ENVIRONMENTAL ASSESSMENT FOR PR OPOSED ENERGY CONSERVATION STANDARDS FOR RESIDENTIAL DISH WASHERS, DEHUMIDIFIERS, AND COOKING PRODUCTS, AND COMMERCIAL CLOTHES WASHERS

TABLE OF CONTENTS

1.0 INTRODUCTION

........................................................................................................ EA-1 2.0 METHODOLOGY

....................................................................................................... EA-2 3.0 RESULTS

.................................................................................................................... . EA-3

EA-iENVIRONMENTAL ASSESSMENT FOR PR OPOSED ENERGY CONSERVATION STANDARDS FOR RESIDENTIAL DISHWA SHERS, DEHUMIDIFIERS, COOKING PRODUCTS, AND COMMERCIAL CLOTHES WASHERS

1.0 INTRODUCTION
The Department of Energy (DOE) will conduct anenviron mental assessment as part of the notice of proposed rulemaking. DOE w ill assess the impacts of proposed energy conservation standards for residential dishwash ers, dehumidifiers, and cooking products and commercial clothes washers on certain environmen tal indicators using a variant of the U.S. DOE/Energy Information Administration (EIA)’ s National Energy Modeling System (NEMS). a EIA uses NEMS to produce the Annual Energy Outlook (AEO). 1 DOE will use a variant known as NEMS-BT to provide key inputs to the analysis, based on the 2007 version of the AEO ( AEO2007 ). Results of the environmental assessment will be similar to those provided in AEO2007

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DOE intends the environmental assessment to provide emissions results to policymakers and other stakeholders, and to fulfill requirement s that the environmental effects of all new Federal rules be properly quantified and consid ered. The environmental assessment considers three pollutants— su lfur dioxide (SO 2 ), nitrogen oxides (NO x ), and mercury—as well as carbon emissions. The only form of carbon emissions tracked by NEMS-BT is carbon dioxide (CO 2 ), so the carbon discussed in this repo rt is only in the form of CO 2 . For each of the trial standard levels, DOE will calculate total emissions using NE MS-BT, using additional, external analysis as needed.

Although DOE plans to consider only SO 2 , NO x , mercury, and CO 2 in its environmental assessment, there are other air pollutants which ar e of concern. Specifically, the Clean Air Act requires the Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards for the following six common air pollutants, also know as “crit eria pollutants”: (1) ozone, (2) particulate matter (PM), (3) carbon m onoxide (CO), (4) nitrogen dioxide, (5) SO 2 , and (6) lead. 2 EPA recently added to this list mercury. But none of the “criteria pollutants” not already considered (i.e., ozone, PM, CO, and l ead) are driven significantly by either electric utility power plants or fuel-fir ed appliances. Therefore, DOE does not intend on addressing them in the environmental assessment. In the case of ozone and particulate matter, other pollutants are precursors to their formation and atmospheric c onditions are the driver behind their formation. Also, SO 2 and NO x are the primary precursors to ozone and PM, respectively, and will already be addressed by the environmental assessment. In the case of CO, electric utilities and fuel-fired appliances are not significant sources. For electric power plants, almost all carbon emissions come out in the form of CO 2 as the combustion process is lean enough not to yield CO in significant amounts. For fuel-fir ed appliances, proper appliance maintenance, installation, and

a For more information on NEMS, please refer to th e U.S. Department of Energy, Energy Information Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000

, DOE/EIA-0581(2000), March 2000. EIA approves use of the name NEMS to describe only an official version of the model without any modification to code or data. Because this analysis entails some minor code modifications and the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model as NEMS-BT (BT is DOE’s Building Technologies Pr ogram). NEMS-BT was previously called NEMS-BRS.

EA-1use can prevents dangerous leve ls of CO. A well-designed and properly functioning heating or cooking appliance should not produce toxic or lethal levels of CO, as, most often, CO poisoning occurs in the home as a result of malfunctioning appliances. Finally, with regard to lead, the ban on the use of leaded gasoline has resulted in a dram atic decrease in lead emissions since the mid 1970s. Now industrial processes (not electric utilities), particular ly primary and secondary lead smelters and battery manufacturers, are responsibl e for most of lead emissions and all violations of the lead air quality standards.

2.0 METHODOLOGY

DOE will conduct the environmental assessm ent as a policy d eviation from the AEO2007 , using the same basic set of assumptions. For example, the emissions characteristics of an electricity generating plant will be exactly those used in AEO2007 . The NEMS reference case and alternative growth scenarios are as descri bed in the utility impact analysis (see Chapter 13 of the technical support document).
NEMS-BT tracks carbon emissions using a detailed carbon m odule; this approach provides good results because of its broad coverage of all sector s and inclusion of interactive effects. Past experience withcarbon results from NEMS sugge sts that the NEMS-generated emissions estimates are somewhat lower than estimates based on simple average factors. One of the reasons for this divergence is that NEMS tends to predict that conservation displaces renewable generating capacity in the later year s of its forecast. On the whole, NEMS-BT provides carbon emissions results of reasonable accuracy, at a level consistent with other published Federal results.
The NEMS-BT model reports the two airborne pollutant emissions that DOE has reported in past analyses, SO 2 and NO x . The Clean Air Act Amendments of 1990 set an SO 2 emissions cap on all power generation. 3 The attainment of this target, however, is flexible among generators through the use of emissions allowan ces and tradable permits. The NEMS-BT model includes a module for SO 2 allowance trading and delivers a forecast of SO 2 allowance prices. Accurate simulation of SO 2 trading tends to imply that physical emissions effects will be zero, as long as emissions are at th e ceiling. There is an SO 2 benefit from conservation in the form of a lower allowance price but, since the impact of any one standard on the allowance price is likely small and highly uncertain, DOE does not plan to monetize the SO 2 benefit.

NEMS-BT also has an algorithm for estimating NO Xemissions from power generation. The impact of these emissions, however, will be affected by the Clean Air Interstate Rule (CAIR), which the U.S. Environmental Prot ection Agency (EPA) issued on May 12, 2005. 4 CAIR will permanently cap emissions of NO x in 28 eastern States and th e District of Columbia. As with SO 2 emissions, a cap on NO X emissions means that equipment efficiency standards may have no physical effect on these emissions. When NO x emissions are subject to emissions caps, DOE’s emissions reduction estimate corresponds to incremental changes in the prices of emissions allowances in cap-and-trade emissi ons markets rather than physical emissions reductions. Therefore, while th e emissions cap may mean that physical emissions reductions will not result from standards, standards could produce an environmental-related economic benefit in the form of lower prices for emissi ons allowance credits. However, as with SO 2

EA-2allowance prices, DOE does not plan to monetize this benefit because the impact on the NO x allowance price from any single energy conser vation standard is likely small and highly uncertain.

While NEMS-BT contains provisions for estimating emissions of CO 2 , NO x , and SO 2 from power generation, it does not estimate emissions from gas appliances (e.g., gas water heaters used to heat water for commercial clothes washers and residential dishwashers, and gas cooking products). Therefore, DOEplans to conduct an analysis that includes separate estimates of the effect of energy conservation standards on CO 2 , NO x , and SO 2 emissions from gas appliances, based on simple emissions factors derived from the literature. 5 Although household NO x and SO 2 emissions savings will be small, DOE w ill report them because the emissions caps do not apply to the residential sector.

With regard to mercury emissions, NEMS has an algorithm for estimating these

emissions from power generation. However, the impact on mercury emissions will be affected by the Clean Air Mercury Rule (CAMR), which the EPA issued on May 18, 2005. 6 CAMR will permanently cap emissions of mercury for new and existing coal-fired plants in all States. As with SO 2 and NO x emissions, a cap on mercury emissions means that equipment efficiency standards may have no physical effect on these emissions. When mercury emissions are subject to emissions caps, DOE’s emissions reduction es timate corresponds to incremental changes in the prices of emissions allowances in cap-and -trade emissions markets rather than physical emissions reductions. Therefore, while the emissions cap may mean that physical emissions reductions will not result from standards, sta ndards could produce an environmental-related economic benefit in the form of lower prices for mercury emissions allowance credits. However, as with SO 2 and NO x allowance prices, DOE does not plan to monetize this benefit because the impact on the mercury allowance price from any single energy conservati on standard is likely small and highly uncertain.

3.0 RESULTS

The results for the environmental assesssment are similar to a complete NEMS run, as published in the AEO2007 . These include emissions for SO 2 , NO x , mercury, and CO 2 in fiveyear forecasted increments, extrapolated to th e year 2042. DOE will report the outcome of the analysis for each trial standard level as a deviation from the AEO2007 reference case results.

EA-3REFERENCES

1 U.S. Department of Energy- Energy Inform ation Administration. Annual Energy Outlook 2007 with Projections to 2030 , February, 2007. Washington, DC. DOE/EIA-0383(2007).

2 U.S. Environmental Protection Agency. Six Common Air Pollutants . Washington, DC.

< http://www.epa.gov/air/urbanair/ >

3 U.S. Environmental Protection Agency. Clean Air Act . Washington, DC.

< http://www.epa.gov/air/caa/ >

4 U.S. Federal Register. Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to A cid Rain Program; Revisions to the NOX SIP Call, Final Rule , May 12, 2005. 70 FR 25162.

5 U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, AP42, Fifth Edition, Volume I: St ationary Point and Area Sources . 1998. (Posted October) <http://www. epa.gov/ttn/chief/ap42.html>

6 U.S. Federal Register. Standards of Performance for Ne w and Existing Stationary Sources: Electr ic Utility Steam Generating Units, Final Rule , May 18, 2005. 70 FR 28606.

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