Table 12. Cumulative Power Sector and Household Emission Reductions for High & Low Economic Growth Sensitivities to 2030 Shipment Drop AE099 Low Economic Growth AE099 Reference Economic Growth AE099 High Economic Growth MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF) Carbon(Mt) 93.8 95.1 9.6 NO,, (kt) 292.7 253.5 2485 S02(kt)

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Table 13. Cumulative Power Sector and Household Emission Reduction with Elasticity Sensitivities to 2030 Shipment Drop Sensitivity

Price / Income = medium Price Elasticity = none Reference Case Price Elasticity = medium PriceIIncome = none Sensitivity Price Elasticity = high PriceIIncome = none
MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF) Carbon (Mt) 97.3 95,] 94.4 NO(kt) 256.2 253.5 254.3 S02(kt) 28.7 ] 276

5.2 Water Resources
The measurement of the MEF and the DOE minimum efficiency level do not have as a condition a set maximum water usage. However, energy savings are often achieved by reducing the hot water consumption and in some cases the total water consumption for a wash cycle. Table 14 lists the cumulative reduction in water use through 2020 for each of the efficiency levels. Water savings are based on the results of a manufacturer questionnaire detailing energy and water use of clothes washers under the various efficiency standard scenarios.

EA- 19Table 14. Cumulative Reduction in Water Use to 2030 MEF Parameter 0.86 0.908 0.961 1.021 1.089 1.257 1.362 1.485 1.634 1.04 in 2004 1.26 in 2007 TSL 1 TSL 2 TSL 4 TSL 5 TSL 6 TSL 3 (PROPOSED MEF)
Trillion 0.41 0.41 0.41 0.53 9.09 12.9 12.9 10.9 10.9 11.59 Gallons
The proposed standard would result in significant water savings which amounts to 11.59 trillion gallons through the period 2004 - 2030. This means less water needs to be pumped from U.S. aquifers and rivers, and less strain on many of the nation's overtaxed water and sewer systems. The standards will save enough in less use water to supply the needs of 7.3 million households for 25 years (based on indoor water use). Results of a sensitivity analysis for high and low economic growth and high and low forecasts of price elasticity (i.e., number of washer shipments) are shown below in Tables 15 and 16.

Table 15. Cumulative Water Reduction for High & Low Economic Growth Sensitivities to 2030 Shipment Drop AE099 Low Economic AE099 Reference Economic AE099 High Economic Growth Growth Growth MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF) Trillion Gals Water 11.58 11.59 11.59

Table 16. Cumulative Water Reduction with Elasticity Sensitivities to 2030 Shipment Drop Price / Income = medium Reference Case Price Elasticity =high Price Elasticity = none Price Elasticity = PriceIIncome =none medium Price / Income = none MEF = 1.04 in 2004 & 1.26 in 2007 (PROPOSED MEF) Trillion Gals Water 11.8 11.59 11.5

EA-205.3 WetlandsIEndangered and Threatened Species / Cultural Resources

As this action is not a site-specific action, nor would it change land disturbance due to clothes washer placement, impacts to these resources are not expected. Therefore, this action is not expected to impact the quality of wetlands, or threatened or endangered species, although lowered national water use and reduced air pollution could have a positive impact, if any at all. This action is not expected to impact cultural resources such as historical or archaeological sites. 5.4 Socioeconomic Impacts Analysis has shown that the possible increase in the first cost of purchasing a more efficient clothes washer is on average offset by a reduction in the life-cycle cost of owning a more efficient washer. This is true for every standard level considered. Although the proposed standard may increase the initial cost of a clothes washer, the proposed standard level has a decrease in life-cycle cost (due to reduced energy and water costs) for 90% of consumers at the first stage in 2004 and for 80% of consumers at the second level of the standard becoming effective in 2007. See chapter 7 and Appendix G of the TSD for details.

5.5 Environmental Justice Impacts The proposed action, a new minimum efficiency standard for clothes washers, would not cause any adverse environmental impacts, and therefore would not cause any disproportionately high and adverse human health or environmental impacts. Positive impacts, such as decreased air emissions and water conservation, would be equally shared among all populations. However,the department did conduct a consumer utility analysis that looked at economic impacts to lowincome and elderly populations. For a complete discussion see chapter 8 and Appendix K of the TSD at the DOE internet site at http://www.eren.doe.govlbuildings/codes_standards/applbrf/clwasher.html. 5.6 Energy Consumption Impacts The proposed standard level of a 1.04 MEF in 2004 and a second higher level of 1.26 MEF in 2007 (TSL 3) would result in the energy savings through the year 2030 shown in Table 17, when compared against the no-action alternative.

EA-21Table 17. Cumulative Energy Savings for Trial Standard Level 3 (Proposed MEF) Cumulative Energy Savings in Quads Total Electric Gas Oil LPG from2004 to 2010 0.39 0.23 0.14 0.01 0.01 to 2020 2.51 1.47 0.93 0.06 0.05 To 2030 5.52 3.23 2.05 0.14 0.1

5.7 Summary of Environmental Impacts This BA provides information on the effects new clothes washer standards would have on pollutants and other emissions as well as on water use. Analysis of carbon and NO emissions from the power sector and households indicates that each of the proposed trial standard levels would have a positive impact on the environment. Cumulative power sector and household emissions reductions through 2020 for the proposed standards range from 2.5-65 Mt for carbon and 8.4-210 kt for NOR. Through 2030, the cumulative emissions reductions range from 5.1-135 Mt for carbon and 14.4-364 kt of NOR. The reduction in SO2 emissions ranges from 0.6-15.5 kt through 2020 and from 1.2-31.4 kt through 2030. The corresponding reduction in water use through 2030 ranges from 0.4 1-12.94 trillion gallons of water. The major stakeholders, including manufacturers and energy efficiency advocates, have jointly submitted a proposed clothes washer efficiency standard to DOE that they both feel is technically feasible and economically justified. The proposed standard, which is the Department's proposed action for purposes of this EA, would go into effect in two stages. The proposed standard level of a 1.04 MEF (Modified Energy Factor) in 2004 and a second higher level of 1.26 MEF in 2007 would have the following cumulative reductions in emissions. By the year 2025, the annual reduction in fuel needed to generate electricity will be equivalent to the amount needed to run five large coal-fired power plants. (This is equivalent to an annual savings of 0.18 quads of source energy, 0.086 quads of site energy or 24 Tera watt-hours (TWh) of electricity sales). The proposed standard will save enough electricity to light 16 million U.S. homes for 25 years, while cutting greenhouse gas emissions by an amount equal to that produced by three million cars every year. The proposed standard has significant environmental benefits. Cumulative emissions reductions through 2030 are 95.1 Mt (million metric tons) for carbon, 253.5 kt (thousand metric tons) for NOR, 28.1 kt for SO2. Water use reductions are 11.59 trillion gallons cumulative to 2030. This means less water needs to be pumped from America's aquifers and rivers, and less strain on many of the nation's overtaxed water and sewer systems. The standards will save enough water to supply the indoor water usage needs of 7.3 million households for 25 years.

EA-22REFERENCES

U.S. Department of Energy-Office of Building Research and Standards, Technical Support Document: Energy Efficiency Standards for Consumer Products: Clothes Washers, September, 2000. Washington, DC.
2. Title, Code of Federal Regulations, Part 430, Docket No. EE-RM-94-403, RIN 1904- AA67, Energy Conservation Program for Consumer Products: Clothes Washer Energy Conservation Standards; Proposed Rule, October5, 2000, Federal Register. 3. U.S. Department of Energy - Energy Information Administration, Annual Energy Outlook 1999: With Projections Through 2020, December, 1998. Washington, DC. Report No. DOE/EIA-03 83(99). <http://www.eia.doe.govfoiaf/aeo99/homepage.html>

EA-23APPENDIX EA.1. EMISSION FACTORS FOR COMBUSTION FROM NATURAL GAS,

LPG, AND OIL-FIRED RESIDENTIAL WATER HEATERS AND CLOTHES DRYERS

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................ TABLE OF CONTENTS

EA-1 OVERVIEW EA.1-1 EA-2 EMISSIONS FACTORS BY FUEL TYPE EA.1-2 EA-2.1 All Fuels: Carbon EA.l-2 EA-2.2 Natural Gas EA.l-2

EA-2.2.1 Oxides of Nitrogen EA.1-2 EA-2.2.2 Sulfur Dioxide EA. 1-3 EA-2.3 Fuel Oil #2 EA.1-3

EA-2.3.1 Oxides of Nitrogen EA.1-3 EA-2.3.2 Sulfur Dioxide EA.l-3 EA-2.4 LPG EA.1-4

EA-2.4.1 Oxides of Nitrogen EA.l-4 EA-2.4.2 Sulfur Dioxide EA.1-5 EA-3 SUMMARY EA.1-5 LIST OF TABLES Table EA- 1.1 Estimated National Average Emission Factors for Household Fuel

Combustion of Natural Gas, Fuel Oil #2, and LPG EA.1-2

EA.1-iAPPENDIX EA-1. EMISSION FACTORS FOR COMBUSTION FROM NATURAL GAS,

LPG, AND OIL-FIRED RESIDENTIAL WATER HEATERS AND CLOTHES DRYERS EA-1 OVERVIEW The modified version of the National Energy Modeling System (NEMS) used for the appliance energy efficiency standards analysis, called NEMS-BRS, comprehensively considers a wide range of aspects of energy use.a However, this model does not consider household emissions of SO2 and NO from the combustion of natural gas, heating fuel oil #2 (i.e., high-sulfur distillate fuel oil), and liquefied petroleum gas (LPG). Because an efficiency standard could result in changes in these emissions, the Department has performed some elementary research to determine appropriate emission factors for carbon, sulfur dioxide (SO2), and oxides of nitrogen (NO) from household appliances. Specifically, this work focuses on emission rates from the use of water heaters and clothes dryers and is used to calculate emissions savings from proposed efficiency standards on clothes washers. This analysis attempts to verify that the emissions factors from the U.S. Environmental Protection Agency (EPA) for carbon, SO2, and NO from natural gas, fuel oil, and LPG combustion are representative of the U.S.' The EPA cautions against the use of these emissions factors as representative of actual emissions. Rather, they are to be used, and are used here, as general approximations of national average emissions factors in order to calculate emissions savings that result from proposed water heater or clothes washer energy-efficiency standards. This analysis compares EPA's emissions factors with those from other sources and with regional regulations. Table EA- 1 summarizes the emissions factor estimates for the three fuels of interest. The values presented here are based on EPA' s assessment of combustion emissions (with the exception of SO2 from LPG, see discussion below). These emissions estimates represent an approximate emissions factor for the U.S. as a whole. They are used, together with estimated energy savings, to calculate end-use site emissions savings. The emissions factors discussed in this analysis are represented as mass, grams (g) or kilograms (kg), of the specific emission of interest per gigajoule (GJ) of energy input to the water heater or clothes washer." There are significant differences in state regulations, making it difficult to generalize about localized emissions. For residential fuel oil combustion, stricter state standards exist in the northeastern United States and southern California than elsewhere. State and local agencies like

aFor more information on NEMS, please refer to the U.S. Department of Energy, Energy Information Administration documentation. A useful summary isNational Energy Modeling System. An Overview 1998, DOE/EIA-058 1(98), February 1998. DOE/ETA approves use of the name NEMS to describe only an official version of the model without any modification to code or data. Because our analysis entails some minor code modifications and the model is run under policy scenarios that are variations on DOE/ETA assumptions, the name NEMS-BRS refers to the model as used here (BRS is DOE's Building Research and Standards office, under whose aegis this work has been performed). b 0.454 kg = 1 pound (lb); 1.055 GJ = 1 million British thermal units (MBtu)
EA. 1-1southern California's South Coast Air Quality Management District (SCAQMD), the New Jersey

Department of Environmental Protection, and the New York Department of Environmental Conservation have established regulations for residential fuel combustion emissions. These regulations, however, are local to individual counties and do not apply to all regions in the Northeast or even all of California. Table EA-1.l Estimated National Average Emission Factors for Household Fuel

Combustion of Natural Gas, Fuel Oil #2, and LPG

___________________ Carbon (kgIGJ) SO2 (gIGJ) NO, (g/GJ) Natural Gas 13.8 0 42 HeatingFuelOil#2 18.7 218 61
LPG 16 7.2 66
EA-2 EMISSIONS FACTORS BY FUEL TYPE EA-2.1 All Fuels: Carbon NEMS-BRS tracks emissions of carbon as C02, but factors are included here for completeness. The combustion of natural gas, fuel oil #2, and LPG oxidizes virtually all carbon in the fuel to CO2. This facilitates estimating carbon emissions factors because the carbon content of the fuel is the only determinant of emissions. The carbon estimates in Table EA- 1.1 are based on EPA's assessment of carbon combustion from natural gas, fuel oil #2, and LPG use. Other sources of information include the U.S. DOE' s Energy Information Administration (EIA), Oregon State EPA, and the Gas Research Institute (GRJ). All agree to within ± 2.0 % of EPA's assessed estimate of carbon emissions. EPA's carbon emissions factors for natural gas, fuel oil #2, and LPG combustion are therefore a reasonable evaluation of nationally averaged carbon emissions rates. Carbon monoxide (CO) can be formed by incomplete carbon oxidization, causing a severe health hazard. CO emissions only result from poorly ftmctioning appliances, and since NEMS-BRS assumes that all water heaters or clothes washers are functioning properly, it is unlikely that these emissions will change. EA-2.2 Natural Gas EA-2.2.1 Oxides of Nitrogen Emissions of NO that result from the combustion of natural gas from appliances are also covered by regulations in some jurisdictions. The EPA's estimated NO emissions factor of 42 g/GJ from gas-fired water heaters or clothes washers is equal to the regulation set by the state of New York. This is approximately 20% higher than the strict standard set by the South Coast Air Quality
EA. 1-2Management District (SCAQMD). The SCAQMD provides extensive research into emissions

factors2 and California regulations tend to influence many other states. New Jersey is the only other state that is known to have NO emissions regulations for water heaters, with a limit of 86g of NO/GJ of heat input. The absence of regulations in other states suggests that most have emissions rates comparable to U.S. EPA's estimated value. EA-2.2.2 Sulfur Dioxide SO2 emissions from natural gas combustion are assumed to be zero. EA-2.3 Fuel Oil #2 EA-2.3.1 Oxides of Nitrogen N0 formation in combustion processes is significantly more complex than SO2 or CO2. N0 can result from oxidization of N2 in the fuel, but the larger source is N2 in the combustion intake. This process is sensitive to combustion chemistry, and therefore, quite variable. It also implies that appliance design can lower N0 emissions. An added difficulty is that the potential hazard of residential N0 emissions is also hard to quantify. N0 is both an acid precipitation and ozone (03) precursor, but because residential appliances are a relatively small and dispersed (i.e., hard to monitor) source, these emissions tend to play a small role in NO control strategies. The 03 hazards of NO emissions are highly variable both spatially and over time, as weather conditions favor or disfavor 03 formation. One would, therefore, expect NO emissions rules to vary significantly across jurisdictions. The value estimated by EPA of 61 g of NOX/GJ is for distillate oil-fired boilers with a combustion rate less than 106 GJlhour (or 100 MBtu/hour) of heat input. This combustion type is characteristic ofresidential water heaters or clothes washers.3 Additional research into specific state regulations reveals good matches with the U.S. EPA's emissions factor: New Hampshire limits N0 emissions to 60 g/GJ for non-utility boilers and New York and New Jersey regulations cap emissions at52g ofN0/GJ. These state limits confirm that the U.S. s estimate can serve as a reasonable national average. EA-2.3.2 Sulfur Dioxide Emissions of SO2 are a direct function of the sulfur content of the fuel. Assuming complete combustion of sulfur to SO2 makes it easy to assess and compare emissions across data sources. Individual state and county regulations limiting the amount of sulfur in residential fuel oil, however, reveal substantial variability in SO2 emissions factors from the U.S. EPA's estimate of 218g of SO2IGJof fuel energy content. This is roughly equivalent to 0.5% sulfur content by weight using an emissions factor for fuel oil #2 of43,950 gIGJ weight per unit energy content. A straight multiplication of the fuel energy content and the percentage of sulfur content in the fuel provide the emissions factor.

EA. 1-3In the state of New York, SO2 emissions limits range from 8 8-659 g/GJ depending on the

county. In New Hampshire, the emissions rate of SO2 from high-sulfur distillate fuel oil combustion cannot exceed 176 g/GJ. In Maine and Michigan, the regulations are higher than the U.S. EPA's assessment, limiting SO2 emissions from fuel oil to 500 g of S02/GJ of heat input. Such broad ranges and varying limits in certain regions are a strong argument for using EPA' s averaged national value over a regionally weighted average incorporating the various state and county regulations. Comparing the sulfur content of fuel oil from different refineries also demonstrates regional variability. Most sources were obtained through online web sites detailing product specifications. Mobil Corporation's residential heating fuel oil (#2 high-sulfur) for most states contains a maximum 0.5% sulfur by mass (219 g of 502/GJ of heat input), which is very close to EPA's emissions factor. Mobil also markets fuel with lower sulfur content to some regions in the Northeast. For example, Mobil's lowest sulfur content residential heating fuel oil contains 0.2% sulfur by weight (88 gIGJ), as required in New York City, Philadelphia, parts of Delaware, and most of New Jersey. Other regional regulations adhered to by Mobil are 132 g/GJ for most of Pennsylvania and parts of New Jersey, a limit of 127 g of S02/GJ of heat input for the state of Illinois, and an SO2 emissions factor of145 g/GJ in Massachusetts. The sulfur contents of distillate fuel oil from Chevron, Phillips 66, and the American Society for Testing and Materials (AS TM) exactly match the U.S. EPA' s estimate, substantiating the use of the latter for the analysis. Considerable variation does exist among counties and states, especially in the Northeast. Nonetheless, EPA provides a reasonable estimate of emissions from residential oil-fired water heaters that is representative of the national average. EA-2.4 LPG EA-2.4.1 Oxides of Nitrogen Although NES results are presented for LPG, EPA estimates emissions for only propane and butane, fuels within the LPG family of gases. In the United States, the composition of LPG is typically 90% propane (C3H8) by liquid volume, 5%propylene (C3H6), and2.5% butane (C4H10).4 This analysis uses the U.S. EPA's propane emissions estimate to verify its comparability with LPG combustion or determines a more suitable estimate from other sources that best represents LPG emissions rates. EPA estimates an emissions factor of 66 g ofNOIGJof energy input from propane-fired water heaters, which is slightly higher than the natural gas estimate. The University of New Hampshire's Energy Office estimates an emissions factor of 43 g/GJ from LPG combustion for the state of New Hampshire. In contrast, the state of New Jersey's EPA establishes an 86 g/GJ emissions factor. Both sources, therefore, support EPA's national assessment ofNO emissions from residential propane combustion.

EA.1-4EA-2.4.2 Sulfur Dioxide

The sulfur content of LPG is very low5 although a few regulations exist in certain parts of the country. The U.S. EPA's SO, emissions estimate is derived from the sulfur content of the propane fuel. With 90% of LPG comprised of propane, the EPA's propane emissions factor is a reasonable value for LPG emissions rates. Under the New Hampshire Department of Environmental Services (DES) regulation, the maximum sulfur content allowable is 13.3 g/GJ of SO2 from LPG combustion. The San Diego County Air Pollution Control District enforces a stricter limit of only 8.8 g of SO2IGJ of energy input using the U.S. EPA's recommended value. Both the ASTM and Santa Barbara County Air Pollution Control District specify a sulfur standard of 0.0185% sulfur by weight, which approximates an emissions factor of 4.0 g of S02/GJ of energy input. This calculation is based on an LPG weight per unit energy of21,756 g/GJ. Even lower, Nett Technologies Inc. estimates a 0.0 12% sulfur content by mass LPG average for the United States as well as Canada, which is approximately 2.6 g of S02/GJ of heat input. The wide range of emissions factors for SO2 makes it difficult to determine a representative estimate for the emissions factor and the very small net effect of any energy-efficiency standard argue against making a significant research effort. The obtained estimates range in magnitude from approximately 4 to 13 g/GJ of energy input. The statistical average or arithmetic mean of these four estimates is 7.2 g/GJ, the value provided in Table EA- 1. The averaged emissions factor estimate of 7.2 g/GJ energy input is reasonable to explain three of the five sources presented and suitably accounts for the average among the two extreme estimates. Table EA- 1 therefore adequately represents national SO2 emissions from residential LPG combustion.
EA-3 SUMMARY This investigation of emissions factors from natural gas-, fuel oil-, and LPG-fired residential water heaters andlor clothes washers indicates that using the values estimated by EPA's AP-42 is a robust and credible basis for analysis with NES output. This analysis indicates that regulations at the state and county level, especially in the northeastern region of the United States, are generally not good estimators of the national average set forth by the EPA AP-42 report. This is especially true for SO2 emissions factors from fuel oil combustion where individual state and county regulations are highly variable. Thus, although it is worthwhile examining regional legislation to support the national average, this analysis demonstrates the complexity that would be required to establish a weighted regional calculation for each emission. EPA' s own lack of data on the sulfur content ofLPG made it difficult to derive a nationally representative emissions factor for the country as a whole. External sources were therefore incorporated in the Table EA- 1 estimate for SO2 emissions from LPG combustion.

EA. 1-5REFERENCES

1. U.S. Environmental Protection Agency, Compilation ofAirPollutant Emission Factors, AP42, Fflh Edition, Volume I. Stationary Point and Area Sources, 1998. October. <http:I/www.epa.gov/ttn/chief/ap42.html> 2. South Coast Air Quality Management District, March, 1995. <http:I/www.aumd.gov/ rules/ri 121.html> 3. New Jersey State Department of Environmental Protection, September 1993. <http://www.state.ni .us/dep/aim127 19968 .htm#Boilers>4. United States Hemispheric Clean Cities Program, 1994. <http://www.hemisccities.doe. gov/altfuels/propane.html>
5. U.S. Environmental Protection Agency, Compilation ofA irPollutantEmission Factors, AP42, Fifth Edition, Volume I: Stationary Point and Area Sources, Chapter 1, External Combustion Sources, 1998. October. <http://www.epa. gov/ttnlchief/ap42c 1 .html>

EA.1-6APPENDIX EA.2. UPSTREAM EMISSION FACTORS FROM COAL AND NATURAL GAS PRODUCTION

.................................... TABLE OF CONTENTS Table EA-2. 1 Estimated Upstream Emission Factors and Relative Percentages to Direct Power EA.2-2 Plant Combustion Emissions

EA.2-iAPPENDIX EA-2. UPSTREAM EMISSION FACTORS FROM COAL AND NATURAL GAS PRODUCTION Tracking of pollutant emissions by the National Energy Modeling System (NEMS) used for the appliance energy efficiency standards analysis, called NEMS-BRS, is incomplete, with thorough treatment of some aspects and scant treatment of others.a The approach is also somewhat different between emissions. Overall, carbon emissions are well covered because they are estimated based on elemental carbon released as carbon dioxide (C02) from all hydrocarbon combustion. However, some energy-use effects of proposed standards are not tracked by NEMS-BRS so their effects on carbon emissions are not counted. For example, the effect of lower residential electricity consumption on generation is estimated, but not the second order effect on energy consumed in coal transportation to power plants. In other words, the amount of energy used to perform the upstream processes in coal and natural gas production is not linked to the downstream consumption of these fuels. For this reason, while total carbon emissions are counted, changes due to proposed standards are not. According to DeLuchi, the amount of energy used to mine and clean the coal is minimal, amounting to less than 1% of the energy available in the coal. The amount of energy required to transport the coal using trains, trucks, and pipelines is approximately 0.156 exajoules/annually (EJIa) or 0.148 Quads/a as estimated for the year 2000.1 Based on the AE099 energy consumption of coal from electric generation, this corresponds to 0.7% of the total energy required by electric generators. For natural gas production, the amount of energy used to transport natural gas to the end-use consumer is 3.5% of the total natural gas produced and made available to end-use customers as estimated for the year 2000. For extraction of crude oil, the relative percentage is only 2.8%. Thus, the upstream losses are small relative to the total amount of energy embodied in the coal, oil, and natural gas and, therefore, changes due to proposed standards are also likely to be small. NEMS-BRS tracks only NO and SO2 emissions from power generation. Sources of these emissions that may be affected by proposed standards are therefore missed. Two notable sources of NO and SO2 emissions not considered are household emissions from the combustion of natural gas, liquefied petroleum gas (LPG), and heating fuel oil and emissions associated with fuel extraction and delivery to the point of combustion. This analysis considers two uncounted emissions from coal and natural gas production and delivery, SO2 and NOR. These emissions include those due to the mining of coal or extraction of natural gas, the physical processes involved in preparing or cleaning the fossil fuel, and the transportation of the fuel from the mine to the power plant. Household combustion effects of

aFor more information on NEMS, please refer to the U.S. Department of Energy, Energy Information Administration documentation. A useful summary isNational Energy Modeling System: An Overview 1998, DOE/EIA-0581(98), February 1998. DOE/ETA approves use of the name NEMS to describe only an official version of the model without any modification to code or data. Because our analysis entails some minor code modifications and the model is run under policy scenarios that are variations on DOE/EIA assumptions, the name NEMS-BRS refers to the model as used here (BRS is DOE's Building Research and Standards office, under whose aegis this work has been performed).
EA.2- 1proposed standards are explicitly included in the appliance energy-efficiency standards analysis and

the methods used are described in Appendix EA- 1. Studies addressing upstream emissions are very limited. Thus, the reliability of the exact measurements can be easily criticized. The values presented here are only intended to provide a coarse estimate of the magnitude of upstream emissions not accounted for in NEMS-BRS. In general, emissions from mining, cleaning, or transporting fossil fuels are small compared to the emissions that result from their combustion. Upstream emissions estimates for carbon and NO are taken from a thorough study done byM.A. DeLuchi at Argonne National Laboratory in 1993. DeLuchi provides estimates of full fuelcycle emissions factors for emissions of C02, methane (CH4), carbon monoxide (CO), non-methane organic compounds (NMOC), and NO from coal and natural gas production. An emission factor for SO2 is taken from the United States Environmental Protection Agency's (EPA) Compilation of Air Pollutant Emissions Factors, AP-42.2 This source notes that coal cleaning is the primary source for upstream SO2 emissions from coal production, so the emission factor for SO2 only reflects the coal cleaning process. Transportation is not addressed in EPA's study. Emission factor estimates and corresponding percentage contributions of the upstream emissions relative to power plant emissions are shown in Table EA-2. 1 for carbon, SO2, and NO from coal and natural gas production. The relative percentage to power plant emissions is provided so an estimate of upstream emission savings based on the savings from the power plant could be easily estimated. The values shown in Table EA-2. 1 represent emissions from upstream processes as mass (g) of deliverable energy to end-use consumers.
Table EA-2.1 Estimated Upstream Emission Factors and Relative Percentages to Direct Power

Plant Combustion Emissions

Coal Natural Gas %of %of Emission Emission

Combustion Combustion Factor (g/GJ) Factor (g/GJ)

Emissions Emissions Carbon 2222 2.7 5456 11.9
SO2 29.2 0.9 0 0
NO 41.7 5.8 153 40

DeLuchi's analysis reveals that upstream processes in coal production relative to power plant emissions account for 5.8% of NO and 2.7% of carbon. The AP-42 indicates that less than one

EA.2-2percent of SO2 emissions result upstream relative to those from coal power plant emissions.

Upstream coal processes, therefore, account for at most 6% of relative power plant emissions for carbon, SO2, and NOR. For natural gas production, the upstream 502 emissions are negligible. The upstream emissions from NOR, however, are quite significant, accounting for 40.0% of emissions relative to those from the power plant. Total natural gas combustion NO emissions from the power plant are only half those from coal, while emissions upstream processes are four times those of coal. Carbon emissions are nearly 12% of power plant emissions with an emission factor of 5456 gIGJ of deliverable energy; however, as noted above, changes to these emissions are counted by NEMS. Relative to the entire fuel cycle, DeLuchi estimates that approximately 8% by mass of all emissions from coal production are due to mining, preparation, and transport from the mine to the plant. Transportation emissions include those resulting from the use of fuel by the modes of transportation used to move the fuel from the site of extraction to fuel production facilities. For natural gas production, 14% of total emissions are estimated to result from upstream processes. Based on Table EA-2. 1, this higher loss factor in natural gas production is likely due to the higher NO contribution. Thus, emissions factors and their relation to power plant emissions are provided to reveal the relatively small proportion of energy losses attributable to upstream processes. With the exception of NO emissions from natural gas production, all emissions are less than 12% of power plant emissions.

EA.2-3REFERENCES

DeLuchi, M. A., Emissions of Greenhouse Gasesfrom 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. 2. U.S. Environmental Protection Agency, Compilation ofA ir Pollutant Emission Factors, AP42, F?fth Edition, Volume I. Stationary Point and Area Sources, Chapter 1], Mineral Products Industry, 1995. November. <http://www.epa. ov/ttnIchief/ap42c 11 .html>

EA.2-4APPENDIX EA.3. INTERPOLATION OF UTILITY AND ENVIRONMENTAL RESULTS FROM NEMS-BRS OUTPUT TABLE OF CONTENTS Figure EA-3.1 a An Example of the Interpolation of a Trial Standard Level:

Difference in Coal Capacity

.................................. EA.3-4 Figure EA-3.lb Close-Up of the Interpolation of Trial Standard

Level X2 from Xl

......................................... EA.3-5 Figure EA-3.2 Example of Trial Standard Level Xl: Marginal NO Emissions

...... EA.3-6

EA.3-iAPPENDIX EA-3. INTERPOLATION OF UTILITY AND ENVIRONMENTAL

RESULTS FROM NEMS-BRS OUTPUT The effects of proposed clothes washer energy efficiency standard levels on electricity and gas industries have been analysed using a variant of the U. S. DOE/EIA' s National Energy Modelling System (NEMS), called NEMS-BRS, together with some exogenous calculations.a Because the relative size of the energy savings being implemented in NEMS-BRS is too small to be seen in the context of the whole electricity and gas utility sector, NEMS-BRS is not used directly. Rather, exploratory runs are conducted to estimate marginal effects, which are then used to calculate the small effects due to each proposed trial standard case. To run a simulation inNEMS-BRS, the Residential Demand Module clothes washer, clothes diyer and water heater load is reduced annually according to the energy savings estimated by the National Energy Savings (NES) model for each trial standard level. These energy savings increase over time and are distinguished by fuel type (electricity, gas, oil, and LPG). Differences in fuel usage among U.S. census divisions come from data derived from the Residential Energy Consumption Survey (RECS).1 The magnitude of the energy decrement that would be required for NEMS-BRS to produce stable results safely out of the range of numerical noise is greater than even the most stringent standard under consideration. Therefore, it has been necessary in both the utility and environmental analyses, to estimate results in the range of the standard levels effects using interpolation. Interpolated values are derived from a series of higher decrement simulations based on the standard level. The actual annual savings attributed to each standard level are compared between standard levels, and those with similar savings patterns over time are grouped. One set of simulations is run for each of the savings groups. The groups used for the clothes washers analysis are listed below. The standard level in the first row was the one used to model the others in the same group.

aFor more information on NEMS, please refer to the U.S. Department of Energy, Energy Information Administration documentation. A useful summary is National Energy Modeling System: An Overview 1998, DOE/EIA-058 1(98), February 1998. DOE/ETA approves use of the name NEMS to describe only an official version of the model without any modification to code or data. Because our analysis entails some minor code modifications and the model is run under policy scenarios that are variations on DOE/ETA assumptions, the name NEMS-BRS refers to the model as used here (BRS is DOE's Building Research and Standards office, under whose aegis this work has been performed).
EA.3- 1The MEFs (Modified Energy Factors) in the table below are grouped into four multiplier

categories.
Group 1 (Multipliers 8, 12, 16) Group 2 (Multipliers 6, 9, 12) Group 3 (Multipliers 2, 4, 6) Group 4 (Multiplier 6, 9, 12) 1.089 1.257 1.634 1.04 in yr 2004 & 1.26 in yr 2007 1.021 1.362 1.485 0.96 1 0.908 0.860 To preserve the pattern of energy savings over time for a trial standard, savings in each year are multiplied by the same factor. This factor varies between groups because the magnitude of the savings changes. An appropriate set of multipliers were chosen to augment the savings to a magnitude that produces credible results. Using professional judgement, sets of three multipliers were selected for each of the patterns shown in the table above. For the 1.634 MEF (50% energy reduction level), the series consists of simulations of 2, 4, and 6 times the trial standard energy savings. The output for electricity generation and capacity by fuel type for each of the iterations (the 2, 4, and 6 times the standard) is then regressed, with the y-intercept forced through the origin because a zero change must be the case with no standard in place and because the target points of interpolation are close to the origin (i.e., at low energy decrements). Other trial standards within the same group are interpolated along this regression line by substituting the x-value in the regression equation with the ratio of energy savings between standard levels in the peak energy savings year.
Figure EA-3.l a shows an example of the interpolation approach for a trial standard level Xl. The magnitude of the energy savings multiplier is plotted on the x-axis against the reduction in coal installed generating capacity for each reported year, as shown by the various plotted lines. In general, results for the various NEMS-BRS runs are reasonably stable and linear, with the noisy behavior appearing below the first multiplier of the trial standard level savings decrement. Figure EA-3. lb shows a close-up of the interpolated points for trial standard level X2 from standard Xl. The heavy horizontal lines illustrate the calculated values for the difference in coal capacity in 2020. These regressions appear stable, so estimating results via interpolation toward zero seems justified. A similar approach was used to find the drop in installed generating capacity from other fuels and in generation for each fuel type in each reported year. The estimated reduction in total fuel generation that we report at each trial standard level as determined by interpolation is then used to determine emissions savings. First, annual marginal

EA.3-23 emissions rates are calculated for each of the simulations in a savings group, based on the actual

output from NEMS-BRS. Marginal emissions rates incorporate both effects of the standards-the emissions saved by the reduction in total generation and the slight change in the emissions characteristics of the whole power sector that result from the slight change in dispatch and capacity expansion plan. The net effect on the entire system is very small and, typically, the overall effect on emissions can be fully attributed to the decremental generation. The annual marginal emissions rates at the trial standard level are then extrapolated from these rates (at multipliers of the trial standard level savings) by taking a simple average. Figure EA-3.2 shows an example of the extrapolation for NO emissions rates for trial standard level Xl. In this case, marginal rates for NO emissions are shown for each year. As is evident in the figure, more stable results are produced at higher levels of demand decrement. At lower decrement levels (i.e., both on the left-hand side of the figure and in years with small standards impacts), the emissions rate is quite variable. The dashed plots (years 2003 - 2010) show the earlier years of the imposed standard-those in which the decrements to demand are smallest (not shown here). In most cases, these curves are so close to flat that regression of the higher decrement simulation points produces a curve very close to the simple average of values. The constant emissions rates at higher decrement levels are therefore assumed to hold in the range of small decrements commensurate with the various standard levels, and the implied marginal emissions rates are used to estimate emissions reductions. Total emissions savings in each year are the product of the annual marginal emissions rate and the reduction in thermal generation for that year (as calculated by the interpolation method described above). For each of the standard levels, marginal emissions rates for all years are derived by averaging the marginal rates of the three higher decrement levels (e.g., 2, 4, and 6 times for 50% energy reduction level).

EA.3-3NoStd.Lvi. 6x Std. Lvi. Xl 8x Std. Lvi. Xl lOx Std. Lvi 0

-

-

- -

-6 -_

2010 Regression

- - - 2015 Regression

- - 2020 Regression
Savings Multiplier xl

Figure EA-3.la An Example of the Interpolation of a Trial Standard Level: Difference in Coal Capacity

EA.3-4NoStd.LvI.
02c 050

- - 75 1 0 125 150 175 2

- . - -

-0.5 . -
N

-0.9 -1.0

-1.2

-1.5 - -+2000

---2OO5 --2010 ---- 2015
-*--- 2020 -2.0 - 2005 Regression

2010 Regression - - -2015 Regression - - 2020 Regression -2.5 2020

2020

Savings Multiplier Figure EA-3.lb Close-Up of the Interpolation of Trial Standard Level X2 from Xl N N

- N N N

EA.3-58

6

4

2

o 0 z

-4

-6

-8

-10 S

• :::--.. --. .

______ - ---=ii 2003 ""2004

2005 - - 2006 --*• 2007 "2008 2009 2010 2011 2012 2013 2014 - - 2015

2016 2017 2018 20 19

Std. Lvi. Xl 6x Std. Lvi. Xl 8x Std. Lvi. Xl lOx Std. Lvl.X1 Savings Multiplier

Figure EA-3.2 Example of Trial Standard Level Xl: Marginal NO Emissions

EA.3-6REFERENCE

1. U.S. Department of Energy - Energy Information Administration, Residential Energy Consumption Survey: Household Energy Consumption and Expenditures 1993, October, 1995. Washington, DC. Report No. DOE/EIA-0321(93).

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