ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION

STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS AND

INCANDESCENT REFLECTOR LAMPS

TABLE OF CONTENTS

EA.1 INTRODUCTION ................................................................................................EA­2

EA.2 METHODOLOGY ...............................................................................................EA­2

EA.3 RESULTS .............................................................................................................EA­4

REFERENCES .....................................................................................................................EA­5

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 EE-2006-STD-0131 COMMENT 16.1
ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY

CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT

LAMPS AND INCANDESCENT REFLECTOR LAMPS

EA.1 INTRODUCTION

The U.S. Department of Energy (DOE) will conduct an environmental assessment

as part of the Notice of Public Rulemaking (NOPR) for general service fluorescent lamps

(GSFL) and incandescent reflector lamps (IRL). DOE will assess these environmental

effects by using a variant of the U.S. DOE/Energy Information Administration (EIA)’s

National Energy Modeling System (NEMS) known as NEMS­BT to provide key inputs

to the analysis. The environmental assessment produces results in a manner similar to

those provided in the AEO.

The primary environmental effects of energy conservation standards for GSFL

and IRL would be reduced power plant emissions resulting from reduced electricity

consumption. The intent of the environmental assessment is to provide emissions results

estimates, and to fulfill requirements to properly quantify and consider the environmental

effects of all new Federal rules. The environmental assessment that will be produced by

NEMS­BT considers only two pollutants (SO2 and NOX) and two other emissions (carbon

and mercury). The form of carbon the NEMS­BT model tracks is CO2. Therefore, the

carbon discussed in this analysis is only in the form of CO2. For each of the trial standard

levels, DOE will calculate total undiscounted and discounted power plant emissions using

NEMS­BT.

EA.2 METHODOLOGY

DOE will conduct each environmental assessment performed in this rulemaking

as an incremental policy impact (i.e., a standard for the products under evaluation, in this

case fluorescent and incandescent lamps) of the AEO2007 forecast, applying the same

basic set of assumptions used in AEO2007. For example, the emissions characteristics of

an electricity generating plant will be exactly those used in AEO2007. Also, forecasts

conducted with NEMS­BT consider the supply­side and demand­side effects on the

electric utility industry. Thus, the analysis will account for any factors affecting the type

of electricity generation and, in turn, the type and amount of airborne emissions

generated by the utility industry.

The NEMS­BT model tracks carbon emissions with a specialized carbon

emissions estimation subroutine, producing reasonably accurate results due to the broad

coverage of all sectors and the inclusion of interactive effects. Past experience with

carbon results from NEMS suggests that emissions estimates are somewhat lower than

emissions based on simple average factors. One of the reasons for this divergence is that

NEMS tends to predict that conservation displaces generating capacity in future years.

On the whole, NEMS­BT provides carbon emissions results of reasonable accuracy, at a

level consistent with other Federal published results.

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NEMS­BT also reports SO2 and NOX, which DOE has reported in past analyses.

The Clean Air Act Amendments of 1990 (P.L. 101­549) set an SO2 emissions cap on all

power generation. The attainment of this target, however, is flexible among generators

through the use of emissions allowances and tradable permits. Although NEMS includes

a module for SO2 allowance trading and delivers a forecast of SO2 allowance prices,

accurate simulation of SO2 trading implies that physical emissions effects will be zero

because emissions will always be at or near the ceiling. However, there may be an SO2

benefit from energy conservation in the form of a lower SO2 allowance price. Since the

impact of any one standard on the allowance price is likely small and highly uncertain,

DOE does not plan to monetize the SO2 benefit.

NEMS­BT also has an algorithm for estimating NOX emissions from power

generation. The impact of these emissions, however, will be affected by the Clean Air

1 Interstate Rule (CAIR), which the EPA issued on March 10, 2005. CAIR will

permanently cap emissions of NOX in 28 Eastern states and the District of Columbia. 70

FR 25162 (May 12, 2005). As with SO2 emissions, a cap on NOX emissions means that

product energy conservation standards may have no physical effect on these emissions.

When NOX emissions are subject to emissions caps, DOE’s emissions reduction estimate

corresponds to incremental changes in the prices of emissions allowances in cap­andtrade emissions markets rather than physical emissions reductions. Therefore, while the

emissions cap may mean that physical emissions reductions will not result from

standards, standards could produce an environmental­related economic benefit in the

form of lower prices for emissions allowance credits. However, as with SO2 allowance

prices, DOE does not plan to monetize this benefit because the impact on the NOX

allowance price from any single energy conservation standard is likely small and highly

uncertain.

With regard to mercury emissions, NEMS­BT has an algorithm for estimating

these emissions from power generation, and, as it has done in the past, DOE is able to

report an estimate of the physical quantity of mercury emissions reductions associated

with an energy conservation standard. DOE assumed that these emissions would be

subject to EPA’s Clean Air Mercury Rule (CAMR), which would permanently cap

emissions of mercury for new and existing coal­fired plants in all States by 2010. Similar

to SO2 and NOx, DOE assumed that under such system, energy conservation standards

would result in no physical effect on these emissions, but would be expected to result in

an environmental­related economic benefit in the form of a lower price for emissions

allowance credits. DOE’s plan for addressing analysis does not include monetizing the

benefits of reduced mercury emissions, because DOE considered that valuation of such

impact from any single energy conservation standard would likely be small and highly

uncertain.

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

2 Protection Agency, in which the Court, among other actions, vacated the CAMR

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referenced above. Accordingly, DOE is considering whether changes are needed to its

plan for addressing the issue of mercury emissions in light of the D.C. Circuit’s decision.

With regard to particulates, these emissions are a special case because they arise

not only from direct emissions, but also from complex atmospheric chemical reactions

that result from NOx and SO2 emissions. DOE does not intend to analyze or report on the

particulate emissions from power stations because of the highly complex and uncertain

relationship between particulate emissions and particulate concentrations that impact air

quality.

EA.3 RESULTS

The results for the environmental assessment are similar to a complete NEMS run

as published in the AEO2007. These results include power­sector emissions for SO2,

NOX, mercury and carbon in 5­year forecasted increments extrapolated to 2042. The

outcome of the analysis for each CSL is reported as a deviation from the AEO2007

reference (base) case.

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REFERENCES

1 U.S. Environmental Protection Agency. Rule To Reduce Interstate Transport of Fine

Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain

Program; Revisions to the NOX SIP Call, Final Rule. Federal Register. 2005. 70(91):

pp. 25162­25210.

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

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