reducing CO2 emissions to reflect continuing advances in scientific and economic 

knowledge about the nature and extent of climate change and the threat it poses to world 

economic development. Further, DOE recognizes the interest and expertise of other Federal 

agencies, particularly the Environmental Protection Agency and the Department of 

Transportation, in terms of the issue of valuing the reductions in climate damages that are likely 

to result from those agencies’ own efforts to reduce GHG emissions. DOE will continue to work 

closely with those and other Federal agencies in the development and review of the economic 

values of reducing GHG emissions. 

Nitrogen Oxides (NOx) 

NOx emissions from 28 eastern States and the District of Columbia (D.C.) are limited 

under the Clean Air Interstate Rule, published in the Federal Register on May 12, 2005. 

Although the rule has been remanded to EPA by the D.C. Circuit, it will remain in effect until it 

is replaced by a rule consistent with the Court's opinion in North Carolina v. EPA (see TSD 

Chapter 8 for more complete discussion). All States covered by CAIR opted to reduce NOx 

emissions through participation in cap-and-trade programs for electric generating units; 

emissions from these sources are capped across the CAIR region. However, these emission caps 

do not address more disparate sources of NOx, including sources such as commercial packaged 

boilers. As such, NOx emissions from commercial packaged boilers for which DOE is setting 

efficiency standards are largely unregulated. Accordingly, DOE estimated the national 

monetized benefits of NOx reductions associated with this rulemaking, based on environmental 

damage estimates from the literature. Available estimates suggest a very wide range of monetary 

values for NOx emissions, ranging from $370 per metric ton to $3,800 per metric ton of NOx

from stationary sources, measured in 2001$,3

Sulfur Dioxide (SO2) 

or a range of $432 per metric ton to $4,441 per 

metric ton in 2007$. 

As with NOx, although regulations on SO2 emissions for power plants currently exist, 

there are no national regulations limiting SO2 emissions from relatively small and disparate 

sources such as oil-fired commercial packaged boilers. 

SO2 causes a wide variety of health and environmental impacts because of the way it 

reacts with other substances in the air. Direct human health effects, including respiratory effects, 

can be caused by SO2 or by sulfate particles derived from the presence of SO2 in the atmosphere. 

Damage to vegetation and water resources can result from acid rain and subsequent acidification 

of the terrestrial and aquatic environments. Aesthetic damages to building materials and visibility 

impairment can also result. All of these result in damages to the environment that have a 

monetary impact. Environmental damage from SO2 emissions is dependent on the location of the 

emission and subsequent location of the environmental impact. 

DOE conducted research to provide an estimate of the ranges of monetized benefits that 

could be attributed to the reduction of SO2 emissions from commercial packaged boilers based 

on a range of estimates. At one end, DOE used the annual estimates of an SO2 trading price as 

developed in the National Energy Modeling System (NEMS) electricity market model for the 

western and eastern U.S. This model estimates a trading price for SO2 in the utility markets, and 

EERE-2008-BT-STD-0013 COMMENT 06
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while not directly applicable to commercial packaged boilers, does reflect a market value for the 

cost of reducing SO2 emissions into the atmosphere. As DOE is interested in a national estimate, 

it used a simple average of the trading prices from the eastern and western electricity market 

models for the period from 2012-2030, and extrapolated the prices out through 2042. 

These range in SO2 costs from this source varied both by year and region from $86 to $1,012 

(2007$). At the higher end, DOE used an estimate of environmental damage costs of $7,300 per 

metric ton of SO2 from stationary sources, measured in 2001$e,4

The resulting estimates of the potential range of the present value of monetary benefits 

associated with the national reduction of CO2, NOx and SO2 emissions resulting from adoption of 

standards for commercial packaged boilers at the ASHRAE 90.1-2007 efficiency levels are 

shown by equipment class in 

or $8,542 per metric ton in 

2007$. These low and high values were in turn multiplied by the emission of SO2 estimated for 

the period from 2012-2042. 

Table 9.2.1 (7 percent discount rate) and Table 9.2.2 (3 percent 

discount rate). As with the energy emission benefits discussed previously, these are benefits 

calculated against the market baseline.

Table 9.2.1 Cumulative Present Value for Emissions Reductions from Commercial 

Boilers from 2012 to 2042 for Adopting ASHRAE Standard 90.1-2007 over the Market 

Baseline, Seven Percent Discount Rate

Equipment Class

Cumulative National Emissions Impact from 2012 to 2042

CO2 

(Thousand 2007$) 

NOx 

(Thousands 2007$) 

SO2 

(Thousands 2007$) 

Low High Low High Low High

Small, Gas-fired, Hot Water $0 $4,716 $95 $983 $0 $0 

Small, Gas-fired, Steam, All Except natural 

Draft $0 $215 $4 $45 $0 $0 

Small, Gas-fired, Steam, Natural Draft $0 $12,153 $230 $2,366 $0 $0 

Small, Oil-fired, Hot Water $0 $4,735 $68 $699 $254 $4,651 

Small, Oil-fired, Steam $0 $2,284 $33 $337 $122 $2,243 

Large, Gas-fired, Hot Water $0 $2,068 $42 $431 $0 $0 

Large, Gas-fired, Steam, All Except 

Natural Draft $0 $1,235 $25 $257 $0 $0 

Large, Gas-fired, Steam, Natural Draft $0 $8,716 $157 $1,615 $0 $0 

Large, Oil-fired, Hot Water $0 $0 $0 $0 $0 $0 

Large, Oil-fired, Steam $0 $0 $0 $0 $0 $0 

EERE-2008-BT-STD-0013 COMMENT 06
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Table 9.2.2 Cumulative Present Value for Emissions Reductions from Commercial 

Boilers from 2012 to 2042 for Adopting ASHRAE Standard 90.1-2007 over the Market 

Baseline, Three Percent Discount Rate

Equipment Class

Cumulative National Emissions Impact from 2012 to 2042

CO2 

(Thousand 2007$) 

NOx 

(Thousands 2007$) 

SO2 

(Thousands 2007$) 

Low High Low High Low High

Small, Gas-fired, Hot Water $0 $11,368 $218 $2,242 $0 $0 

Small, Gas-fired, Steam, All 

Except natural Draft $0 $518 $10 $102 $0 $0 

Small, Gas-fired, Steam, 

Natural Draft $0 $32,087 $582 $5,995 $0 $0 

Small, Oil-fired, Hot Water $0 $11,415 $155 $1,594 $549 $10,609 

Small, Oil-fired, Steam $0 $5,505 $75 $769 $265 $5,116 

Large, Gas-fired, Hot Water $0 $4,985 $95 $983 $0 $0 

Large, Gas-fired, Steam, All 

Except Natural Draft $0 $2,978 $57 $587 $0 $0 

Large, Gas-fired, Steam, 

Natural Draft $0 $24,399 $428 $4,408 $0 $0 

Large, Oil-fired, Hot Water $0 $0 $0 $0 $0 $0 

Large, Oil-fired, Steam $0 $0 $0 $0 $0 $0 

In addition, DOE developed estimates of the potential range of the present value of 

monetary benefits associated with the national reduction of CO2, NOx, and SO2 emissions 

resulting from adoption of standards higher than the ASHRAE Standard 90.1-2007 efficiency 

levels. These estimates are shown by equipment class in Table 9.2.3 (7 percent discount rate) and 

Table 9.2.4 (3 percent discount rate). 

EERE-2008-BT-STD-0013 COMMENT 06
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9-8

Table 9.2.3 Cumulative Present Value of National Emissions Reductions for Commercial Boilers from 2

Adoption of Analyzed Higher Standards over ASHRAE 90.1-2007 Baseline, Seven Percent Discount Rate 

Equipment Class

Cumulative Value of National Emissions Reductions from 2012 to 2042 (Thousand 2007

Efficiency Level 1 Efficiency Level 2 Efficiency Level 3 

CO2 NOx SO2 CO2 NOx SO2 CO2 NOx SO2 

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Small, Gas-fired, Hot Water 0 -

8,091

157 -

1,618

0 -

0 

0 -

27,056

157 -

1,618

0 -

0 

0 -

52,820

1,039 -

10,710

0 -

0 

Small, Gas-fired, Steam, All Except 

natural Draft

0 - 

(32)

( 1) - 

(8)

0 - 

0

0 - 

5,371

( 1) - 

(8)

0 - 

0

0 - 

11,226

221 - 

2,280

0 - 

0

Small, Gas-fired, Steam, Natural Draft 0 -

(1,235)

( 13) -

(137)

0 -

0 

0 -

6,933

( 13) -

(137)

0 -

0 

0 -

16,885

344 -

3,546

0 -

0 

Small, Oil-fired, Hot Water 0 -

7,713

106 -

1,091

384 -

7,263

0 -

17,324

106 -

1,091

877 -

16,470

0 -

29,099

405 -

4,169

1,480 -

27,750 

Small, Oil-fired, Steam 0 -

4,658

64 -

661

233 -

4,401

0 -

13,580

64 -

661

691 -

12,948

0 -

34,913

487 -

5,015

1,785 -

33,384 

Large, Gas-fired, Hot Water 0 - 

5,312

104 - 

1,068

0 - 

0

0 - 

13,962

104 - 

1,068

0 - 

0

0 - 

23,023

453 - 

4,668

0 - 

0

Large, Gas-fired, Steam, All Except 

Natural Draft

0 -

8,161

160 -

1,652

0 -

0 

0 -

23,784

160 -

1,652

0 -

0 

0 -

39,671

782 -

8,056

0 -

0 

Large, Gas-fired, Steam, Natural Draft 0 - 

(6,793)

( 117) - 

(1,207)

0 - 

0

0 - 

2,074

( 117) - 

(1,207)

0 - 

0

0 - 

13,520

285 - 

2,938

0 - 

0

Large, Oil-fired, Hot Water 0 -

6,962

97 -

1,002

357 -

6,669

0 -

12,279

97 -

1,002

630 -

11,762

0 -

17,472

244 -

2,514

896 -

16,737 

Large, Oil-fired, Steam 0 -

20,280

283 -

2,919

1,040 -

19,427

0 -

54,700

283 -

2,919

2,805 -

52,400

0 -

102,301

1,429 -

14,723

5,246 -

97,999

*Negative values, shown in parentheses, indicate emissions savings over the base case

**na indicates that the equipment class did not have an Efficiency Level 4
ASHRAE_90 1-2007_TSD(EnvMonet)_05-22-09v3.doc

9-9

Table 9.2.4 Cumulative Present Value of National Emissions Reductions for Commercial Boilers from 2

Adoption of Analyzed Higher Standards over ASHRAE 90.1-2007 Baseline, Three Percent Discount Rate

Equipment Class

Cumulative Value of National Emissions Reductions from 2012 to 2042 (Thousand 2

Efficiency Level 1 Efficiency Level 2 Efficiency Level 3 

CO2 NOx SO2 CO2 NOx SO2 CO2 NOx SO2 

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low -

High $

Low 

High 

Small, Gas-fired, Hot Water 0 -

20,503

381 -

3,928

0 -

0 

0 -

67,647

1,267 -

13,060

0 -

0 

0 -

131,692

2,471 -

25,466

0 -

0 

Small, Gas-fired, Steam, All Except 

natural Draft

0 -

(63)

( 1) -

(14)

0 -

0

0 -

13,368

251 -

2,588

0 -

0

0 -

27,923

525 -

5,407

0 -

0

Small, Gas-fired, Steam, Natural Draft 0 -

(5,128)

( 73) -

(752)

0 -

0

0 -

15,176

309 -

3,181

0 -

0

0 -

39,916

774 -

7,973

0 -

0 

Small, Oil-fired, Hot Water 0 -

19,563

257 -

2,652

890 -

17,654

0 -

43,455

575 -

5,929

2,002 -

39,465

0 -

72,727

965 -

9,944

3,363 

66,18

Small, Oil-fired, Steam 0 -

11,767

155 -

1,599

538 -

10,643

0 -

33,945

450 -

4,641

1,570 -

30,891

0 -

86,976

1,156 -

11,914

4,037 

79,30

Large, Gas-fired, Hot Water 0 -

13,374

250 -

2,572

0 -

0 

0 -

34,878

654 -

6,737

0 -

0 

0 -

57,403

1,077 -

11,100

0 -

0 

Large, Gas-fired, Steam, All Except 

Natural Draft

0 -

20,390

382 -

3,938

0 -

0

0 -

59,225

1,112 -

11,461

0 -

0

0 -

98,717

1,854 -

19,111

0 -

0

Large, Gas-fired, Steam, Natural Draft 0 -

(19,929)

( 340) -

(3,505)

0 -

0

0 -

1,964

73 -

753

0 -

0

0 -

30,225

607 -

6,251

0 -

0

Large, Oil-fired, Hot Water 0 -

17,306

230 -

2,374

805 -

15,799

0 -

30,522

406 -

4,186

1,420 -

27,865

0 -

43,432

578 -

5,957

2,020 

39,65

Large, Oil-fired, Steam 0 - 

50,414

671 - 

6,914

2,345 - 

46,024

0 - 

135,977

1,810 - 

18,650

6,326 - 

124,138

0 - 

254,305

3,384 - 

34,879

11,83

232,1

*Negative values, shown in parentheses, indicate emissions savings over the base case

**na indicates that the equipment class did not have an Efficiency Level 4
9-10

ASHRAE_90 1-2007_TSD(EnvMonet)_05-22-09v3.doc

REFERENCES

1 Intergovernmental Panel on Climate Change IPCC, Climate Change 2007 – Impacts, 

Adaptation and Vulnerability Contribution of Working Group II to the Fourth Assessment 

Report of the IPCC, 17 (2007) (Last accessed August 7, 2008) <http://www.ipcc-wg2.org>.

2 Tol, Richard S.J., “The marginal damage costs of carbon dioxide emissions: an assessment of 

the uncertainties,” 33 Energy Policy (2005), pp. 2064-74.

3 Office of Management and Budget, Office of Information and Regulatory Affairs, 2006 

Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded 

Mandates on State, Local, and Tribal Entities (2006) (Last accessed March 2009) 

<http://www.whitehouse.gov/omb/inforeg/regpol-reports_congress.html>.

4 U.S. Environmental Protection Agency, NSR 90-Day Review Background Paper, Docket A2001-19, Document II-A-01 (2001) (Last accessed March 2009) 

<http://www.epa.gov/nsr/documents/nsr-review.pdf>. 

ABBREVIATIONS AND ACRONYMS

ASHRAE American Society of Heating, Refrigerating and Air-Conditioning 

CAIR Clean Air Interstate Rule

CFR Code of Federal Regulations 

CO2 Carbon Dioxide 

DOE U.S. Department of Energy 

EIA Energy Information Administration

EPA Environmental Protection Agency 

EPCA Energy Policy and Conservation Act of 1975 

GHG Green House Gas

IPCC Intergovernmental Panel on Climate Change 

LCC Life-Cycle Cost

N2 Nitrogen

NEMS National Energy Modeling System

NEMS-BT National Energy Modeling System-Building Technologies version 

NEPA National Environmental Policy Act

NO2 Nitrogen Dioxide

NOx Nitrous Oxides 

NODA Notice of Data Availability 

NOPR Notice of Proposed Rulemaking 

EERE-2008-BT-STD-0013 COMMENT 06
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ASHRAE_90 1-2007_TSD(EnvMonet)_05-22-09v3.doc

NPV Net Present Value

NSPS New Source Performance Standards

OMB Office of Management and Budget

O3 Ozone 

SCC Social Cost of Carbon 

SO2 Sulfur Dioxide 

TSD Technical Support Document 

EERE-2008-BT-STD-0013 COMMENT 06