### CHAPTER 16. ENVIRONMENTAL ASSESSMENT

TABLE OF CONTENTS

16.1 INTRODUCTION

......................................................................................................... 16-2 16.2 AIR EMISSIONS ANALYSIS

...................................................................................... 16-2 16.2.1 Air Emissions Descriptions

............................................................................................ 16 -3 16.2.2 Air Quality Regulation

.................................................................................................. . 16-4 16.2.3 Global Climate Change

.................................................................................................. 1 6-5 16.2.4 Analytical Methods for Air Emissions

.......................................................................... 16-9 16.2.5 Effects on Power Plant Emissions

............................................................................... 16-10 16.2.6 Effects on Building Emissions

..................................................................................... 16-12 16.2.7 Effects on Upstream Fuel-Cycle Emissions

................................................................ 16-14 16.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND CULTURAL RESOURCES

........................................................................................ 16-15 16.4 SOCIOECONOMIC IMPACTS

.................................................................................. 16-17 16.5 ENVIRONMENTAL JUSTICE IMPACTS

................................................................ 16-18 16.6 NOISE AND AESTHETICS

....................................................................................... 16-19 16.7 SUMMARY OF ENVIRONMENTAL IMPACTS

..................................................... 16-19

LIST OF TABLES Table 16.2.1 Impact of Commercial Clothes Washer Efficiency Standards on Cumulative Energy-Related Emissions of CO 2 

### between 2013-2043 by Trial Standard Level (Million Metric Tons of CO 2 

### )

.......................................... 16-8 Table 16.2.2 Power Sector Emissions Forecast from AEO2009 Reference Case

................. 16-11 Table 16.2.3 Power Sector Emissions Impact Forecasts for Commercial Clothes Washers

............................................................................................................ 16-12 Table 16.2.4 Change in Household Emissions from Commercial Clothes Washers

............ 16-13 Table 16.2.5 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct Power Plant Combustion Emissions

................................................................ 16-14 Table 16.3.1 Top-Loading Commercial Clothes Washers: Per-Cycle Water Use and Water Discharge Savings by TSL

.................................................................... 16-16 Table 16.3.2 Front-Loading Commercial Clothes Washers: Per-Cycle Water Use and Water Discharge Savings by TSL

.................................................................... 16-16 Table 16.3.3 Summary of National Wastewater Discharge Reductions and National Water Savings due to Commercial Clothes Washer Standards (Cumulative reductions for products sold from 2013 to 2043)

............................................. 16-17 Table 16.4.1 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, Commercial Clothes Washers

.......................................................................... 16-18 Table 16.7.1 Environmental Impact Analysis Results Summary for Commercial Clothes Washers

............................................................................................................ 16-20

16-1

### CHAPTER 16. ENVIRONMENTAL ASSESSMENT

16.1 INTRODUCTION This chapter describes potential environmental effects that may result from amended energy conservation standards for commercial clothes washers. The U.S. Department of Energy (DOE)’s proposed energy conservation standards are not site-specific, and would apply to all 50 States and U.S. territories. Therefore, none of the proposed standards would impact land uses, cause any direct disturbance to the land, or directly affect biological resources in any one area. All of the potential trial standard levels (TSLs) are expected to reduce energy consumption in comparison to a baseline efficiency level. These changes in the demand for electricity and the costs of achieving these savings are the primary drivers in analyzing environmental effects. Estimates of source energy savings can be found in the national impact analysis in Chapter 11 of this technical support document (TSD). Detailed discussion on TSLs can be found in Chapter 9 of this TSD. The primary impact of the TSLs is in air quality resulting from changes in power plant operations and capacity additions. Therefore, much of this chapter describes the air quality analysis. The latter part of the chapter describes potential impacts to other environmental
resources. The technical support document (TSD) for DOE’s notice of proposed rulemaking (NOPR) covered conventional cooking products (i.e., cooktops and ovens), microwave oven energy factor (EF), microwave oven standby power consumption, and commercial clothes washers (CCW). 1 

### DOE has already completed its standards rulemaking for conventional cooking products and microwave oven EF and has published both a final rule 2 

### and corresponding TSD. 3 

### This chapter presents information and results pertaining solely to CCWs. The impact of more-efficient equipment on microwave oven standby power will be addressed in a subsequent TSD.

16.2 AIR EMISSIONS ANALYSIS The primary focus of the environmental analysis is the impact on air quality of amended energy conservation standards for commercial clothes washers. The outcomes of the environmental analysis are driven by changes in power plant types and quantities of electricity generated under each of the alternatives. Changes in generation are described in the utility impact analysis in Chapter 14.

16-2

### 16.2.1 Air Emissions Descriptions For each of the TSLs, DOE calculated total power-sector emissions based on output from NEMS-BT model (see Chapter 14). This analysis considers three pollutants: nitrogen oxides (NO x 

### ), mercury (Hg), and sulfur dioxide (SO 2 

### ). An air pollutant is any substance in the air that can cause harm to humans or the environment. Pollutants may be natural or man-made (i.e., anthropogenic) and may take the form of solid particles (i.e., particulates or particulate matter), liquid droplets, or gases a 

### . This analysis also considers carbon dioxide (CO 2 

### ). Sulfur Dioxide (SO 2 

### ) In addressing SO 2 

### emissions, the Clean Air Act Amendments of 1990 set an SO 2 

### emissions cap on all power generation, but permitted flexibility among generators through the use of emissions allowances and tradable permits. This SO 2 

### trading process (sometimes called “cap and trade”) implies that the standard will have no affect on total physical emissions because emissions will always be at, or near, the allowed emissions ceiling. Consequently, there is no direct SO 2 

### environmental benefit from a reduction in electricity use due to the proposed energy conservation standards, as long as there is enforcement of the emissions ceiling. But to the extent reduced power generation demand decreases the demand for and price of emissions allowance permits, there is an environmentally related economic benefit from the proposed energy conservation standards reducing SO 2 

### emissions allowance demand. Furthermore, over time, if emissions decline, there is greater flexibility in reducing the ceiling amount. However, since DOE does not anticipate a change in SO 2 

### emissions, SO 2 

### emission results are not reported in this Chapter. Nitrogen Oxides (NO x 

### ) Nitrogen oxides , or NO x 

### , are the generic term for a group of highly reactive gases, all of which contain nitrogen and oxygen in varying amounts. Many of the nitrogen oxides are colorless and odorless. However, one common pollutant, nitrogen dioxide (NO 2 

### ), along with particles in the air can often be seen as a reddish-brown layer over many urban areas. NO 2 

### is the specific form of NOx reported in this document. NO x 

### is one of the main ingredients involved in the formation of ground-level ozone, which can trigger serious respiratory problems. It can contribute to the formation of acid rain, and can impair visibility in areas such as national parks. NO x 

### also contributes to the formation of fine particles that can impair human health. Nitrogen oxides form when fossil fuel is burned at high temperatures, as in a combustion process. The primary manmade sources of NO x 

### are motor vehicles, electric utilities, and other industrial, commercial, and residential sources that burn fossil fuels. NO x 

### can also be formed naturally. Electric utilities account for about 22 percent of NO x 

### emissions in the United States.

a More information on air pollution characteristics an d regulations is available on the U.S. Environment Protection Agent (EPA)’s website at www.epa.gov.

16-3

### MercuryCoal-fired power plants emit Hg found in coal during the burning process. While coalfired power plants are the largest remaining source of human-generated Hg emissions in the United States, they contribute very little to the global Hg pool or to contamination of U.S. waters. U.S. coal-fired power plants emit Hg in three different forms: oxidized Hg (likely to deposit within the United States); elemental Hg, which can travel thousands of miles before depositing to land and water; and Hg that is in particulate form. Atmospheric Hg is then deposited on land, lakes, rivers, and estuaries through rain, snow, and dry deposition. Once there, it can transform into methylmercury and accumulate in fish tissue through bioaccumulation. Americans are exposed to methylmercury primarily by eating contaminated fish. Because the developing fetus is the most sensitive to the toxic effects of methylmercury, women of childbearing age are regarded as the population of greatest concern. Children exposed to methylmercury before birth may be at increased risk of poor performance on neurobehavioral tasks, such as those measuring attention, fine motor function, language skills, visual-spatial abilities, and verbal memory. Carbon Dioxide (CO 2 

### ) Carbon dioxide (CO 2 

### ) is not a regulated or criteria pollutant (see below), but it is of interest because of its classification as a greenhouse gas (GHG). GHGs trap the sun’s radiation inside the Earth’s atmosphere and either occur naturally in the atmosphere or result from human activities. Naturally occurring GHGs include water vapor, CO 2 

### , methane (CH 4 

### ), nitrous oxide (N 2 

### O), and ozone (O 3 

### ). Human activities, however, add to the levels of most of these naturally occurring gases. For example, CO 2 

### is emitted to the atmosphere when solid waste, fossil fuels (oil, natural gas, and coal), wood, and wood products are burned. During the past 20 years, about three-quarters of anthropogenic (i.e., human-made) CO 2 

### emissions resulted from burning fossil fuels.

Concentrations of CO 2 

### in the atmosphere are naturally regulated by numerous processes, collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and the land and oceans is dominated by natural processes, such as plant photosynthesis. While these natural processes can absorb some of the anthropogenic CO 2 

### emissions produced each year, billions of metric tons are added to the atmosphere annually. In the U. S., CO 2 

### emissions from both energy generation and industrial processes account for 84.6 percent of total U.S. GHG emissions.

16.2.2 Air Quality Regulation The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that EPA is required to control. EPA has set national air quality standards for six common pollutants (also referred to as “criteria” pollutants), two of which are SO 2 

### and NO x 

### . Also, the Clean Air Act Amendments of 1990 gave EPA the authority to control acidification and to require operators of electric power

16-4

### plants to reduce emissions of SO 2 

### and NO x 

### . Title IV of the 1990 amendments established a capand-trade program for SO 2 

### intended to help control acid rain. This cap-and-trade program serves as a model for more recent programs with similar features. In 2005, EPA issued the Clean Air Interstate Rule (CAIR) under sections 110 and 111 of the Clean Air Act (40 CFR Parts 51, 96, and 97). b 

### CAIR will permanently cap emissions of SO 2 

### and NOx in eastern States of the United States. CAIR achieves large reductions of SO 2 

### and/or NOx emissions across 28 eastern states and the District of Columbia. States must achieve the required emission reductions using one of two compliance options: 1) meet an emission budget for each regulated state by requiring power plants to participate in an EPA-administered interstate cap-and-trade system that caps emissions in two stages, or 2) meet an individual state emissions budget through measures of the state’s choosing. Phase 1 caps for NO x 

### are to be in place in 2009. Phase 1 caps for SO 2 

### are to be in place in 2010. The Phase 2 caps for both pollutants are due in 2015.
Also in 2005, EPA issued the final rule entitled “Standards of Performance for New and Existing Stationary Sources: Electric Steam Generating Units,” under sections 110 and 111 of the Clean Air Act (40 CFR Parts 60, 63, 72, and 75). This rule, also called the Clean Air Mercury Rule (CAMR), was closely related to the CAIR and established standards of performance for Hg emissions from new and existing coal-fired electric utility steam generating units. The CAMR regulated Hg emissions from coal-fired power plants. On February 8, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its decision in State of New Jersey, et al. v. Environmental Protection Agency , c 

### in which the Court, among other actions, vacated the CAMR referenced above. On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its decision in North Carolina v. Environmental Protection Agency
, which vacated the CAIR issued by the U.S. Environmental Protection Agency on March 10, 2005. d 

### But on December 23, 2008, the D.C. Circuit decided to allow CAIR to remain in effect until it is replaced by a rule consistent with the court’s earlier opinion. North Carolina v. Environmental Protection Agency , 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur).

16.2.3 Global Climate Change Climate change has evolved into a matter of global concern because it is expected to have widespread, adverse effects on natural resources and systems. A growing body of evidence points to anthropogenic sources of greenhouse gases, such as carbon dioxide (CO 2 

### ), as major contributors to climate change. Because this Rule, if finalized, will likely decrease CO 2 

### emission

b See http://www.epa. gov/cleanairinterstaterule/.

c No. 05-1097, 2008 WL 341338, at *1 (D.C. Cir. Feb. 8, 2008).

d See http://www.epa. gov/cleanairinterstaterule/.

16-5

### rates from the fossil fuel sector in the United States, the Department here examines the impacts and causes of climate change and then the potential impact of the Rule on CO 2 

### emissions and global warming. Impacts of Climate Change on the Environment Climate is usually defined as the average weather, over a period ranging from months to many years. Climate change refers to a change in the state of the climate, which is identifiable through changes in the mean and/or the variability of its properties (e.g., temperature or precipitation) over an extended period, typically decades or longer. The World Meteorological Organization and United Nations Environment Programme (UNEP) established the Intergovernmental Panel on Climate Change (IPCC) to provide an objective source of information about climate change. According to the IPCC Fourth Assessment Report (IPCC Report), published in 2007, climate change is consistent with observed changes to the world’s natural systems; the IPCC expects these changes to continue. Changes that are consistent with warming include warming of the world’s oceans to a depth of 3000 meters; global average sea level rise at an average rate of 1.8 mm per year from 1961 to 2003; loss of annual average Arctic sea ice at a rate of 2.7 % per decade, changes in wind patterns that affect extra-tropical storm tracks and temperature patterns, increases in intense precipitation in some parts of the world, as well as increased drought and more frequent heat waves in many locations worldwide, and numerous ecological changes. Looking forward, the IPCC describes continued global warming of about 0.2°C per decade for the next two decades under a wide range of emission scenarios for carbon dioxide (CO 2 

### ), other greenhouse gases (GHG)s, and aerosols. After that period, the rate of increase is less certain. The IPCC Report describes increases in average global temperatures of about 1.1°C to 6.4°C at the end of the century relative to today. These increases vary depending on the model and emissions scenarios. The IPCC Report describes incremental impacts associated with the rise in temperature. At ranges of incremental increases to the global av erage temperature, IPCC reports, with either high or very high confidence, that there is likely to be an increasing degree of impacts such as coral reef bleaching, loss of wildlife habitat, loss to specific ecosystems, and negative yield impacts for major cereal crops in the tropics, but also projects that there likely will be some beneficial impacts on crop yields in temperate regions. Causes of Climate Change The IPCC Report states that the world has warmed by about 0.74°C in the last 100 years. The IPCC Report finds that most of the temperature increase since the mid-20th century is very likely due to the increase in anthropogenic concentrations of CO 2 

### and other long-lived greenhouse gases (GHGs) such as methane and nitrous oxide in the atmosphere, rather than from natural causes.

16-6

### Increasing the CO 2 

### concentration partially blocks the earth’s re-radiation of captured solar energy in the infrared band, inhibits the radiant cooling of the earth, and thereby alters the energy balance of the planet, which gradually increases its average temperature. The IPCC Report estimates that currently, CO 2 

### makes up about 77% of the total CO 2 

### -equivalent e 

### global warming potential in GHGs emitted from human activities, with the vast majority (74%) of the CO 2 

### attributable to fossil fuel use. For the future, the IPCC Report describes a wide range of GHG emissions scenarios, but under each scenario CO 2 

### would continue to comprise above 70% of the total global warming potential. Stabilization of CO 2 

### Concentrations Unlike many traditional air pollutants, CO 2 

### mixes thoroughly in the entire atmosphere and is long-lived. The residence time of CO 2 

### in the atmosphere is long compared to the emission processes. Therefore, the global cumulative emissions of CO 2 

### over long periods determine CO 2 

### concentrations because it takes hundreds of years for natural processes to remove the CO 2 

### . Globally, 49 billion metric tons of CO 2 

### –equivalent of anthropogenic (man-made) greenhouse gases are emitted every year. Of this annual total, fossil fuels contribute about 29 billion metric tons of CO 2 

### . f


### Researchers have focused on considering atmospheric CO 2 

### concentrations that likely will result in some level of global climate stabilization, and the emission rates associated with achieving the “stabilizing” concentrations by particular dates. They associate these stabilized CO 2 

### concentrations with temperature increases that plateau in a defined range. For example, at the low end, the IPCC Report scenarios target CO 2 

### stabilized concentrations range between 350 ppm and 400 ppm (essentially today’s value)—because of climate inertia, concentrations in thislow end range would still result in temperatures projected to increase 2.0°C to 2.4°C above preindustrial levels g 

### (about 1.3°C to 1.7°C above today’s levels). To achieve concentrations between 350 ppm to 400 ppm, the IPCC scenarios present that there would have to be a rapid downward trend in total annual global emissions of greenhouse gases to levels that are 50% to 85% below today’s annual emission rates by no later than 2050. Since it is assumed that there would continue to be growth in global populations and substantial increases in economic production, the scenarios identify required reductions in greenhouse gas emissions intensity (emissions per unit of output) of more than 90%. However, even at these rates, the scenarios describe some warming and some climate change is projected due to already accumulated CO 2 

### and GHGs in the atmosphere.

e GHGs differ in their warming influence (radiative forcing) on a global climate system due to their different radiative properties and lifetimes in the atmosphere. These warming influences may be expressed through a common metric based on the radiative forcing of CO 2 , i.e., CO 2 -equivalent. CO 2 equivalent emission is the amount of CO 2 emission that would cause the same- time integrated radiative forcing, over a given time horizon, as an emitted amount of other long- lived GHG or mixture of GHGs.

f Other non-fossil fuel contributors include CO 2 emissions from deforestation and decay from agriculture biomass; agricultural and industrial emissi ons of methane; and emissions of nitrous oxide and fluorocarbons.

g IPCC Working Group 3 Table TS 2

16-7

### The Beneficial Impact of the Rule on CO 2 

### Emissions If finalized, it is anticipated that the Rule will reduce energy-related CO 2 

### emissions, particularly those associated with energy consumption in buildings. In the United States, the U.S. Energy Information Administration (EIA) reports in its 2009 Annual Energy Outlook, April Release ( AEO2009 ) 4 

### that U.S. annual energy-related emissions of CO 2 

### in 2007 were about 5.9 billion metric tons (about 20 percent of the world energy-related CO 2 

### emissions and about 12 percent of total global greenhouse gas emissions), of which 2.3 billion tons were attributed to residential and commercial buildings sector (including related energy–using equipment such as commercial clothes washers). Most of the greenhouse gas emissions attributed to residential and commercial buildings are emitted from fossil fuel-f ired power plants that generate electricity used in this sector. In the AEO2009 Reference Case, EIA projected that annual energy-related CO 2 

### emissions would grow from 5.9 billion metric tons in 2007 to 6.2 billion metric tons in 2030, an increase of 4 percent (see AEO2009 ), while emissions attributable to buildings would grow to 2.6 billion tons, an increase of 13 percent.

As shown in Table 16.2.2 in the AEO2009 Reference Case, the cumulative U.S. energyrelated power sector CO 2 

### emissions between 2013 and 2043 are described at about 79 billion metric tons. The estimated cumulative CO 2 

### emission reductions from a commercial clothes washer efficiency standard (shown as a range of alternative Trial Standard Levels) during this same 30-year period are indicated in Table 16.2.1. Estimated CO 2 

### emission reductions in Table 16.2.1 come from two sources: electricity generation (i.e., power plants) and fossil fuel-fired appliances. The estimated CO 2 

### emission reductions from electricity generation are calculated using the NEMS-BT model. The estimated CO 2 

### emission reductions from fossil fuel-fired appliances (i.e., commercial clothes washers) are derived from emissions factors for commercial natural gas combustion. Table 16.2.1	 Impact of Commercial Clothes Washer Efficiency Standards on Cumulative Energy-Related Emissions of CO 2 

### between 2013-2043 by Trial Standard Level (Million Metric Tons of CO 2 

### ) Trial Standard Levels TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 Commercial Clothes Washers (CCW) * -2.36 -2.39 -5.07 -5.66 -6.11 Percent of Total Cumulative Emissions Reduction from 2013 to 2043 compared with the AEO 2009 Reference Case -0.003 -0.003 -0.006 -0.007 -0.008

* All results in million metric tons, equivalent to 1.1 short tons and negative values refer to a reduction compared with the Base Case. 

### The estimated savings shown in Table 16.2.1, which are at most 0.010 percent of U.S. energy-related emissions of CO 2 

### (total emissions reported for TSL 5 in Table 16.2.1), comprise an even smaller fraction of U.S. emissions of greenhouse gases and of world emissions of greenhouse gases. However, the savings would likely reduce overall U.S. CO 2 

### emissions, as

16-8

### compared to U.S. CO 2 

### emissions absent an increase in the required efficiency of commercial clothes washers. The Incremental Impact of the Rule on Climate Change It is difficult to correlate specific emission rates with atmospheric concentrations of CO 2 

### and specific atmospheric concentrations with future temperatures because the IPCC Report describes a clear lag in the climate system between any given concentration of CO 2 

### (even if maintained for long periods) and the subsequent average worldwide and regional temperature, precipitation, and extreme weather regimes. For example, a major determinant of climate response is “equilibrium climate sensitivity”, a measure of the climate system response to sustained radioactive forcing. It is defined as the global average surface warming following a doubling of carbon dioxide concentrations. The IPCC Report describes its estimated, numeric value as about 3°C, but the likely range of that value is 2°C to 4.5°C, with cloud feedbacks the largest source of uncertainty. Further, as illustrated above, the IPCC Report scenarios for stabilization rates are presented in terms of a range of concentrations, which then correlates to a range of temperature changes. Thus, climate sensitivity is a key uncertainty for CO 2 

### mitigation scenarios that aim to meet specific temperature levels. Because of how complex global climate systems are, it is difficult to know to what extent and when particular CO 2 

### emissions rates will impact global warming. However, as Table 16.2.1 indicates, the Rule will likely reduce CO 2 

### emissions rates from the fossil fuel sector.

16.2.4 Analytical Methods for Air Emissions NEMS-BT incorporates capabilities to assess compliance with SO 2 

### restrictions specified in the Clean Air Act and its amendments. Clean air act provisions include New Source Performance Standards, and Revised New Source Performance Standards. The version of NEMS-BT in 2008 also included provisions for the CAIR, which imposes stricter restrictions on SO 2 

### and NO X 

### for some states, and the CAMR, which imposed a national Hg constraint. As discussed earlier is section 16.2.2, on December 23, 2008, the D.C. Circuit decided to allow CAIR to remain in effect until it is replaced by a rule consistent with the court’s earlier opinion. Carolina v. Environmental Protection Agency , 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur). But actions taken on February 8, 2008 by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued in its decision in State of New Jersey, et al. v. Environmental Protection Agency , remain in effect vacating the CAMR. Although the constraints on Hg in CAMR have since been vacated by a court decision, the AEO2009 Reference Case assumes that emissions of Hg would decline over time as shown in Table 16.2.2. Because the courts vacated CAMR with many States planning to enact new laws or make existing laws more stringent, DOE decided not to use the 2009 version of NEMS-BT estimate emissions impacts for Hg. Instead, DOE established a range of Hg reductions due to standards. DOE’s high estimate used a Hg emission rate based on the AEO2009 . Because virtually all Hg emitted from electricity generation is from coal-fired power plants, DOE based the emission rate from the tons of Hg emitted per TWh of coal-generated electricity. DOE based the emission rate

16-9

### on the average value reported in the AEO2009 for the year 2006. This emission rate is 0.0230 tons per TWh (0.0255 short tons/TWh). DOE’s low estimate was based on the use of an emission rate for new combined-cycle gas plants as provided in the NEMS-BT. The emission rate for this generation technology is 0.000 tons per TWh. To estimate the reduction in Hgemissions from the power sector, DOE multiplied the emission rate by the reduction in coalgenerated electricity due to the standards considered as determined in the utility impact analysis (see Chapter 14, Utility Impact Analysis). The estimated changes in Hg emissions are shown by TSL for commercial clothes washers in Table 16.2.3 for the period from 2013 to 2043. Coal-fired electric generation is the single largest source of electricity in the United States. Because the mix of coals used significantly affects the emissions produced, the model includes a detailed representation of coal supply. The model considers the rank of the coal as well as the sulfur contents of the fuel used when determining optimal dispatch. Within the NEMS-BT model, planning options for achieving emissions restrictions in the Clean Air Act Amendments include installing pollution control equipment on existing power plants and building new power plants with low emission rates. These methods for reducing emission are compared to dispatching options such as fuel switching and allowance trading. Environmental regulations also affect capacity expansion decisions. For instance, new plants are not allocated SO 2 

### emissions allowances according to the Clean Air Act Amendments. Consequently, the decision to build a particular capacity type must consider the cost (if any) of obtaining sufficient allowances. This could involve purchasing allowances or over complying at an existing unit. Modeling of SO 2 

### trading tends to imply that the physical emissions effects will be zero, as long as emissions are at the allowed ceiling. Because SO 2 

### has been regulated with emissions caps for more than a decade, and no emissions reductions are reported from the NEMS-BT forecast model, DOE does not report SO 2 

### results here. This assumption is consistent with previous DOE environmental assessment documents. As noted in Chapter 14, NEMS-BT model forecasts end in year 2030. Emissions impacts beyond 2030 were extrapolated for this rulemaking in Table 16.2.3.

16.2.5 Effects on Power Plant Emissions Table 16.2.2 shows reference power plant emissions in selected years along with the change from the AEO2009 Reference Case. The Reference case emissions are the emissions shown by the NEMS-BT model to result if none of the TSLs are promulgated.

16-10

### Table 16.2.2 Power Sector Emissions Forecast from AEO2009 Reference Case NEMS-BT Results*: 2005 2010 2015 2020 2025 2030 CO 2 (Million metric tons/year)** 2,397 2,343 2,381 2,466 2,535 2,636 NO X (Thousand metric tons/year) † 3,302 2,077 1,869 1 ,878 1,878 1,905 Hg (metric tons/year) † 51.49 43.79 29.46 28.92 29.33 28.73 * All results in metric tons, equ ivalent to 1.1 short tons and negativ e values refer to a reduction compared with the Base Case ** Comparable to Table A17 of AEO2009 : Electric Generators † Comparable to Table A8 of AEO2009 : Emissions 

### Table 16.2.3 shows the estimated changes in power plant emissions in selected years for all the TSLs. Changes in NO X 

### and Hg emissions from power plants are shown in these tables. Changes in CO 2 

### emissions from all sources are also shown in these tables. Compared to the anticipated reference case emissions impacts forecast shown in Table 16.2.2, changes in emission levels shown in Table 16.2.3 are extremely small.

16-11

### Table 16.2.3 Power Sector Emissions Impact Forecasts for Commercial Clothes Washers NEMS-BT Results* Difference from AEO2009 Reference Case 2013 2015 2020 2025 2030 2035 2040 2043 Extrapolation Cumulative 2013-2043

Trial Standard Le vel 1 CO2 (Mt/a) 0.000 0.000 -0.025 -0.030 -0.033 -0.033 -0.033 -0.033 -0.82 NOx (kt/a) Hg (t/a) 0.000 0.000 -0.007 -0.006 -0.009 -0.009 -0.009 -0.009 -0.22

High 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.01 Low

Trial Standard Le vel 2 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00

CO2 (Mt/a) 0.000 0.000 -0.025 -0.031 -0.034 -0.034 -0.034 -0.034 -0.84 NOx (kt/a) Hg (t/a) 0.000 0.000 -0.007 -0.006 -0.009 -0.009 -0.009 -0.009 -0.22

High 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.01 Low

Trial Standard Le vel 3 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00

CO2 (Mt/a) 0.000 0.000 -0.056 -0.067 -0.074 -0.074 -0.075 -0.075 -1.83 NOx (kt/a) Hg (t/a) 0.000 0.000 -0.016 -0.013 -0.020 -0.020 -0.020 -0.020 -0.48

High 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.03 Low

Trial Standard Le vel 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00

CO2 (Mt/a) 0.000 0.000 -0.062 -0.075 -0.083 -0.083 -0.083 -0.083 -2.05 NOx (kt/a) Hg (t/a) 0.000 0.000 -0.018 -0.014 -0.022 -0.022 -0.022 -0.022 -0.54

High 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.03 Low

Trial Standard Le vel 5 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00

CO2 (Mt/a) 0.000 0.000 -0.067 -0.081 -0.090 -0.090 -0.090 -0.090 -2.22 NOx (kt/a) Hg (t/a) 0.000 0.000 -0.020 -0.015 -0.024 -0.024 -0.024 -0.024 -0.59

High 0.000 -0.001 -0.001 -0.001 -0.002 -0.002 -0.002 -0.002 -0.03 Low 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.00

* All results in metric tons (t), equivalent to 1.1 short tons.



### 16.2.6 Effects on Building Emissions For commercial clothes washers, impacts on commercial building emissions at the site are also reported. These estimates are based on exogenous emissions factors for residential and commercial natural gas combustion derived by the EPA’s AP-42 report in conjunction with the energy savings predicted by the National Impacts Analysis (NIA) model because NEMS-BT does not account for these emissions at the site.

16-12

### The emissions factors DOE used are derived from what are reported in the AP-42 for residential water heaters because no explicit listing was provided for commercial clothes washers. However, the AP-42 sources does provide a method for estimating the share of emissions from commercial clothes washers based on natural gas deliveries specific to a given region, but this approach was not easily applicable to the U.S. so is not performed here. 5 h 

### As well, given that emissions rates from end-use combustion are small compared to other emissions sources, it is not uncommon to see emissions factors from residential end uses reported in one general rate. 6 i 

### For these reasons, the Department opted to simply use the water heating emissions factor as a way of providing a rough estimates for the emissions savings associated with these efficiency standards, but acknowledging that these estimates are only general approximations. Table 16.2.4 shows the estimated changes in building emissions in selected years for the commercial clothes washer TSLs. Table 16.2.4 Change in Household Emissions from Commercial Clothes Washers NEMS-BT Results* Difference from AEO2009 Reference Case

Trial Standard Level 1 CO2 (Mt/a) NOx (kt/a)

Trial Standard Level 2 CO2 (Mt/a) NOx (kt/a)

Trial Standard Level 3 CO2 (Mt/a) NOx (kt/a)

Trial Standard Level 4 CO2 (Mt/a) NOx (kt/a)

Trial Standard Level 5 CO2 (Mt/a) NOx (kt/a) 2013 2015 2020 2025 2030

-0.005 -0.016 -0.045 -0.059 -0.059 -0.004 -0.013 -0.036 -0.046 -0.046

-0.005 -0.016 -0.046 -0.060 -0.060 -0.004 -0.013 -0.036 -0.047 -0.047

-0.011 -0.034 -0.095 -0.124 -0.124 -0.009 -0.027 -0.075 -0.098 -0.098

-0.012 -0.037 -0.106 -0.138 -0.138 -0.010 -0.030 -0.084 -0.109 -0.109

-0.013 -0.040 -0.114 -0.149 -0.149 -0.010 -0.032 -0.090 -0.118 -0.118 2035 2040

-0.059 -0.059 -0.046 -0.046

-0.060 -0.060 -0.047 -0.047

-0.124 -0.124 -0.098 -0.098

-0.138 -0.138 -0.109 -0.109

-0.149 -0.149 -0.118 -0.118 Extrapolation 2043

-0.059 -0.046

-0.060 -0.047

-0.124 -0.098

-0.138 -0.109

-0.149 -0.118 Cumulative 2013-2043

-1.53 -1.21

-1.56 -1.23

-3.24 -2.56

-3.61 -2.85

-3.89 -3.08

* All results in metric tons (t), equivalent to 1.1 short tons.

h The AP-42 source does not list an approach for how to estimate commercial clothes washer related emissions as a function of the share of total gas deliveries (http://www.epa.gov/ttn/chief/eiip/techreport/volume03/ng.pdf).

i See section 3.2 of a AGA report.

16-13

### 16.2.7 Effects on Upstream Fuel-Cycle Emissions Fuel-cycle emissions refer to the emissions associated with the amount of energy used in the upstream production and downstream consumption of electricity, including energy used at the power plant. Upstream processes include the mining of coal or extraction of natural gas,physical preparatory and cleaning processes, and transportation to the power plant. The NEMSBT does a thorough accounting of emissions at the power plant due to downstream energy consumption, but does not account for upstream emissions (i.e., emissions from energy losses during coal and natural gas production). Thus, this analysis reports only power plant emissions. However, previous DOE environmental assessment documents have developed qualitative estimates of affects on upstream fuel-cycle emissions. These emissions factors provide the reader with a sense of the possible magnitude of upstream effects. These upstream emissions would be in addition to emissions from direct combustion. Relative to the entire fuel cycle, estimates based on the work of Dr. Mark DeLuchi, and reported in earlier DOE environmental assessment documents, find that an amount approximately equal to eight percent, by mass, of emissions (including SO 2 

### ) from coal production are due to mining, preparation that includes cleaning the coal, and transportation from the mine to the power plant. 7 

### Transportation emissions include emissions from the fuel used by the mode of transportation that moves the coal from the mine to the power plant. In addition, based on Dr. DeLuchi’s work, DOE estimated that approximately an amount equal to 14 percent of emissions from natural gas production result from upstream processes. Emission factor estimates and corresponding percentages of contributions of upstream emissions from coal and natural gas production, relative to power plant emissions, are shown in Table 16.2.5 for CO 2 

### and NOx. The percentages are relative to power plant emissions and provide a means to estimate upstream emission savings based on changes in emissions from power plants. The percentage effects presented in Table 16.2.5 provides a qualitative approach to viewing effects on fuel cycle emissions. The previous section indicates slight overall reductions in CO 2 

### and NOx. Thus, very small reductions in upstream emissions of air pollutant could be expected. This approach does not address Hg emissions. Table 16.2.5	 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct Power Plant Combustion Emissions

Pollutant Percent of Coal Combustion Emissions Percent of Natural Gas Combustion Emissions CO 2 2.7 11.9 NOx 5.8 40

16-14

### 16.3 WETL AND, ENDANGERED AND THREATENED SPECIES, AND CULTURAL RESOURCES Because commercial clothes washers are a water-consuming product, more efficient washers reduce the amount of water discharged into the waste stream. As a result, commercial clothes washer energy efficiency standards have the effect of potentially improving the quality of wetlands, and threatened or endangered species that reside in these wetlands. This action is not expected to impact cultural resources such as historical or archaeological sites. To determine the potential benefits to wetlands from the reductions of wastewater discharge due to commercial clothes washer standards, DOE estimated the amount of commercial clothes washer water use and the typical amount of water retention in a clothes load after a wash cycle. Table 16.3.1 and Table 16.3.2 show the remaining moisture content (RMC) and total water use as a function of clothes washer efficiency for top-loading and front-loading washers (both the RMC and water use were first presented in Chapter 6, section 6.3.1 of this TSD). Based on the RMC of the clothes after a wash cycle, DOE estimated that approximately two percent of washer water use is retained in the clothes load at the baseline efficiency level. The RMC decreases as a function of efficiency, thereby decreasing the amount of water retention in the clothes. But the amount of water use decreases with clothes washer efficiency as well. Because the rate of water use savings grows at approximately double the rate of water retention, the increased amount of water retained in the clothes as a percentage of the water use savings drops from approximately two percent to one percent over the range of clothes washer efficiencies considered. Therefore, assuming that water not retained in the clothes load is discharged into the wastewater stream, wastewater discharge savings range from 98 to 99 percent of the water use savings at the baseline and max-tech levels, respectively (see Tables 16.3.1 and 16.3.2). Note that TSL 1 for top-loading washers actually yields an increase in wastewater discharge because the water factor of the clothes washer does not increase but less water is retained in the clothes due to the lower RMC.

16-15

### Table 16.3.1 Top-Loading Commercial Clothes Washers: Per-Cycle Water Use and Water Discharge Savings by TSL Total Water Use Water Discharge Savings

MEF WF Amount Savings WI** WC** Water Retention in Clothes*** Amount Savings as percent of Water Use Savings CSL TSL cu.ft./kWh/cyc gal/cu.ft. RMC* gal/cyc gal/cyc lbs/cyc lbs/cyc gal/cyc gal/cyc gal/cyc percent Baseline

- 1.26 9.50 53.7% 26.6

- 7.35 11.30 0.47 26.1

- - 1 1, 2 1.42 9.50 51.2% 26.6 0.00 7.35 11.11 0.45 26.1 -0.02 Incr. 2 3, 4, 5 1.60 8.50 48.4% 23.8 2.80 7.35 10.91 0.43 23.4 2.75 98.3% * Based on the relationship: RMC = -0.156* MEF + 0.734 ** WI = Initial Weight of Dry Test Load. WC = Weight of Test Load after Extraction. Values based on a container volume of 2. 8 cu.ft. and an average test-load weight of 11.7 lb/cycle. *** Based on water density of 8.33 lbs/gallon. 

### Table 16.3.2	 Front-Loading Commercial Clothes Washers: Per-Cycle Water Use and Water Discharge Savings by TSL

CSL TSL MEF WF RMC* Total Water Use

WI** WC** Water Retention in Clothes*** Water Discharge

Amount Savings Amount Savings Savings
as percent of Water Use Savings cu.ft./kWh/cyc gal/cu.ft. gal/cyc gal/cyc lbs/cyc lbs/cyc gal/cyc gal/cyc gal/cyc percent Baseline

- 1.72 8.00 46.5% 22.4

- 7.35 10.77 0.41 22.0

- - 1 1 1.80 7.50 45.3% 21.0 1.40 7.35 10.68 0.40 20.6 1.39 99.2% 2 2, 3 2.00 5.50 42.2% 15.4 7.00 7.35 10.45 0.37 15.0 6.96 99.4% 3 4 2.20 5.10 39.0% 14.3 8.12 7.35 10.22 0.34 13.9 8.05 99.2% 4 5 2.35 4.40 36.7% 12.3 10.08 7.35 10.55 0.32 12.0 9.99 99.1% * Based on the relationship: RMC = -0.156* MEF + 0.734 ** WI = Initial Weight of Dry Test Load. WC = Weight of Test Load after Extraction. Values based on a container volume of 2. 8 cu.ft. and an average test-load weight of 11.7 lb/cycle. *** Based on water density of 8.33 lbs/gallon. 

### Table 16.3.3 shows the national wastewater discharge reductions due to the trial standard levels for commercial clothes washers. For comparison purposes, the national water savings due to the commercial clothes washer trial standard levels are also provided in the table to show how the wastewater discharge reductions compare to the national water savings. The national water savings were first presented in Chapter 11, section 11.5.2 of this TSD.

16-16

### Table 16.3.3	 Summary of National Wastewater Discharge Reductions and National Water Savings due to Commercial Clothes Washer Standards (Cumulative reductions for products sold from 2013 to 2043) 1 2 3 4 5 Water Savings (billion galons) 1 6 143 163 209 Wastewater Reduction (billion gallons) 0.4 5 141 161 206



### 16.4 SOCIOECONOMIC IMPACTS DOE's analysis has shown that the increase in the first cost of purchasing more efficient commercial clothes washers at the proposed standard level is completely offset by a reduction in the life-cycle cost (LCC) of owning a more efficient piece of equipment. In other words, the customer will pay less operating costs over the life of the equipment even through the first cost increases. The complete analysis and its conclusions are presented in Chapter 8 of the TSD. For subgroups of small businesses and building owners without municipal water and wastewater that purchase commercial clothes washers, DOE determined that the average LCC impact is similar to that for the full sample of consumers. Therefore, DOE concludes that the proposed action would have no significant socioeconomic impact. For a complete discussion on the LCC impacts on consumer subgroups, see Chapter 12 of the TSD. Table 16.4.1 shows the mean LCC savings for both the full sample of consumers and subgroup of consumers for commercial clothes washers.

16-17

### Table 16.4.1 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, Commercial Clothes Washers Trial Standard Level 1 2 3 4 5 Top-Loading Washers, Multi-Family Application All Consumers -$8 -$8 $179 $179 $179 Small Business Subgroup -$22 -$22 $113 $113 $113 No Municipal Water/Wastewater Subgroup -$8 $8 $184 $184 $184 Top-Loading Washers, Laundromat Application All Consumers -$18 -$18 $190 $190 $190 Small Business Subgroup -$26 -$26 $141 $141 $141 No Municipal Water/Wastewater Subgroup -$18 -$18 $196 $196 $196 Front-Loading Washers, Multi-Family Application All Consumers $5 $19 $19 $91 $203 Small Business Subgroup $4 $15 $15 $69 $152 No Municipal Water/Wastewater Subgroup $5 $20 $20 $95 $210 Front-Loading Washers, Laundromat Application All Consumers $5 $22 $22 $93 $216 Small Business Subgroup $4 $15 $15 $76 $176 No Municipal Water/Wastewater Subgroup $5 $22 $22 $96 $223



### 16.5 ENVI RONMENTAL JUSTICE IMPACTS According to Executive Order 12898 of February 11, 1994, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,” DOE is required to examine the effect of more stringent energy-efficiency standards on (1) small businesses that either manufacture or use commercial clothes washers, (2) manufacturers of niche products related to commercial clothes washers, and (3) small businesses operated by disadvantaged or minority populations. DOE identified small businesses as a subgroup that possibly could be disproportionatelyaffected by commercial clothes washer energy conservation standards. As described in the LifeCycle Cost Subgroup Analysis, Chapter 12 of the TSD, DOE found that there was no disproportionately high and adverse human health or environmental effects on small businesses that would result from the proposed energy conservation standards. DOE believes that above conclusion also applies to minority populations.

16-18

### 16.6 NOISE AND AESTHETICS Improvements in efficiency of commercial clothes washers is expected to result from changes in the choice of components and other design features. These changes are described in Chapter 5 of this TSD. These design changes are not expected to change noise levels in comparison to equipment in today’s market. Equipment that is currently manufactured in the existing market that would meet the proposed standards is no louder than less efficient equipment. Changes to the design to improve the efficiency levels are not anticipated to affect the equipment’s aesthetics.

16.7 SUMMARY OF ENVIRONMENTAL IMPACTS Table 16.7.1 summarizes anticipated environmental impacts for each of the TSLs across all equipment types. Air quality impacts were modeled for each of the TSLs. The summary table shows cumulative changes in emissions for CO 2 

### , NOx, and Hg over the period 2013 to 2043. The resulting changes in emission quantities are very small. Cumulative CO 2 

### , NO x 

### , and Hg emissions show a decrease compared to the reference case. Hg emissions show a very small increase in cumulative emissions. This increase may result from the combined effects of emissions banking, a shift in how power plants are dispatched, or the timing within the model of when power plants are replaced. Upstream fuel cycle emission of CO 2 

### and NO x 

### are described but not quantified in section 16.2.7. The text describes potential reductions in fuel cycle emissions as percentage of decreases in power plant emissions. This qualitative approach suggests that upstream fuel cycle emissions would decrease and provides a sense for the magnitude of effects, however DOE does not report actual estimates of the effects. This approach does not address Hg emissions. Socioeconomic impacts are presented as changes in life cycle costs. No impacts are anticipated in the area of environmental justice; wetlands, endangered and threatened species, and cultural resources; or noise and aesthetics.

16-19

### Table 16.7.1 Environmental Impact Analysis Results Summary for Commercial Clothes Washers

Environmental Effects Reference Case* Trial Standard Level 1 2 3 4 5 Cumulative Total Emission Reductions** CO 2 (Million metric tons) 86,206 -2.36 -2.39 -5.07 -5.66 -6.11 NO X (Thousand tons) 60,796 -1.43 -1.45 -3.04 -3.39 -3.66 Hg (tons) High Emission Rate Estimate 519 -0.01 -0.01 -0.03 -0.03 -0.03 Low Emission Rate Estimate 519 0.00 0.00 0.00 0.00 0.00 Cumulative Power Sector Emission Reductions** CO 2 (Million metric tons) 86,206 -0.82 -0.84 -1.83 -2.05 -2.22 NO X (Thousand tons) 60,796 0.22 0.22 0.48 0.54 0.59 Hg (tons) High Emission Rate Estimate 519 -0.01 -0.01 -0.03 -0.03 -0.03 Low Emission Rate Estimate 519 0.00 0.00 0.00 0.00 0.00 Cumulative Building Emission Reductions** CO 2 (Million metric tons)

- -1.53 -1.56 -3.24 -3.61 -3.89 NO X (Thousand tons)

- -1.21 -1.23 -2.56 -2.85 -3.08 Fuel-Cycle (Upstream) Emissions NA *** *** *** *** *** Wetlands, Endangered and Threatened Species, Cultural Resources**

Wastewater Discharge Impact (billion gal)

- -0.4 -5 -141 -161 -206 Socioeconomic Impacts - Mean LCC Savings† Top-Loading Multi-Family Application All Consumers

- -$8 -$8 $179 $179 $179 Small Business Subgroup

- -$22 -$22 $113 $113 $113 No Municipal Water/Wastewater Subgroup

- -$8 $8 $184 $184 $184 Top-Loading Laundromat Application All Consumers

- -$18 -$18 $190 $190 $190 Small Business Subgroup

- -$26 -$26 $141 $141 $141 No Municipal Water/Wastewater Subgroup

- -$18 -$18 $196 $196 $196 Front-Loading Multi-Family Application All Consumers

- $5 $19 $19 $91 $203 Small Business Subgroup

- $4 $15 $15 $69 $152 No Municipal Water/Wastewater Subgroup

- $5 $20 $20 $95 $210 Front-Loading Multi-Family Application All Consumers

- $5 $22 $22 $93 $216 Small Business Subgroup

- $4 $15 $15 $76 $176 No Municipal Water/Wastewater Subgroup

- $5 $22 $22 $96 $223 Environmental Justice NA None None None None None Noise and Aesthetics NA None None None None None * The reference case values reflect total cumulative emissions in the absence of an energy standard. ** Cumulative total is over a time period from 2013 to 2043. Negative values refer to emission/wastewater reductions. *** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 16.2.7 provides a sens e for the possible magnitude of effects. † Values refer to life-cycle cost savings over the equipment lifetime.

16-20

### REFERENCES

1 

### U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical Support Document: Energy Efficiency Program for Consumer Products and Commercial and Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and Commercial Clothes Washers , September, 2008. Washington, DC.
< http://www1.eere.energy.gov/buildings/appliance_standards/residential/home_appl_tsd.html >

2 

### U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy Conservation Standards for Certain Consumer Products (Dishwashers, Dehumidifiers, Microwave Ovens, and Electric and Gas Kitchen Ranges and Ovens) and for Certain Commercial and Industrial Equipment (Commercial Clothes Washers); Final Rule. Federal Register , 2009. 74(66): pp. 16040-16096.

3 

### U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical Support Document: Energy Efficiency Program for Consumer Products and Commercial and Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and Commercial Clothes Washers , March, 2009. Washington, DC.
< http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_final_rul e_tsd.html >

4 

### U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and Reinvestment Act and Recent Changes in the Economic Outlook , April, 2009. Washington, DC. SR/OIAF/2009-03.
< http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf >

5 

### U.S. Environmental Protection Agency, Emission Inventory Improvement Program, Technical Report Series Volume 3, Area Sources . Washington, DC.
< http://www.epa.gov/ttn/chief/eiip/techreport/volume03/ >

6 

### American Gas Association, Source Energy and Emission Factors for Residential Energy Consumption , 2000. Washington, DC. August.
< http://www.aga.org/NR/rdonlyres/F17F15FC-FC7D-4469-B8E2­ 14F26FFAC440/0/0008ENERGYEMISSIONFACTORSRESCONSUMPTION.pdf >

7 

### DeLuchi, M. A. Emissions of Greenhouse Gases from 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.

16-21