APPENDIX Q. LIST OF ACRONYMS AND ABBREVIATIONS

Q-i

EE-RM-PET-100 COMMENT 88
APPENDIX Q. LIST OF ACRONYMS AND ABBREVIATIONS

§: Section

Act or EPCA: Part B of Title ifi of the Energy Policy and Conservation Act, Public Law 94-163,

as amended by the National Energy Conservation Policy Act, Public Law 95-619, the National

Appliance Energy Conservation Act, Public Law 100-12, the National Appliance Energy

Conservation Amendments of 1988, Public Law 100-357, and the Energy Policy Act of 1992, Public

Law 102-486

ADL: Arthur D. Little

AEC: Annual Energy Consumption

AEO: Annual Energy Outlook, DOE/ETA publication

AGA: American Gas Association

AHAM: Association of Home Appliance Manufacturers

ANOPR: Advance Notice of Proposed Rulemaking

ARIMA: Auto-Regressive Moving Average Model

ASME: American Society of Mechanical Engineers

AWWA: American Water Works Association

BLS: Bureau of Labor Statistics

BOM: Bill of Materials

Btu: British thermal unit

C: carbon

CAPM: capital asset pricing model

ccf: hundreds of cubic feet

CEE: Consortium for Energy Efficiency

Q-1

EE-RM-PET-100 COMMENT 88
CES: Consumer Expenditure Surveys

CFR: Code of Federal Regulations

CH2: methane

CIR: Current Industrial Reports

CM: Census of Manufactures

CO: carbon monoxide

C02: carbon dioxide

CRADA: Cooperative Research and Development Agreement

CRF: capital recovery factor

cu.ft.: cubic feet

CW: clothes washer

DOD: Department of Defense

DOE: Department of Energy

DOJ: Department of Justice

EA: Environmental Assessment

EEl: Edison Electric Institute

EF: Energy Factor

EIA: Energy Information Administration

EJ: exajoules (1018 joules)

ELCAP: Elrick & Lavidge Computerized Audit Program

E.O.: Executive Order

EPCA: Energy Policy and Conservation Act

Q-2

EE-RM-PET-100 COMMENT 88
EPA: Environmental Protection Agency

EPRI: Electric Power Research Institute

FASB: Financial Accounting Standards Board

FEMP: Federal Energy Management Program

ft.3: cubic feet

FR: Federal Register

G & A: General and Administrative

GAAP: Generally Accepted Accounting Principles

GJ: gigajoules (lOg joules)

GRI: Gas Research Institute

GRIM: Government Regulatory Impact Model

H-axis: horizontal axis

ImBuild: Impact of Building Energy Efficiency Programs model

kt/a: thousand metric tons per year

kWh: kilowatt-hour

LBNL: Lawrence Berkeley National Laboratory

LCC: Life-Cycle Cost

LPG: Liquid petroleum gas

MACT: Maximum Achievable Control Technology

MIA: Manufacturer Impact Analysis

MEF: Modified Energy Factor

MMBtu: million Btu

Q-3

EE-RM-PET-100 COMMENT 88
Mt/a: megatons (1 6 metric tons) per year

NAPSA: National Appliance Parts Suppliers Association

NAECA: National Appliance Energy Conservation Act

NCYCLE: Cycles per year

NEEP: Northeast Energy Efficiency Partnership

NEMS: National Energy Modeling System

NEPA: National Environmental Policy Act of 1969

NMOC: Non-methane organic compound

NES: National Energy Savings

NWEEA: WashWise - Northwest Energy Efficiency Alliance

NOPR: Notice of Proposed Rulemaking

NOx: nitrogen oxides

NPV: net present value

NYSE: New York Stock Exchange

OIRA: Office of Information and Regulatory Affairs

0MB: Office of Management and Budget

ORNL: Oak Ridge National Laboratory

PBP: Payback period

PEA: Pacific Energy Associates

PECI: Portland Energy Conservation Inc.

PG&E: Pacific Gas & Electric

PNNL: Pacific Northwest National Laboratory

Q-4

EE-RM-PET-100 COMMENT 88
pwh: petawatt-hours (1 15 watt-hours)

Quads: quadrillion Btu

R&D: Research and Development

RECS: Residential Energy Consumption Survey, DOE/ETA publication

RECW: resource-efficient clothes washers

RMC: remaining moisture content

RPP: rebuttable payback period

SEC: Securities and Exchange Commission

S & P: Standard & Poor's

Sat: saturation

SDA: Soap and Detergent Association

SDA&E: San Diego Gas & Electric

SEC: Securities and Exchange Commission

SG&A: Sales, General, & Administration

SIC: Standard Industrial Classification

S/L: saturationllifetime

SMUD: Sacramento Municipal Utility District

SO2: sulfur dioxide

srcconv: source conversion factor

STOCKY: Stock of clothes washers

SWA: shipment weighted average

SD: standard deviation

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EE-RM-PET-100 COMMENT 88
t: metric ton

THELMA: The High Efficiency Laundry Metering & Marketing Analysis

TM: Trade mark

TSD: Technical Support Document

TUF: temperature use factor

UEC: Unit energy consumption

U.S.C.: United States Code

V-axis: vertical axis

WACC: Weighted Average Cost of Capital

Working Group: Clothes Washer Consumer Analysis Working Group

Q-6

EE-RM-PET-100 COMMENT 88
APPENDIX R. LIFE-CYCLE-COST AND NATIONAL ENERGY SAVINGS USING

THE MOST CURRENT RECS 1997 AND AEO 2000 DATA

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R.1 INTRODUCTION R-l

R. 1.1 How Updating RECS and AEO Data Affects the Analysis R- 1

R. 1.1.1 Input Parameter Changes to LCC / Payback Spreadsheet R- 1

R. 1.1.2 Input Parameter Changes to NES / Shipment Spreadsheet . . . . R-2

R.2 LIFE-CYCLE-COST & PAYBACK PERIOD R-2

R.2. 1 Life-Cycle-Cost Results R-3

R.2.2 Distribution Payback Results R-4

R.2.3 Rebuttable Payback Period Results R-4

R.2.4 Comparison of LCC & Payback Period Results R-5

R.3 NATIONAL ENERGY SAVINGS (NES) R-6

R.3. 1 National Energy and Water Savings Results R-6

R.3.2 Comparison of NES Results for AEO99IRECS93 and AEO2000/RECS97 Input

Data R-8

LIST OF TABLES

Table R. 1 Summary of LCC Results R-3

Table R.2 Summary of Payback Period Results R-4

Table R.3 Rebuttable Presumption Payback in Years R-4

Table R.4 LCC for Trial Standard Level 3 R-5

Table R.5 Distribution Payback Periods for Trial Standard Level 3 R-5

Table R.6 Rebuttable Presumption Payback Periods for Trial Standard Level 3 R-5

Table R.7 Reference Case - All Parameters Set to Medium or Average R-6

Table R.8 NES Results: Proposed Rule (MEF=1 .04 in 2004 & MEF = 1.26 in 2007) . . . R-6

Table R.9 Efficiency Level: Energy and Water Savings (proposed rule, TSL 3) R-7

Table R.10 NES Results: Proposed rule (MEF = 1.04 in 2004 & MEF = 1.26 in 2007) . . . R-8

LIST OF FIGURES

Figure R. 1 Distribution of Life-Cycle-Costs Savings for an MEF of 1.26 R-3

Figure R.2 Distribution of Payback Periods for a MEF of 1.26 R-4

R-i

EE-RM-PET-100 COMMENT 88
APPENDIX R. LIFE-CYCLE-COST AND NATIONAL ENERGY SAVINGS USING

THE MOST CURRENT RECS 1997 AND AEO 2000 DATA

R.1 INTRODUCTION

Since the TSD was written for the NOPR, more updated data has become available from

ETA, for both the Residential Energy Consumption Survey (RECS97) and for the Annual Energy

Outlook (AEO2000). This appendix will show that the results and conclusions in the NOPR

TSD are not affected significantly by the new data.

R.1.1 How Updating RECS and AEO Data Affects the Analysis

Updating analysis with more current RECS data and AEO fuel forecasts affects the inputs

to the LCC and NES analysis.

R.1.1.1 Input Parameter Changes to LCC / Payback Spreadsheet

Changes due to RECS

The 1993 version of RECS sampled more households than the 1997 version. After

culling out the households that did not have a clothes washer and a clothes dryer. The 1993

RECS gave a sample size of 4396 households. When the same criteria was used to determine a

sample set from the 1997 RECS, 2833 households were included in the sample. Data from the

RECS database used in the LCC analysis are:

• marginal energy prices (both a distribution and average prices are used in the LCC

spreadsheet),

• cycles per year (based on the number of household occupants and then normalized to an

average of 392 cycles per year to agree with the test procedure),

• to separate households into having rural versus urban for purposes of determining water

and wastewater removal expenses,

differences in the percentages of households using the various fuel types.

Changes due to AEO

The AEO data generated by a variation of the ETA's NEMS program, called NEMS-BRS

provides a year by year forecast of fuel prices. This average fuel price forecast is used to escalate

the marginal price as determined for the year of the RECS data. In other words, to determine a

fuel price escalation rate.

R- 1

EE-RM-PET-100 COMMENT 88
R.1.1.2 Input Parameter Changes to NES/Shipment Spreadsheet

Changes due to RECS

The NES spreadsheet does not use a distribution of fuel prices but does use an average

marginal rate for each fuel type and this is determined from the RECS database of households

having a washer and a dryer.

Changes due to AEO

For the NES, updating to the AEO2000 data has an effect on the forecasted escalation of

fuel prices including: electricity, natural gas, LPG and oil. This in turn affects shipments and the

national energy savings. A change in forecasted shipments also effects the forecasted energy

savings. As in the LCC analysis the fuel price escalation rate is determined from yearly AEO

fuel price forecasts.

NEMS-BRS forecasting model is updated every year and is used to determine the fuel

price forecasts. Other internal changes to the latest version of NEMS-BRS also have an effect on

the NES analysis. Among these is the heat rate (or source conversion factor) used to determine

the source energy consumption. The heat rate varies from appliance to appliance as the average

annual heat rate used depends on the daily and seasonal load profile for a particular appliance.

The clothes washer load profile, uses the same load profile as specified for water heaters. This is

due to water heating being the major load for a clothes washer. The NEMS-BRS heat rate

includes the transmission and distribution losses. Heat rate projections differed significantly

from the AEO 1999 projections.

To be consistent with an updated NEMS-BRS model, the housing completions and

housing stock are also updated with the latest data. There was no significant change in housing

completions.

R.2 LIFE-CYCLE-COST & PAYBACK PERIOD

Rather than redo the entire analysis with the updated RECS97 and AEO2000 data, the

tables below show updated LCC results for only the standard level proposed in the NOPR (TSL

3). These results are compared to the results in the main body of the TSD which are based on

RECS93 and AEO 1999.. (Each table is referenced to the equivalent table in chapter 7 of the

TSD). All results shown here are for the reference AEO scenario, i.e., not high or low economic

growth assumptions.

R-2

EE-RM-PET-100 COMMENT 88
R.2.1 Life-Cycle-Cost Results

Figure R. 1 shows the distribution of life-cycle-costs using input data from RECS97 and

AEO2000. The life-cycle-cost is for the second tier of the proposed standard (TSL 3) which

takes effect in 2007.

10,000 Trials

Forecast: LCC Difference

Frequency Chart 156 Outliers

.032

.024 ____________________________________________________________ II __________________________

317

________________ 237.7

1

-I

.016 158.5

. rD

.008

=

79.25

.000 0

($1,250) ($750) ($250) $250 $750

Certainty is 81.66% from -Infinity to $0 $

Figure R.1 Distribution of Life-Cycle-Cost Savings for an MEF of 1.26

Table R.1 Summary of LCC Results

Trial Change in LCC from Baseline Percent

Std. MEF Shown by Percentiles of the Distribution of Results with

Level (values in $) LCC

Less

0 10 25 50 75 90 100 Mean

than

Baseline

1.O4MEF ($1,011) ($233) ($153) ($86) ($37) ($1) $116 ($105) 90

in 2004

3

1.26 MEF ($2,784) ($701) ($444) ($216) ($49) $85 $620 ($269) 82

in 2007

See '[able 7.6 for RECS 93 / AEO 99 version

R-3

EE-RM-PET-100 COMMENT 88
R.2.2 Distribution Payback Period Results

10,000 Trials

Forecast: Payback (yrs)

Frequency Chart 180 Outliers

.046

.034

'

- 459

344.2

ll

I

-'

.023 _______ 229.5 -

=

.oiiI 11ft 114.7 Miu11111

Mean =

.000 r ___

ttlUflIU.IIEJJJJIIJJJ,I

__

0

0.0 6.3 12.5 18.8 25.0

Figure R.2 Distribution of Payback Periods for a MEF of 1.26

Table R.2 Summary of Pavback Period Results

Trial Payback Period in Years

Standard MEF Shown by Percentiles of the Distribution of Results

Level 0% 10% 25% 50% 75% 90% 100% Mean

1.O4MEF 0.0 0.9 1.9 3.5 5.8 9.2 182.7 4.6

3 in 2004

1.26 MEF 0.8 2.3 3.2 4.9 7.9 12.9 194.2 6.6

in 2007

See Table 7.9 for RECS 93 I AEO 99 version

R.2.3 Rebuttable Payback Period Results

'table R.3 Rebuttable 1"resumDtion 1-'avback in Years

Market Share 91% 9%

Standard Level 0% (MEF=O.860) 35% (MEF= 1.257) Weighted Payback

to new Standard Level to New Standard Level

MEF 1.04 (in 2004) 2.7 NA 2.7

MEF = 1.26 (in 2007) 4.3 20.4 5.7

Note: NA = not applicable

See Table 7.12 for RECS 93 I AEO 99 version

R-4

EE-RM-PET-100 COMMENT 88
R.2.4 Comparison of LCC & Payback Period Results

Table R.4 below shows that there are no significant differences between the

RECS93/AE099 and RECS97/AEO2000 values. The difference is within the variation in results

from successive Monte Carlo simulations. Distribution payback period results, have a maximum

difference in the mean payback period of 3%

Table R.4 LCC for Trial Standard Level 3

Level RECS93/AE099 RECS97/AEO2000

Mean Percent with

LCC Less

than Baseline

Mean Percent with

LCC Less

than Baseline

1.04 MEF in 2004 $ (103) 90 $ (105) 90

1.26 MEF in 2007 $ (260) 81 $ (269) 82

Table R.5 Distribution Payback Periods for Trial Standard Level 3

Level RECS93/AE099 RECS97/AEO2000

Median Mean Median Mean

1.04 MEF in 2004 3.5 4.6 3.5 4.6

1.26 MEF in 2007 5.0 6.8 4.9 6.6

Table R.6 Rebuttable Presumption Payback Periods for Trial Standard Level 3

Level Weighted Payback

RECS93/AE099 RECS97/AEO2000

1.04 MEF in 2004 2.5 2.7

1.26 MEF in 2007 5.5 5.7

R-5

EE-RM-PET-100 COMMENT 88
R.3 NATIONAL ENERGY SAVINGS (NES)

R.3.1 National Energy and Water Savings Results

Shown below are tables that reproduce the results in Chapter 10 of the TSD, except that

they use RECS97 and AEO2000 as inputs to the NES/Shipment spreadsheet. Each table is

referenced to its equivalent in Chapter 10. Results are provided for each of the six trial standard

levels considered. All results in the tables below are for the AEO reference case economic

growth assumptions. All other parameters are set to medium or average. In other words, the

main scenario is shown, not the sensitivity cases.

Table R.7 Reference Case - All Parameters Set to Medium or Average

Trial

Standard

Level

MEF Efficiency

Improvement over

the Base Case

Energy Savings

Quads

Water Savings

trillion gallons

Net Present Value

(NPV)

(billion 1997$)

1.021 20% 2.09 0.52 3.76

2 1.089 25% 3.98 8.93 14.30

4 1.257 35% 5.92 12.71 16.89

5 1.362 40% 5.95 12.71 16.75

6 1.634 50% 7.44 10.66 10.94

3 1.04 in2004

1.26 in2007

22%

35%

5.42 11.36 15.33

See Table 10.7 for RECS 93 / AEO 99 version

Table R.8 NES Results: Proposed rule (MIEF = 1.04 in 2004 & MFF=1.26 in 2007)

Cost and Net Present Values

Discounted from 2004 at 7% real to 1997 (in billion 1997$)

Total Energy & Water Savings 27.09

Net equipment Cost 11.77

Net Present Benefit 15.33

Benefit/Cost Ratio 2.3

See Table 10.8 for RECS 93 / AEO 99 version

R-6

EE-RM-PET-100 COMMENT 88
Table R.9 Efficiency Level: Energy and Water Savings (proposed rule, TSL 3)

Energy Saving in Quads Water Saving

Total Elec Gas Oil LPG (Trillion gals)

From 2004 to 2010 0.41 0.26 0.14 0.01 0.01 0.60

to 2020 2.52 1.51 0.90 0.06 0.04 4.91

to 2030 5.42 3.21 1.98 0.13 0.10 11.36

See Table 10.9 for RECS 93 / AEO 99 version

2000 2005 2010 2015 2020 2025 2030

8.00 I IPrice Change

Energy & Water Saving

6.00 NetSaving

H Ii II I III ill Ii Iii ;;4jI ri iii ji j'i UI II III III IIL_Il-ITTI

4.00 ! 1i - I

2.00 M flhJJ]1111flh1R 0.00 j fflj fl t fflfrThi

-2.00

-4.00

Figure R.3 Annual Cost and Savings for the Proposed Clothes Washer Rule (TSL 3)

R-7

EE-RM-PET-100 COMMENT 88
R.3.2 Comparison of NES Results for AE099 and AEO2000 Input Data

Table R.10 NES Results: Proposed rule (MEF = 1.04 in 2004 & MEF=1.26 in 2007)

Cost and Net Present Values

Discounted from 2004 at 7% real to 1997 (in billion 1997$)

_______________________

AE099, RECS93 AEO2000, RECS97

___________

% change

Total Energy & Water

Savings

27.16

________________

27.09 -0.26%

Net equipment Cost 11.86 11.77 -0.76%

Net Present Benefit 15.30 15.33 0.20%

Benefit/Cost Ratio 2.3 2.3 0.0%

As shown in Table R. 10 above for the proposed trial standard (TSL 3), differences in the

results are less than 1%, and therefore, not significant.

R-8

EE-RM-PET-100 COMMENT 88
DOEIEA-1344

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARDS FOR RESIDENTIAL

CLOTHES WASHERS

December 2000

T lp

U.S. Department of Energy

Assistant Secretary,

Energy Efficiency & Renewable Energy

Office of Building Research and Standards

Washington, DC 20585

EE-RM-PET-100 COMMENT 88
ENVIRONMENTAL ASSESSMENT FOR RESIDENTIAL CLOTHES WASHERS

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TABLE OF CONTENTS

1. INTRODUCTION EA-1

2. PURPOSE AND NEED EA-l

3. ALTERNATIVES INCLUDING THE PROPOSED ACTION EA-2

3.1 No Action Alternative EA-2

3.2 Proposed Standard EA-2

3.3 Alternative Standards EA-3

3.4 Impacts of Proposed and Alternative Standards EA-3

4. DESCRIPTION OF THE AFFECTED ENVIRONMENT EA-4

4.1 Geography EA-4

4.2 Air Resources EA-4

4.2.1 Assumptions EA-5

4.2.2 Methods EA-5

4.2.2.1 Carbon EA-5

4.2.2.2 Power Sector NO EA-6

4.2.2.3 Power Sector SO2 EA-6

4.2.2.4 Household NO and SO2 EA-6

4.2.2.5 Fuel-Cycle Emissions EA-6

4.2.2.6 Interpolation EA-7

4.2.2.7 Extrapolation EA-7

4.3 Water Resources EA-7

4.4 Socioeconomics EA-7

4.5 Environmental Justice EA-8

4.6 Energy Consumption EA-8

5. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION EA-8

5.1 Air Quality / Emissions Impacts EA-8

5.1.1 Power Sector Emissions EA-8

5.1.2 Residential Sector Emissions EA-1 1

5.1.3 Power and Residential Sector Emissions EA-14

5.1.4 Fuel-Cycle Emissions EA-15

5.1.5 High and Low Sensitivity Analysis for Air Emissions EA-15

5.2 Water Resources EA-19

5.3 Wetlands / Endangered and Threatened Species / Cultural Resources EA-21

5.4 Socioeconomic Impacts EA-21

5.5 Environmental Justice Impacts EA-21

5.6 Energy Consumption Impacts EA-21

5.7 Summary of Environmental Impacts EA-22

EE-RM-PET-100 COMMENT 88
APPENDIX EA- 1 Emission Factors for Combustion from Natural Gas, LPG, and Oil

Fired Residential Water Heaters and Clothes Dryers ........... EA. 1-i

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APPENDIX EA-2 Upstream Emission Factors from Coal and Natural Gas

Production EA.2-i

APPENDIX EA-3 Interpolation of Utility and Environmental Results from NEMS-BRS

Output EA.3-i

TABLES

Table 1 Summary of the Analysis Results EA-4

Table 2 Power Sector Emissions for all Standards EA-9

Table 3 Cumulative Emissions Reductions through 2020: Power Sector EA-11

Table 4 Change in Annual Household Emissions for MEF Standards EA-12

Table 5 Cumulative Emissions Reductions through 2020: Households EA-13

Table 6 Cumulative Emissions Reductions through 2020: Household and Power

Sectors EA-14

Table 7 Cumulative Emissions Reductions through 2030: Household and Power

Sectors EA-14

Table 8 High and Low Economic Growth: Annual Power Sector Emissions for Proposed

Standard (Trial Standard Level 3) EA- 16

Table 9 High and Low Price Elasticity Scenarios: Annual Power Sector Emissions for

Proposed Standard (Trial Standard Level 3) EA- 17

Table 10 High and Low Economic Growth Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3) EA-18

Table 11 High and Low Price Elasticity: Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3) EA-18

Table 12 Cumulative Power Sector and Household Emission Reductions for High & Low

Economic Growth Sensitivities to 2030 EA-19

Table 13 Cumulative Power Sector and Household Emission Reductions with Elasticity

Sensitivities to 2030 EA-19

Table 14 Cumulative Reduction in Water Use to 2030 EA-20

Table 15 Cumulative Water Reduction for High & Low Economic Growth Sensitivities to

2030 EA-20

Table 16 Cumulative Water Reduction with Elasticity Sensitivities to 2030 EA-20

Table 17 Cumulative Energy Savings for Proposed Standard (Trial Standard Level 3)EA-22

EE-RM-PET-100 COMMENT 88
APPENDIX TABLES

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Table EA- 1.1 Estimated National Average Emission Factors for Household Fuel Combustion of

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

Table EA-2. 1 Estimated Upstream Emission Factors and Relative Percentages to Direct Power

Plant Combustion Emissions EA.2-2

APPENDIX FIGURES

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

EE-RM-PET-100 COMMENT 88
ABBREVIATIONS AND ACRONYMS

Act or EPCA: Part B of Title ifi of the Energy Policy and Conservation Act, Public Law 94-163,

as amended by the National Energy Conservation Policy Act, Public Law 95-6 19, the National

Appliance Energy Conservation Act, Public Law 100-12, the National Appliance Energy

ConservationAmendments of 1988, PublicLaw 100-357, andtheEnergyPolicyActof 1992, Public

Law 102-486

AEO: Annual Energy Outlook, DOE/EIA publication

BRS: DOE's Building Research and Standards office

BTU: British Thermal Unit

C: carbon

DOE: Department of Energy

EA: Environmental Assessment

EF: Energy Factor

EIA: Energy Information Administration

EJ: exajoule (1018 joules)

EPCA: Energy Policy and Conservation Act

GJ: gigajoule (l0 joules)

kt/a: thousand metric tons per year

kWh: kilowatt-hour

LCC: Life-Cycle Cost

LPG: liquified petroleum gas

MEF: Modified Energy Factor (cu. ft. / kWh per cycle)

Mt/a: millions of metric tons per year

NAECA: National Appliance Energy Conservation Act

NEMS: National Energy Modeling System

EE-RM-PET-100 COMMENT 88
NEPA: National Environmental Policy Act of 1969

NES: National Energy Savings

NOPR: Notice of Proposed Rulemaking

NON: nitrogen oxides

PBP: Payback period

Quad: quadrillion Btu

RIA: Regulatory Impact Analysis

SO2: sulfur dioxide

t: metric ton

TSL: Trial Standard Level

TSD: Technical Support Document

TWh: terawatt-hour

U.S.C.: United States Code

EE-RM-PET-100 COMMENT 88
1.0 INTRODUCTION

The U.S. Department of Energy (DOE) prepared this clothes washer environmental

assessment (EA) pursuant to the National Environmental Policy Act of 1969 (NEPA)(42 U.S.C.

4321 et seq.), the regulations of the Council on Environmental Quality (40 CFR Parts 1500-1508),

and the Department of Energy's regulations for compliance with NEPA (10 CFR Part 1021).

On November 14, 1994, DOE published an Advance Notice of Proposed Rulemaking

(ANOPR). 59 FR 56423. On November 19, 1998, DOE published a Supplemental ANOPR

(Hereafter referred to as the 1998 Supplemental ANOPR.). 63 FR 64344. On October 5, 2000, DOE

published a Notice of Proposed Rulemaking (NOPR or proposed rule) for energy efficiency

standards. 65 FR 59550. For the NOPR, we analyzed the energy savings, benefits and burdens of

amended energy conservation standards for clothes washers and shared the results of these analyses

with all stakeholders. Based on these analyses, several of the major stakeholders, including clothes

washer manufacturers and energy efficiency advocates, submitted to the Department ajoint proposal

for the highest standard level which they believed to be technically feasible and economically

justified. (Hereafter referred as the Joint Comment). Based on our review of the Joint Comment,

we found the proposed standards technically feasible and economically justified. Therefore, the

Department is adopting the energy conservation standards for clothes washers at Trial Standard

Level (TSL) 3 (The clothes washer energy standards for Top Loading, Standard (1.6 ft.3 or greater

capacity) and Front Loading class clothes washers shall be 1.04 modified energy factor (MEF) in

1/1/2004 and 1.26 MEF in 1/1/2007.).

DOE proposed the clothes washer efficiency standards pursuant to Part B of Title ifi of the

Energy Policy and Conservation Act, Public Law (P.L.) 94-163, as amended by the National Energy

Conservation Policy Act, P.L. 95-619, by the National Appliance Energy Conservation Act, P.L.

100-12, by the National Appliance Energy Conservation Amendments of 1988, P.L. 100-357, and

the Energy Policy Act of 1992, P.L. 102486a (the Act or EPCA), which created the Energy

Conservation Program for Consumer Products other than Automobiles.

The proposed clothes washer efficiency standard affects consumers and manufacturers of

residential clothes washers.

2.0 PURPOSE ANI NEED

The Energy Policy and Conservation Act, as amended, specifies that the Department must

consider, for new or amended conservation standards, those standards that "achieve the maximum

aPt B of Title III of the Energy Policy and Conservation Act, as amended by the National Energy Conservation Policy Act,

the National Appliance Energy Conservation Act, the National Appliance Energy Conservation Amendments of 1988, and the

Energy Policy Act of 1992, is referred to in this notice as the Act." Part B of Title III is codified at 42 U.S.C. 6291 et seq. Part

B of Title III of the Energy Policy and Conservation Act, as amended by the National Energy Conservation Policy Act only, is

referred to in this notice as the National Energy Conservation Policy Act.

EA- 1

EE-RM-PET-100 COMMENT 88
improvement in energy efficiency which the Secretary determines is technologically feasible and

economically justified" and which will "result in significant conservation of energy." Accordingly,

DOE' s proposed rule would be amending the energy conservation standard for residential clothes

washers.

Consistent with this requirement, DOE's purpose in the proposed action is to reduce the

consumption of energy used by clothes washers in the United States (U.S.). DOE's discretion is in

deciding the level for a minimum efficiency standard, not if there should be one.

3.0 ALTERNATIVES INCLUDING THE PROPOSED ACTION

A DOE clothes washer standard analysis includes the energy saved by the clothes washer

itself (always electrical), the energy used in an electric, gas, LPG or oil-fired water heater to heat

water for the clothes washer, and the energy required by a clothes dryer (electric, gas or LPG) to

remove the water remaining in laundry after a completed wash cycle. The metric used to measure

the efficiency is called the Modified Efficiency Factor (MEF). Details are provided in the Clothes

Washer Technical Support Document (TSD).1

After an initial analysis of ten different efficiency levels, the analysis was reduced to six

possible TSLs. Of these, DOE proposes to set a clothes washer standard at TSL 3.

3.1 No Action Alternative

Under this alternative DOE would not publish a new minimum energy efficiency standard

for clothes washers. By taking no action, DOE would be in violation of EPCA, which requires (1)

DOE to determine whether to amend the statutory standard, and (2) that a minimum standard be set

at a level that 'shall be designed to achieve the maximum improvement in energy efficiency that the

Secretary determines is technologically feasible and economically justified." EPCA, §325(l)(2)(A),

42 U.S.C. §6295(l)(2)(A). In addition to analyzing a baseline case in the TSD, a Draft Clothes

Washer Regulatory Impact Analysis (RIA) was published that examines the no action alternative as

well as other non-mandatory efficiency standards or voluntary incentive programs. It was

determined in this report that the "no action" alternative would result in less energy reductions than

the proposed standard. If"no action" were taken, the minimum efficiency requirement would remain

at its current level, an Energy Factor (EF) of 1.18. Unlike the proposed MEF, the EF does not

account for energy use in the clothes dryer. The current baseline value for EF corresponds to an

MEF of 0.817 kWhlcycle, a lower minimum efficiency level than any other level being considered.

3.2 Proposed Standard

The major stakeholders, including manufacturers and energy efficiency advocates, have

jointly submitted a proposed clothes washer efficiency standard to DOE that they feel is technically

feasible and economically justified. This proposed clothes washer efficiency standard will provide

significant energy savings and water savings to the nation. The proposed standard (TSL 3) would

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EE-RM-PET-100 COMMENT 88
go into effect in two stages, with a lower required improved efficiency (MEF of 1.04) by the year

2004 and a higher efficiency level (MEF of 1.26) by the year 2007. Additional details of the

proposed TSL 3 and other TSL's are provided in the Clothes Washer TSD1. The TSD is available

on a DOE internet site at http:llwww.eren.doe.gov/buildings/codes_standards/applbrf/clwasher.html.

The justification for selecting the proposed standard, TSL 3, over the other trial standard

levels considered is explained in Section V.F, conclusions of the October 5, 2000 Federal Register

Notice, page 59580. This Federal Register notice is also available on a DOE internet site at

http://www.eren.doe.gov/buildings/codes_standards/applbrf/clwasher.html under "Notice of

Proposed Rulemaking."

3.3 Alternative Standards

This EA presents the results of the environmental impacts from six clotheswasher efficiency

trial standards. Each standard is an alternative action, and is compared against the no-action

alternative. In the course of a typical appliance rulemaking, all alternatives are initially considered.

To simplify the analysis for the final detailed selection process, some alternatives are eliminated

from further analysis. Of the ten beginning standard levels, six have been analyzed in detail in this

EA and four were eliminated from further analysis. Of the four eliminated, three trial standard levels

with MEF's of 0.86 (5% energy reduction), 0.908 (10% energy reduction) and 0.961 (15% energy

were eliminated from further consideration because it was determined that an MEF of 1.021(20%

energy reduction) was technically feasible and economically justified, making further consideration

of the less efficient trial levels unnecessary. The fourth trial standard with a MEF of 1.485 (energy

reduction of 45%) was eliminated due to its significantly higher increase in clothes washer retail

price, life-cycle-cost and payback period. It is required that the maximum technically achievable

level, in this case MEF of 1.634 (representing reduced energy use of 50%), be retained as part of the

analysis.

3.4 Impacts of Proposed and Alternative Standards

The NOPR established that DOE determined that significant energy savings could be

achieved through the adoption of an amended conservation standard for clothes washers. DOE

considers the impacts of standards beginning with the most efficient level. Table 1 includes a

summary of the analysis results to aid the reader in the discussion of the benefits and burdens for the

different trial standard levels. DOE proposes to set a clothes washer standard at TSL 3 which is felt

to be technically feasible and economically justified. Additional information on the six trial standard

levels is provided in Section 5 of this EA, Environmental Impacts of the Proposed Action.

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EE-RM-PET-100 COMMENT 88
Table 1.--Summary of the Analysis Results*

Tra1 Sltndard LevI 6 5 4 3 2 1

1EF

_____________________________________

1.63

_________________

1.26

________________

1 26 I 08 in 2004.

I 26 LII 2007

.09 102

Percejit Rediction in Eiterv

Use

51)

______________

4(1 35 22 in 2(104

in 2007

25 211

'Jotal Energy Saved Oiirids) 7.52

______________

093

______________

5.99 52

______________

4.04

____________

2.12

Witer Savings lirihion aUons1 ItI.85 204 12.94 11.59 9.09 (t53

Em ions

Carbon Equivalent (MI) 134.o 1(173 1116.2 95.1 70.9 us. I

1th(kcl .164 283.1 28{16 253.5 1939 I15

SO.,ktl 11.41 20.31 2031 28.11 20.(I •i1i

* Values are all cummulative to 2030.

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT

4.1 Geography

The clothes washer standard that DOE is proposing would apply to all 50 states and U.S.

territories.

4.2 Air Resources

The primary focus of the EA is the effect of proposed efficiency standards on air resources.

For this analysis, the EA uses a variant of DOE, Energy Information Administration's (DOEIEIA)

National Energy Modeling System (NEMS), called NEMS-BRS (BRS is DOE' s Building Research

and Standards office), plus some additional analysis not using NEMS-BRS to determine the nonpower sector air emissions)' The environmental analysis is similar to the utility sector analysis

described in Chapter 12 of the Clothes Washer TSD.' Outputs of the environmental analysis are in

a format similar to the results of the DOEIEIA's Annual Energy Outlook 1999 (AEO99).3

For each of the standard levels, DOE calculated total power sector emissions based on output

from NEMS-BRS. DOE also conducted some additional analysis to calculate household emissions

which are not covered by NEMS-BRS. The EA considers only two pollutants, nitrogen oxides (NO)

and sulfur dioxide (SO2), and one emission, carbon (C). Because emissions of SO2 from power

plants are capped by clean air legislation, physical emissions of this pollutant from electricity

generation will be only minimally affected by possible clothes washer standards. The maximum SO2

allowed by law will most likely still be produced, but because SO2 emissions are traded, and if SO2

emissions are lowered due to less power generation, then the cost of SO2 emission credits may

decrease slightly. Therefore, the EA does not consider changes in power sector SO2 emissions,

although it does household emissions savings. The only form of carbon tracked by NEMS-BRS is

bFor more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration

documentation. A useful summary is National Energy Modeling System: An Overview 199 DOEIETA-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.

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EE-RM-PET-100 COMMENT 88
carbon dioxide (C02), so the carbon discussed in this analysis is only in the form of C02, but is

reported as mass of elemental carbon, in keeping with standard practice.

4.2.1 Assumptions

The EA uses the same basic assumptions as AE099 and models the changes resulting from

standards as variations from current policy. For example, the emissions characteristics of an

electricity generating plant in the environmental analysis are the same as those used in AE099,

although the fuel mix used for generation and the construction program for new plants may deviate

slightly as a result of reduced generation requirements under the standard, which in turn affects air

emission results. As with the utility impact analysis in Chapter 12 of the TSD', the environmental

emissions effects are assumed to be linear in the range of the standards decrements and results are

extrapolated.

The EA also includes a sensitivity analysis for the proposed standard level, using the High

and Low Economic Growth scenarios of NEMS-BRS. As described in Chapter 12 of the TSD',

these scenarios cover a range of macro-economic growth assumptions. In addition, a separate

sensitivity assuming high and low price elasticities are analyzed. The high and low price sensitivities

have an effect on the magnitude of clothes washer shipments. Both sensitivity analyses are done for

the case of the proposed standard level (TSL 3) only. Sensitivities were not done for all possible

standard levels as they have been eliminated based on the results of the reference scenario.

4.2.2 Methods

4.2.2.1 Carbon

A detailed carbon module tracks carbon emissions in NEMS-BRS. The Carbon Module

provides good results because it covers all sectors of the economy and their interactions. Because

NEMS-BRS tracks carbon emissions based on the total energy consumption and produces

comprehensive estimates of the benefits of proposed standards, actual household emissions are

included and no external analysis is necessary. NEMS-BRS itself does not account for potential

carbon savings that result from upstream processes, as described in the fuel-cycle section below.

Past experience with NEMS-BRS carbon results from power generation suggests that using

marginal emissions estimates are more accurate than emissions based on simple forecast average

factors for analysis of proposed appliance standards. First, the marginal fuel displaced by reduced

generation as a result of proposed standards tends to be natural gas, which releases less carbon

emissions than coal. Second, lowered electricity demand tends to slow down the construction of

power generation capacity, thereby slowing improvement in energy conversion efficiency and

emissions rates that typically result from deployment of newer technology.

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EE-RM-PET-100 COMMENT 88
4.2.2.2 Power Sector NO

NEMS-BRS reports two airborne pollutant emissions, NO and SO2. Power sector NO

results are based on forecasts of compliance with existing legislation at the time AE099 was released

and have proven stable and reasonable.

4.2.2.3 Power Sector SO2

The Clean Air Act Amendments of 1990 set an SO2 emissions cap on all power generation,

but permits flexibility among generators through the use of emissions allowances and tradable

permits. SO2 trading tends to imply that physical emissions effects of a standard will be zero because

emissions will always be at, or near, the ceiling. There is virtually no real possible SO2

environmental benefit from electricity conservation as long as there is enforcement of the emissions

ceiling. A slight economic benefit may result only if coal generation falls and the reduced demand

for SO2 emission allowances lowers the allowance price. Because the effects considered here are

too small to deliver reasonable estimates, the EA does not consider this possibility.

4.2.2.4 Household NO and SO2

While NEMS-BRS has an algorithm for estimating emissions of NO and SO2 from power

generation, it does not estimate household emissions of these pollutants. Because households use

natural gas, fuel oil, and LPG, the residential sector also contributes to NO and SO2 emissions. This

analysis therefore includes separate estimates of the effect of standards on household NO and SO2

emissions, based on simple emissions factors derived from general literature. Although small,

household SO2 emissions savings are reported because the SO2 emissions caps do not apply to the

residential sector. Appendix BA-i provides a detailed description of the methodology for deriving

the emissions factors for residential combustion.

4.2.2.5 Fuel-Cycle Emissions

NEMS-BRS does not account for upstream emissions from energy losses during coal and

natural gas production. The upstream processes include the mining of coal or extraction of natural

gas, physical preparatory and cleaning processes, and transportation to the power plant. Appendix

EA-2 shows upstream emission estimates for carbon, SO2, and NOR, along with the emissions factors

and the relative percentage of upstream emissions to power plant emissions. Appendix EA-2 also

provides a detailed description of the methodology used to derive these estimates. Although DOE

does not report actual estimates of the effects of standards, the material in Appendix EA-2 provides

the reader with a feel for the possible magnitude of upstream effects. According to the study by

M.A. DeLuchi, approximately 8% of total coal fuel cycle carbon, NOR, or SO2 emissions are

attributed to upstream coal production. The equivalent value for gas is 14%.

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EE-RM-PET-100 COMMENT 88
4.2.2.6 Interpolation

Because the size of the energy savings from standards are too small to produce stable power

sector results in NEMS-BRS, it has been necessary to estimate results in the range of the standard

levels' effects using interpolation. Appendix EA-3 describes the interpolation methodology in detail.

A series of cases is executed in which the Residential Demand Module's clothes washer, clothes

dryer and water heater loads are reduced for each of the fuel types (electricity, gas, oil and LPG) at

incrementally higher savings than the standards levels. Actual standard level savings are then

derived from these outputs.

4.2.2.7 Extrapolation

The current time horizon of NEMS-BRS is 2020 (modeling a 1 7-year period, 2004-2020),

yet other parts of the appliance energy efficiency work reach 2030. As described in the utility

analysis in Chapter 12 of the TSD, it is not feasible to extend the forecast period of NEMS-BRS for

the purposes of this analysis, nor does EIA have an approved method for extrapolation of many

outputs beyond 2020; therefore, to ensure consistency all extrapolations beyond 2020 presented here

are simple replications of year 2020 results. As with the AE099 Reference Case in general, the

implicit assumption is that the regulatory environment does not deviate from the current known

situation during the extrapolation period. Only changes that have been announced with date-certain

introduction are included in NEMS-BRS. Consistent with this assumption, the household emissions

factors used do not change in either the forecast or the extrapolation periods because little

compelling evidence of tightening emissions standards for household appliances was forthcoming

in the research described in Appendix EA- 1. To emphasize the extrapolated results wherever they

appear, they are shaded in grey to distinguish them from actual NEMS-BRS output.

4.3 Water Resources

The efficiency level and effective dates of the proposed rulemaking (TSL 3) are analyzed as

well as the nine originally considered MEF standard levels. The original nine MEF values

considered are: 0.860, 0.908, 0.961, 1.021, 1.089, 1.257, 1.362, 1.485, and 1.634. Water usage

reduction per washer was obtained from the Association of Home Appliance Manufacturers

(AHAM) data showing the amount of water use at each clothes washer efficiency level. The amount

of national water usage reduction is determined by using a spreadsheet model that forecasts

shipments and national energy savings (NES). The NES/Shipments model is described in detail in

Chapters 9 and 10 of the Clothes Washer TSD accompanying the NOPR.

4.4 Socioeconomics

As part of the rulemaking process, the socioeconomic effect on consumers was analyzed.

Analysis included determining the differences in life-cycle cost for the standard levels analyzed. See

Chapter 7 and Appendix G of the TSD. In addition, a conjoint analysis and focus groups provided

information on consumer preferences relating to clothes washers. See Chapter 8 and Appendix J of

the TSD.

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EE-RM-PET-100 COMMENT 88
4.5 Environmental Justice

A consideration of Environmental Justice is made pursuant to Executive Order 12898,

Federal Actions to Address Environmental Justice in Minority Populations and Low-Income

Populations. The Executive Order requires federal agencies to assess whether a proposed federal

action causes any disproportionately high and adverse human health or environmental effects on lowincome or minority populations. The proposed action causes no such adverse impacts.

4.6 Energy Consumption

Data from manufacturer questionnaires were used as input to a NES/Shipment spreadsheet

model that forecasted shipment of clothes washers to the year 2030 and determined the savings of

energy consumption to the nation both annually and cumulatively. Detail is provided in Chapters

4, 9 and 10 of the Clothes Washer TSD, published together with the NOPR. A sophisticated

NES/Shipments spreadsheet model is described in the Clothes Washer TSD. This spreadsheet model

forecasts the national shipments and energy use of clothes washers with and without standards.

5.0 ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

5.1 Air Quality/Emissions Impacts

5.1.1 Power Sector Emissions

Table 2 shows the annual power sector carbon and NO emissions for the proposed and

alternative standard levels. The total carbon emission reductions range up to 5.2 MtJa in 2020. NO

emissions reductions reach up to 9.8 kt/a in 2020. Cumulative emissions savings for the power

sector over the 17-year period modeled are listed in Table 3. All of the nine originally considered

MEFs are shown, as well as the proposed two stage standard level and the reference case. The six

TSL's selected for closer analysis are labeled as TSL 1 through 6. Of these, TSL 3 is being

proposed. See details on the selection process in the Clothes Washer TSD. In Table 3 the lowest

MEF of 0.860 represents a 5% reduction in energy use, whereas the largest MEF, 1.634, represents

a 50% reduction in energy use over a baseline energy use level of 0.817, assumed to be equivalent

to the current minimum clothes washer efficiency requirement. In this analysis, the reference case

refers to cases with respect to the AE099 Reference Case. All trial standard levels are compared to

the reference case, which represents the no action alternative. This is also referred to as the baseline

case, EF level of 1.18 and MEF level of 0.817.

EA-8

EE-RM-PET-100 COMMENT 88
Table 2. Power Sector Emissions for all Standards

NEMS-ERS Results AE099 Ref. Case - Proposed Standards

Absolute Values of Emissions Emission Reductions as Compared to

the No Action Alternative

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

AE099 Reference Case (No Action Alternative, MEF = 0.817) Exirapolation

Carbon (Mt/a)1 '3 588.9 612.9 653.2 704.6 744.6 0 0 0 0 0 0 0

NO(kt/a)2'3 4191.2 3547.1 3665 3819.2 3882.8 0 0 0 0 0 0 0

Proposed Standard Levels

MEF = 0.860

Carbon (Mt/a) 588.9 612.9 653.1 704.5 744.4 Carbon (Mt/a) 0 0 -0.1 -0.1 -0.2 -0.2 -0.2

NO (ktla) 4191.2 3546.9 3664.8 3818.8 3882.4 NO (ktla) 0 -0.2 -0.3 -0.5 -0.4 -0.4 -0.4

MEF = 0.908

Carbon (Mt/a) 588.9 612.8 653 704.2 744 Carbon (Mt/a) 0 -0.1 -0.2 -0.4 -0.6

NO(ktJa) 4191.2 3546.5 3664.2 3817.7 3881.6 NO(kt/a) 0 -0.6 -0.8 -1.5 -1.2 -1.2 -L2

MEF = 0.961

Carbon (Mt/a) 588.9 612.7 652.8 703.8 743.5 Carbon (Mt/a) 0 -0.2 -0.4 -0.8 -1.1 -1.1 -1.1

NO (kt/a) 4191.2 3546 3663.6 3816.6 3880.7 NO (ktla) 0 -1.1 -1.5 -2.6 -2.1 2.1 -2.1

MEF = 1.021 Trial Standard Level 1

Carbon (Mt/a) 588.9 612.7 652.7 703.7 743.3 Carbon(Mt/a) 0 -0.2 -0.5 -0.9 -1.3 j

NO(ktJa) 4191.2 3545.8 3663.3 3816.1 3880.3 NO(ktJa) 0 -1.3 -1.8 -3.1 -2.4 -2.4 -2.4

MEF = 1.089 Trial Standard Level 2

Carbon (Mt/a) 588.9 612.5 652.3 702.9 742.3 Carbon(MtJa) 0 -0.4 -0.9 -1.7 -2.3 23 -2.3

NO(kt/a) 4191.2 3544.3 3662.1 3813.4 3879 NO(kt/a) 0 -2.8 -2.9 -5.8 -3.8 ,38

EA-9

EE-RM-PET-100 COMMENT 88
lame . rower Sector missions for all Standards continued)

NEMS-BRS Results

Absolute Values of Emissions

AE099 Ref. Case - Proposed Standards

Emission Reductions as Compared to

the No Action Alternative

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

MEF = 1.257 Trial Standard Level 4 Extrapolation

Carbon(MtJa) 588.9 612.3 651.7 701.8 740.8 Carbon(Mt/a) 0 -0.6 -1.5 -2.8 -3.8 -3,8 -3.8

NO (kt/a) 4191.2 3544 3660 3810.2 3876.2 NO (ktla) 0 -3.1 -5 -9.1 -6.5 - -5,5

MEF = 1.362 Trial Standard Level 5

Carbon (MtJa) 588.9 612.2 651.7 701.8 740.8 Carbon (Mt/a) 0 -0.7 -1.5 -2.8 -3.8 -3, -3,8

NO(ktJa) 4191.2 3542.8 3660.1 3809.8 3876.2 NO (ktla) 0 -4.2 -5 -9.4 -6.5 -6. -6.5

MEF = 1.485

Carbon (Mt/a) 588.9 612 651.5 701.2 739.7 Carbon (Mt/a) 0 -0.9 -1.7 -3.4 -4.9 4,9 .49

NO(kt/a) 4191.2 3541.3 3659.9 3807.6 3873.6 NO(ktJa) 0 -5.8 -5J -11.6 -9.1 -9J -9.1

MEF = 1.634 Trial Standard Level 6

Carbon (Mt/a) 5889 611.9 65L4 700.9 739.4 Carbon (Mt/a) 0 -1 -1.8 -3.7 -5.2 '7 -5.2

NO (kti'a) 4191.2 35408 3659.5 3806.8 3872.9 NO (kt/a) 0 -6.3 -5.5 -12.5 -9.8 ,g 9

PROPOSED LEVEL: MEF = 1.04 in 2004 & 1.26 in 2007 (TSL 3)

Carbon(Mt/a) 588.9 612.7 652.1 702.2 741 Carbon(MtJa) 0 -0.2 -1.1 -2.4 -3.6 36 -3.6

NO, (kt/a) 4191.2 3545.5 3661.2 3811.4 3876.1 NO, ktJa 0 -1.3 -3.9 -7.8 -6.6 -66 -6fuomparaie to i aoie A1? 01 AiU t.iectnc enerators

2 Comparable to Table A8 of AE099: Emissions

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

EA- 10

EE-RM-PET-100 COMMENT 88
Table 3. Cumulative Emissions Reductions through 2020: Power Sector

MEF (cu. ft. / kWh per cycle)

Emission

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

TSL1 TSL2 TSL4 TSL5 TSL6 TSL3

(PROPOSED

_____________ ______ ______ ______ _______

MEF)

Carbon (Mt) 1.9 5.8 10.1 12

______

22.2

_______

36.3

______

36.9

______

44.8 48.1 29.8

NO (kt) 6.2 19.1 33.3 39.6 72.2 114 116.3 144.8 155.5 93.5

5.1.2 Residential Sector (Household) Emissions

In the emissions reductions analysis, reductions in emissions resulting from a clothes washer

standard, are separated into two parts: power sector and residential. The power sector consists of

emissions emitted outside of the household and include primarily emissions generated at power

plants used to generate electricity. Residential sector emissions (also referred to as household

emissions) are those emitted physically at the residence. All emissions due to the generation of

electricity are considered power sector. All emissions due to combustion at the physical location of

the residence are considered residential sector emissions.

Included as part of the clothes washer measure of energy use, is the energy needed to heat

the water that is used by the clothes washer and the energy used to dry the clothes in the clothes

dryer. This is in addition to the electrical energy used to run the washer and dryer electric motors.

Where a natural gas, oil or LPG fuel is used by the water heater, combustion emissions are emitted

at the residence or household. Similarly, for those households having a gas-fired clothes dryer,

emissions from the dryer's gas burner are also located at the residence. Emissions at the location of

the residence are referred to as residential sector emissions. Details on the emission factors for

combustion from natural gas, LPG, and oil-fired residential water heaters and clothes dryers are

provided in Appendix EA- 1.

Total household carbon, NO and SO2 emissions savings are presented in Table 4 for all MEF

standard levels. These figures represent the sum of emissions reductions that result from reduced

combustion of natural gas, fuel oil and LPG at residences due to the different trial standard levels.

The annual emissions savings in 2020 range from 0.06 to 1.73 MtJa for carbon, 0.21 to 5.59 ktla for

NO and 0.06 to 1.59 ktla for SO2. These savings are in addition to the power sector savings reported

above. Table 5 shows cumulative emissions savings for households over the 17-year period (2004-

2020) modeled in NEMS-BRS.

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EE-RM-PET-100 COMMENT 88
Table 4. Change in Annual Household Emissions for MEF Standards

Year 2000 2005 2010 2015 2020 2025 2030

MEF = 0.860 Extrapolation

Carbon (Mt/a) 0 0 -0.03 -0.05 -0.06 41.06 1.06

NO(kt/a 0 0 -0.1 -0.18 -0.21 -0,21 -0.21

SO2 (ktia) 0 0 -0.03 -0.05 -0.06 1 -0.{)6 -006

MEF = 0.908

Carbon (MtJa) 0 0 -0.11 -0.19 -0.23 i -0.23 -023

NO (ktla) 0 -0.11 -0.4 -0.69 -0.82 -0.82 -0.82

SO2 (kt/a) 0 0 -0.12 -0.2 -0.24 -0.24 -0.24

MEF = 0.961

Carbon (Mt/a) 0 -0.1 -0.23 -0.38 -0.46 -046 -0.46

NO(kt/a) 0 -0.23 -0.8 -1.39 -1.66 -1.66 -161)

SO2 (kt/a) 0 -0.1 -0.25 -0.42 -0.51 :! -0,51 -0.51

MEF = 1.021 Trial Standard Level 1

Carbon (Mt/a) 0 -0.1 -0.33 -0.56 -0.67 I -0,67 -0.67

NO(kt/a) 0 -0.35 -1.21 -2.12 -2.57 -2.57 -2.57

S02(ktla) 0 -0.2 -0.7 -1.27 -1.59 -1.59 -1.59

MEF = 1.089 Trial Standard Level 2

Carbon (Mt/a) 0 -0.18 -0.61 -1.05 -1.28 -1.28 -I.2

NO(kt/a) 0 -0.56 -1.97 -3.44 -4.17 -4.17 -4.17

502 (kt/a) 0 -0.2 -0.69 -1.24 -1.52 , -1.52 -1.52

MEF = 1.257 Trial Standard Level 4

Carbon (Mt/a) 0 -0.22 -0.74 -1.3 -1.6 -1,6 -1,6

NO (kt/a) 0 -0.67 -2.31 -4.13 -5.08 -5.08 -5.08

SO,(kt/a) 0 -0.2 -0.69 -1.24 -1.52 -1.52 -l.52

MEF = 1.326 Trial Standard Level 5

Carbon (Mt/a) 0 -0.22 -0.74 -1.29 -1.6 .1 -1.6 -1.6

NO (kt/a) 0 -0.67 -2.31 -4.14 -5.09 -5.09 -5.09

SO1 (ktla) 0 -0.2 -0.69 -1.24 -1.52 I -1.52 -1.52

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EE-RM-PET-100 COMMENT 88
Table 4. Change in Annual Household Emissions for MEF Standards (Continued)

Year 2000 2005 2010 2015 2020 2025 2030

MEF = 1.485 Extrapolal ion

Carbon (MtJa) 0 -0.23 -0.75 -1.34 -1.68 -1.68 -L68

NO (ktla) 0 -0.69 -2.39 -4.34 -5.43 -5.43 -5.43

SO2 (kt/a) 0 -0.2 -0.69 -1.25 -1.56 -1.56 - .56

MEF = 1.634 Trial Standard Level 6

Carbon (MtJa) 0 -0.24 -0.77 -1.38 -1.73 - I .73 - I .73

NO (ktla) 0 -0.71 -2.45 -4.46 -5.59 -5,59 -5.59

SO2 (kt/a) 0 -0.2 -0.7 -1.27 -1.59 -1.5.9 -1.59

PROPOSED MEF = 1.04 in 2004 & 1.26 in 2007 Trial Standard Level 3

Carbon (Mt/a) 0 -0.12 -0.6 -1.15 -1.58 ;

- .58 -1.58

NO(kt/a) 0 -0.35 -1.87 -3.66 -4.97 -4.97 -4.97

SO, (ktia) 0 -0.11 -0.56 -1.1 -1.49 -r,49 -1.49

Table 5. Cumulative Emissions Reductions through 2020: Households

MEF

Emission 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

TSL1 TSL2 TSL4 TSL5 TSL6 TSL3

(PROPOSED

MEF)

Carbon (Mt) 0.6 2.3 4.7 6.8 12.9 15.9 15.9 16.5 16.9 13.9

NO (kt) 2.2 8.4 16.9 25.8 42 50.4 50.5 53 54.4 43.9

SO2 (kt) 0.6 2.5 5.2 15.5 15.1 15.1 15.1 15.3 15.5 13.2

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5.1.3 Power and Residential Sector Emissions

Cumulative emissions reduction for the power sector and households (excluding upstream

emissions) over the 17-year period modeled are presented in Table 6 below.

Table 6. Cumulative Emissions Reductions through 2020: Household and Power Sectors

MIEF

Emission 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

TSL1 TSL2 TSL4 TSL5 TSL6 TSL3

(PROPOSED

MEF)

Carbon (Mt) 2.5 8.1 14.8 18.9 35.2 52.3 52.8 61.3 65 43.7

NO (kt) 8.4 27.5 50.3 65.4 114.2 164.4 166.7 197.8 209.9 137.4

SO2 (kt) 0.6* 2.5* 5.2* 15.5* 15.1* 15.1* 15.1* 15.3* 15.5* 13.2*

*Results include only household emissions reductions because the power sector emissions cap implies that savings from

electricity generation will be negligible.

Cumulative emissions reductions for the power sector and households (excluding upstream

emissions) with the forecast extended through 2030 are in Table 7.

Table 7. Cumulative Emissions Reductions through 2030: Household and Power Sectors

MEF

Emission 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)

Carbon(Mt) 5.1 16.4 30 38.1 70.9 106 107 127 135 95.1

NO(kt) 14.4 47.4 87.4 116 194 281 283 344 364 253.5

SO2 (kt) 1.2* 49* 49* 31.4* 30.3* 303* 30.3* 30.9* 31.4* 28.1*

*Results include only household emissions reductions because the power sector emissions cap implies that savings from

electricity generation will be negligible.

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EE-RM-PET-100 COMMENT 88
5.1.4 Fuel-Cycle Emissions

The effects of standards on upstream emissions are not reported here. Please refer to

Appendix EA-2 for a general description of the possible magnitude of these effects.

5.1.5 High and Low Sensitivity Analysis for Air Emissions

The Annual Energy Outlook (AEO), a document produced yearly by DOE/ETA, forecasts

emission outputs. As part of its analysis, the AEO analyzes sensitivities for assumptions of high and

low economic growth for the nation. These assumptions of economic activity in turn produce

differences in fuel use and fuel prices. The Reference Case, refers to the emissions predicted in

AE099, i.e., without a new clothes washer standard.

In Tables 8 and 10, DOE reports the equivalent results for the High and Low Economic

Growth Cases for the proposed TSL 3. Table 8 shows the annual emissions savings from the power

sector with the corresponding annual change in household emissions shown in Table 10.

In addition to the high and low economic activity AEO scenarios, additional sensitivities

were analyzed based on predictions of how much clothes washer shipments would decrease for an

increase in clothes washer price (i.e., high and low assumptions for price elasticity) that may

accompany an increase in clothes washer efficiency. Detailed analysis is reported in Chapter 9 of

the TSD. DOE reported the equivalent results for assumptions of high and low price elasticity

scenarios for the proposed standard level. Table 9 shows the annual emissions savings from the

power sector with the corresponding annual change in household emissions shown in Table 11.

Shown in Tables 12 and 13 are the low and high sensitivities for the proposed proposed

rulemaking scenario. Table 12 shows results for the low and high economic growth cases.

Generally, the carbon savings for the Low Economic Growth Cases are slightly lower than those

reported for the comparable Reference Case standards scenario while the savings for the High

Economic Growth Cases are slightly higher than those reported for the Reference Case. Table 13

covers high and low price elasticities with MEFs of 1.04 and 1.26 in the years 2004 and 2007,

respectively. The price elasticity sensitivities are chosen to represent a relatively large drop and a

relatively small drop in forecasted shipments when a new minimum efficiency standard takes affect.

See the Shipments and National Energy Savings in Chapters 9 and 10 of the TSD for more detailed

discussion.

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EE-RM-PET-100 COMMENT 88
Table 8. High and Low Economic Growth: Annual Power Sector Emissions for Proposed Standard (Trial Standard Level 3)

NEMS-BRS Results Difference from AE099 Reference

2000 2005 2010 2015 2020 2000 2005 2010 2015 2020 2025 2030

AE099 High Economic Growth Reference Case Difference from AE099 Reference Case Extrapolation

Carbon (MtJa)"3 590.6 628.9 679 741.8 799 4.5 32.6 46.6 71.7 104

NO (ktia)2'3 4200 3628.7 3764.8 3937.2 4000.7 18 163 163 236 263

MEF = 1.04 in 2004 & 1.26 in 2007 High Economic Growth

Carbon (Mt/a) 590.6 628.7 677.8 739.4 795.1 Carbon (Mt/a) 0 -0.2 -1.2 -2.4 -3.9 -3.9 -3.9

NO (ktia) 4200.3 3626.2 3760.3 3929.1 3994.6 NOx (kt/a) 0 -2.5 -4.5 -8.06 -6.1 -6.1 -6.1

AE099 Low Economic Growth Reference Case Difference from AE099 Reference

Carbon (Mt/a)1'3 586.1 596.3 632.4 670.1 694.6 -1.8 -17 -21 -34.5 -50

NO(ktJa)2'3 4182 3465.4 3601.5 3701.3 3737.6 -9 -82 -64 -118 -145

MEF = 1.04 in 2004 & 1.26 in 2007 Low Economic Growth

Carbon(MtJa) 586.1 596.1 631 667.8 691.3 Carbon(Mt/a) 0 -0.2 -1.4 -2.3 -3.3 -3.3 -3.3

NO (kt/a) 4182.1 3464.6 3593.7 3693.3 3728.9 NOx (ktla) 0 -0.8 -7.8 -8 -8.7 -8.7 -8.7

Comparable to Table B19 of AE099: Electric Generators

Comparable to Table B8 of AE099: Emissions

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

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EE-RM-PET-100 COMMENT 88
Table 9. High and Low Price Elasticity Scenarios: Annual Power Sector Emissions for Proposed Standard

(Trial Standard Level 3)

NEMS-BRS Results Difference from AE099

Reference

2000 2005 2010 2015 2020 2000 2005 2010 201 2020 2025 2030

MEF = 1.04 in 2004 & 1.26 in 2007 Level with Low Price Elasticity

Carbon (MtJa) 588.9 612.7 652.1 702.2 741 Carbon (MtJa) 0 -0.2 -1.1 -2.4 -3.6 -3.6 -3.6

NO(ktJa) 4191.2 3545.5 3661.2 3811.4 3876.1 NQ(ktla) 0 -1.6 -3.9 -7.8 -6.6 -6.6 -6.6

MEF = 1.04 in 2004 & 1.26 in 2007 Level with High Price Elasticity

Carbon(MtJa) 588.9 612.7 652.2 702.3 741 Carbon(MtJa) 0 -0.2 -1 -2.3 -3.6 -3.6 -3.6

NO(kt/a) 4191.2 3545.8 3661.2 3811.4 3875.5 NO(ktJa) 0 -1.3 -3.9 -7.8 -7.2 -72 -7.2

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Table 10. High and Low Economic Growth: Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3)

Results

2000 2005 2010 2015 2020 2025 2030

MEF = 1.04 in 2004 & 1.26 in 2007 High Economic Growth

Carbon (Mt/a) 0 -0.12 -0.6 -1.12 -1.54 -1.54 -1.54

NO (ktla) 0 -0.35 -1.88 -3.66 -4.97 -4 497

SO2 (kt/a) 0 -0.11 -0.56 -1.1 -1.49 -1.49 J

-1 .4

MEF = 1.04 in 2004 & 1.26 in 2007 Low Economic Growth I

Carbon (Mt/a) 0 -0.11 -0.6 -1.18 -1.62

__________

i -.'.62 -1.62 1

NO(kt/a) 0 -0.35

-__

-1.87 -3.66 -4.97 -4.9' 4:97]

SO2 (ktia) 0 -0.11 -0.56 -1.1 -1.49 [

-1.49 -1.49

Table 11. High and Low Price Elasticity: Change in Annual Household Emissions for

Proposed Standard (Trial Standard Level 3)

Results

2000 2005 2010 1 2015 2020 2'25 I

MEF = 1.04 in 2004 & 1.26 in 2007 Level with Low Price Elasticityc

Carbon (Mt/a) 0 -0.12 -0.61 -1.19

________ ________

-1.6 -1,6 1, ,

NO (ktla) 0 -0.36 -1.94 -3.78 -5.04 -.S.0Z -5.04

S02(ktla) 0 -0.11 -0.58 -1.13 -1.51 -J.5I -1.51

MEF = 1.04 in 2004 & 1.26 in 2007 Level with High Price Elasticity

Carbon (Mt/a) 0 -0.12 -0.56 -1.11 -1.58 -1.58 -1.58.

NO (kt/a) 0 -0.35 -1.78 -3.52 -4.95 -4.95 -4.95 I

SO2 (ktia) 0 -0.11 -0.53 -1.06 -1.48 -L48 -1.48 [

cAs used here , low price elasticity means the medium price/income elasticity option in the Shipment/NES

spreadsheet model discussed in Chapter 9 of the TSD.

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