10

- i CHAPTER 1 0

. MONETIZATION OF EMISSION REDUCTIONS BENEFITS

TABLE OF CONTENTS

10.1 INTRODUCTION

................................ ................................ ................................ ......... 10

- 1

10.2 MONETIZING CARBON DIOXIDE EMISSIONS

................................ ..................... 10

- 1

10.2.1 Social Cost of Carbon

................................ ................................ ................................ .... 10

- 1

10 .2.2 Social Cost of Carbon Values Used in Past Regulatory Analyses

................................ . 10

- 3

10.2.3 Current Approach and Key Assumptions

................................ ................................ ...... 10

- 4

10.3 VALUATION OF OTHER EMISSIONS REDUCTIONS

................................ ........... 10

- 5

10.4 RESULTS

................................ ................................ ................................ ...................... 10

- 6

LIST OF TABLES

Table 10.2.1 Social Cost of CO 2 , 2010

– 2050 (in 2007 dollars per metric ton)

.................... 10

- 2

Table 10.4.1 ASHRAE Products Estimates of Global Present Value of CO 2 Emissions Reduction Under Efficiency Levels

................................ ................................ ... 10

- 6

Table 10.4.2 ASHRAE Products Estimates of Domestic Present Value of CO 2 Emissions Reduction Under Efficiency Levels

................................ ................. 10

- 7

Table 10.4.3 ASHRAE Products Estimates of Present Value of NO X Emissions Reduction Under Efficiency Levels

................................ ................................ ... 10

- 810

- 1 CHAPTER 10. MONETIZATION OF EMISSION REDUCTIONS BENEFITS

10.1 INTRODUCTION

As part of its assessment of energy conservation standards , DOE considered the estimated monetary benefits likely to result from the reduced emissions of carbon dioxide ( CO 2 ) and nitrogen oxides (NO X ) that are expected to result from each of the Efficiency Level s considered.

This c hapter summarizes the basis for the estimated monetary values used for each of these emissions and presents the benefits estimates considered.

10.2 MONETIZING CARBON DIOXIDE EMISSIONS

10.2.1 Social Cost of Carbon

Under Executive Order 12866, agencies must, to the extent permitted by law, “assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned

determination that the benefits of the intended regulation justify its costs.”

The social cost of carbon (SCC) is an estimate of the monetized damages associated with an incremental increase in carbon emissions in a given year. It is intended to include (but is not limited to) changes in net agricultural productivity, human health, property damages from increased flood risk, and the value of ecosystem services. Estimates of the SCC are provided in dollars per metric ton of carbon dioxide.

The purpose of the SCC estimates presented here is to allow agencies to incorporate the monetized social benefits of reducing CO 2 emissions into cost

- benefit analyses of regulatory actions that have small, or “marginal,” impacts on cumulative global emissions. The estimates are presented with an acknowl edgement of the many uncertainties involved and with a clear understanding that they should be updated over time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed these SCC estimates, technical experts from numerous agencies met on a regular basis to consider public comments, explore the technical literature in relevant fields, and discuss key model inputs and assumptions. The main objective of this process was to develop a r ange of SCC values using a defensible set of input assumptions grounded in the existing scientific and economic literatures. In this way, key uncertainties and model differences transparently and consistently inform the range of SCC

estimates used in the r ulemaking process.

The interagency group selected four SCC values for use in regulatory analyses. Three values are based on the average SCC from three integrated assessment models, at discount rates10

- 2 of 2.5, 3, and 5 percent. The fourth value, which repr esents the 95th percentile SCC estimate across all three models at a 3 percent discount rate, is included to represent higher

- than

- expected impacts from temperature change further out in the tails of the SCC distribution. For emissions (or emission reducti ons) that occur in later years, these values grow in real terms over time, as depicted in Table 1 0 .2.1

.

Table 10.2.1 Social Cost of CO 2 , 2010

– 2050 (in 2007 dollars per metric ton)

Discount Rate

5% 3% 2.5% 3%

Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

When attempting to assess the incremental economic impacts of carbon dioxide emissions, the analyst faces a number of serious challenges. A recent report from the National

Research Council a points out that any assessment will suffer from uncertainty, speculation, and lack of information about (1) future em issions of greenhouse gases, (2) the effects of past and future emissions on the climate system, (3) the impact of changes in climate on the physical and biological environment, and (4) the translation of these environmental impacts into economic damages. As a result, any effort to quantify and monetize the harms associated with climate change will raise serious questions of science, economics, and ethics and should be viewed as provisional.

Despite the serious limits of both quantification and monetiza tion, SCC estimates can be useful in estimating the social benefits of reducing carbon dioxide emissions. Consistent with the directive quoted above, the purpose of the SCC estimates presented here is to make it possible for agencies to incorporate the soc ial benefits from reducing carbon dioxide emissions into cost

benefit analyses of regulatory actions that have small, or “marginal,” impacts on cumulative global emissions. Most Federal regulatory actions can be expected to have marginal impacts on global emissions.

a National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use

. National Academies Press : Washington, DC . 2009

.10

- 3 For such policies, the agency can estimate the benefits from reduced (or costs from increased) emissions in any future year by multiplying the change in emissions in that year by the SCC value appropriate for that year. The net present value of the benefits can then be calculated by multiplying each of these future benefits by an appropriate discount factor and summing across all affected years. This approach assumes that the marginal damages from increased emissions are constant for small dep artures from the baseline emissions path, an approximation that is reasonable for policies that have effects on emissions that are small relative to cumulative global carbon dioxide emissions. For policies that have a large (non

- marginal) impact on global cumulative emissions, there is a separate question of whether the SCC is an appropriate tool for calculating the benefits of reduced emissions. DOE does not attempt to answer that question here.

It is important to emphasize that the interagency process i s committed to updating these estimates as the science and economic understanding of climate change and its impacts on society improves over time. Specifically, the interagency group has set a preliminary goal of revisiting the SCC values within two years or at such time as substantially updated models become available, and to continue to support research in this area. In the meantime, the interagency group will continue to explore the issues raised by this analysis and consider public comments as part of t he ongoing interagency process.

10.2.2 Social Cost of Carbon Values Used in Past Regulatory Analyses

To date, economic analyses for Federal regulations have used a wide range of values to estimate the benefits associated with reducing carbon dioxide emissions. I n the final model year 2011 CAFE rule, the Department of Transportation (DOT) used both a “domestic” SCC value of $2 per ton of CO 2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions (in 2007 dollars), increasing both values at 2.4 percent per year. It also included a sensitivity analysis at $80 per ton of CO 2 . A domestic SCC value is meant to reflect the value of damages in the United States resulting from a unit change in carbon dioxide emissions, while a global

SCC value is mean t to reflect the value of damages worldwide.

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton of CO 2 (in 2006 dollars) for 2011 emission reductions (with a range of $0

- $14 for sensitivity analysis), also increasing at 2.4 perc ent per year. A regulation finalized by DOE in October of 2008 used a domestic SCC range of $0 to $20 per ton CO 2 for 2007 emission reductions (in 2007 dollars). In addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified what it described as “very preliminary” SCC estimates subject to revision. EPA’s global mean values were $68 and $40 per ton CO 2 for discount rates of approximately 2 percent and 3 percent, respectively (in 2006 dollars for 2007 emissions).

In 2009, an i nteragency process was initiated to offer a preliminary assessment of how best to quantify the benefits from reducing carbon dioxide emissions. To ensure consistency in how benefits are evaluated across agencies, the Administration sought to develop a tran sparent and defensible method, specifically designed for the rulemaking process, to quantify avoided climate change damages from reduced CO 2 emissions. The interagency group did not undertake any original analysis. Instead, it combined SCC estimates from t he existing literature to use as interim values until a more comprehensive analysis could be conducted.10

- 4 The outcome of the preliminary assessment by the interagency group was a set of five interim values: global SCC estimates for 2007 (in 2006 dollars) o f $55, $33, $19, $10, and $5 per

ton of CO 2 . The $33 and $5 values represented model

- weighted means of the published estimates produced from the most recently available versions of three integrated assessment models

— DICE (Dynamic Integrated Climate Econom y), PAGE (Policy Analysis of the Greenhouse Effect), and FUND (Climate Framework for Uncertainty, Negotiation and Distribution)

— at approximately 3 and 5 percent discount rates. The $55 and $10 values were derived by adjusting the published estimates for un certainty in the discount rate (using factors developed by Richard Newell and William Pizer) b at 3 and 5 percent discount rates, respectively. The $19 value was chosen as a central value between the $5 and $33 per ton estimates. All of these values were

as sumed to increase at 3 percent annually to represent growth in incremental damages over time as the magnitude of climate change increases.

These interim values represent the first sustained interagency effort within the U.S. government to develop an SCC for use in regulatory analysis. The results of this preliminary effort were presented in several proposed and final rules and were offered for public comment in connection with proposed rules, including the joint EPA

- DOT fuel economy and CO 2 tailpipe

emiss ion proposed rules.

10.2.3 Current Approach and Key Assumptions

Since the release of the interim values, the interagency group reconvened on a regular basis to generate improved SCC estimates, which were considered for this proposed rule. Specifically, the grou p considered public comments and further explored the technical literature

in relevant fields.

It is important to recognize that a number of key uncertainties remain, and that current SCC estimates should be treated as provisional and revisable since the y will evolve with improved scientific and economic understanding. The interagency group also recognizes that the existing models are imperfect and incomplete. The National Research Council report mentioned above points out that there is tension between th e goal of producing quantified estimates of the economic damages from an incremental ton of carbon and the limits of existing efforts to model these effects. There are a number of concerns and problems that should be addressed by the research community, in cluding research programs housed in many of the agencies participating in the interagency process to estimate the SCC.

The U.S. Government intends to periodically review and reconsider estimates of the SCC

used for cost

- benefit analyses to reflect increa sing knowledge of the science and economics of climate impacts, as well as improvements in modeling. In this context, statements recognizing the limitations of the analysis and calling for further research take on exceptional significance. The interagency group offers the new SCC values with all due humility about the uncertainties embedded in them and with a sincere promise to continue work to improve them.

b R. Newell and W. Pizer. “Discounting the Distant Future: How Much Do Uncertain Rates Increase Valuations?” J. Environ. Econ. Manage. 46 (2003) 52

- 71)10

- 5 In summary, in considering the potential global benefits resulting from reduced CO 2 emissions, DOE used the most recent values identified by the interagency process, adjusted to

20 1 0$ using the standard GDP deflator values for 2008 and 2009. For each of the four cases specified, the values used for em issions in 2010 were $ 5.0 , $22. 7 , $ 37.2 , and $ 68.8 per metric ton avoided (values expressed in 2011 $). To monetize the CO 2 emissions reductions expected to

result from conse rvation standards for water and evaporatively cooled products, VRF water source heat pumps, and computer room air conditioners , DOE u sed the values identified in Table A1 of the “Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866,” which is reprinted in appendix 10

- A of this TSD , appropriately escalated to 2011 $. To calculate a present value of the stream o f monetary values, DOE discounted the values in each of the four cases using the discount rates that had been used to obtain the SCC values in each case.

10.3 VALUATION OF OTHER EMISSIONS REDUCTIONS

As discussed in chapter 9 , DOE’s analysis assumed the presence of nationwide emission caps on SO 2 and caps on NO X emissions in the 28 States covered by the CAIR. In the presence of these caps, the NEMS

– BT modeling system that DOE used to forecast emissions reduction indicated that no physical reductions in po wer sector emissions would occur for SO 2 , but that the standards could put slight downward pressure on the prices of emissions allowances in cap

- and

trade markets. Estimating this effect is very difficult because such factors as credit banking can change t he trajectory of prices. From its modeling to date, DOE is unable to estimate a benefit

from SO 2 emissions reductions at this time.

DOE investigated the potential monetary benefit of reduced NO X emissions from the Efficiency Level s it considered. As note d above, new or amended energy conservation standards

would reduce NO X emissions in those 22 States that are not affected by the CAIR, in addition to

the reduction in site NO X emissions nationwide. DOE estimated the monetized value of NO X emissions reducti ons resulting from each of the Efficiency Level s considered for today’s NOPR based on environmental damage estimates from the literature. Available estimates suggest a very wide range of monetary values, ranging from $370 per ton to $3,800 per ton of NO X f rom stationary sources, measured in 2001 $ (equivalent to a range of $ 454 to $4, 672 per ton in

2011 $). c In accordance with OMB guidance , DOE conducted two calculations of the monetary benefits derived using each of the economic values used for NO X , one using a real discount rate of 3 percent and another using a real discount rate of 7 percent. d

DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating the potential economic benefits of reduced Hg emis sions. DOE has decided to await further guidance regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its rulemakings.

c F or additional information , refer to U.S. Office of Management and Budget , Office of Information and Regulatory Affairs, ‘‘2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tr ibal Entities,’’ Washington, DC

. d OMB, Circular A

- 4: Regulatory Analysis ( Se pt. 17, 2003).10

- 6 10.4 RESULTS

Table 1 0 .4.1 present s the global values of CO 2 emissions reductions at each Effici ency Level . DOE calculated domestic values as a range from 7 percent to 23 percent of the global values, and these results are presented in Table 1 0 .4.2

.

Table 10.4.1 ASHRAE Products Estimates of Global Present Value of CO 2 Emissions

Reduction Under Efficiency Levels

Eff.

Level Million 201 1 $

5% discount
rate, average* 3% discount
rate, average* 2.5% discount rate, average* 3% discount rate, 95 th
percentile*

Water and Evaporative Cooled Products

1 0.5 2.4 4.1 7.4

2 0.5 2.5 4.3 7.7

3 1.2 6.3 10.6 19.1

4 1.8 9.0 15.2 27.4

5 1.8 9.2 15.6 28.1

VRF Water Source Heat Pumps

1 0.0 0.0 0.0 0.0

2 0.3 1.4 2.3 4.2

3 4.3 22.5 38.1 68.4

4 10.3 53.7 91.1 163.4

5 18.9 98.1 166.5 298.5

Computer Room Air Conditioners

1 0.9 4.7 7.9 14.4

2 11.2 57.5 97.4 175.2

3 48.2 246.7 417.5 751.4

4 119.9 613.9 1038.7 1869.3

5 214.6 1099.0 1859.6 3346.6

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the distribution. Values presented in the table are based on escalating 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC over time.10

- 7 Table 10.4.2 ASHRAE Products Estimates of Domestic Present Value of CO 2 Emissions Reduction Under E fficiency Levels

Eff.

Level 5% discount rate, average* Million 2011 $

3% discount rate, average* 2.5% discount rate, average* 3% discount rate,

95 th percentile*
Water and Evaporative Cooled Products

1 0.03 to 0.09 0.13 to 0.44 0.22 to 0.74 0.41 to 1.33

2 0.03 to 0.08 0.13 to 0.42 0.22 to 0.71 0.39 to 1.29

3 0.07 to 0.22 0.34 to 1.11 0.57 to 1.87 1.03 to 3.40

4 0.10 to 0.32 0.49 to 1.59 0.82 to 2.68 1.48 to 4.86

5 0.10 to 0.33 0.50 to 1.63 0.84 to 2.74 1.51 to 4.97
VRF Water Source Heat Pumps

1 0.00 to 0.0 0.0 to 0.0 0.0 to 0.0 0.0 to 0.0

2 0.01 to 0.05 0.07 to 0.24 0.12 to 0.40 0.22 to 0.72

3 0.22 to 0.72 1.10 to 3.61 1.85 to 6.08 3.35 to 11.0

4 0.52 to 1.72 2.61 to 8.58 4.40 to 14.4 7.96 to 26.2

5 0.96 to 3.14 4.78 to 15.7 8.04 to 26.4 14.6 to 47.9
Computer Room Air Conditioners

1 0.05 to 0.16 0.24 to 0.78 0.40 to 1.31 0.72 to 2.38

2 0.58 to 1.89 2.87 to 9.42 4.82 to 15.8 8.74 to 28.7

3 2.17 to 7.13 10.8 to 35.5 18.2 to 59.7 32.9 to 108

4 5.05 to 16.6 25.1 to 82.6 42.3 to 139 76.6 to 252

5 8.38 to 27.5 41.8 to 137 70.3 to 231 127 to 418

* Domestic values are presented as a range between 7% and 23% of the global values.

** Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the distribution. Values presented in the table are based on escalating 2007$ to 20 1 0$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC over time.10

- 8 Table 1 0 .4.3 present s the cumulative monetary value of the economic benefits associated

with NO X emissions reductions for each Efficiency Level

, calculated using seven

- percent and

three

- percent discount rates.

Table 10.4.3 ASHRAE Products Estimates of Present Value of NO X Emission s Reduction Under Efficiency Levels

Eff.

Level 3% discount rate 7% discount rate (million 201 1 $)
Water and Evaporative Cooled Products (million 201 1 $)

1 0.02 to 0.25 0.01 to 0.12

2 0.02 to 0.24 0.01 to 0.10

3 0.06 to 0.64 0.03 to 0.28

4 0.09 to 0.92 0.04 to 0.40

5 0.09 to 0.95 0.04 to 0.42 VRF Water Source Heat Pumps

1 0.0 to 0.0 0.0 to 0.0

2 0.01 to 0.13 0.01 to 0.05

3 0.2 to 2.2 0.1 to 0.9

4 0.5 to 5.2 0.2 to 2.2

5 0.9 to 9.5 0.4 to 4.0 Computer Room Air Conditioners

1 0.04 to 0.46 0.02 to 0.22

2 0.6 to 6.1 0.3 to 2.7

3 2.4 to 24.6 1.0 to 10.7

4 6.0 to 61.4 2.6 to 26.6

5 10.7 to 109.8 4.6 to 47.6