CHAPTER 16. ENVIRO NMENTAL ASSESSMENT

TABLE OF CONTENTS

16.1 INTRODUCTION

......................................................................................................... 16-1 16.2 AIR EMISSIONS ANALYSIS

...................................................................................... 16-1 16.2.1 Air Emissions Descriptions

............................................................................................ 16 -1 16.2.2 Air Quality Regulation

.................................................................................................. . 16-3 16.2.3 Global Climate Change

.................................................................................................. 1 6-4 16.2.4 Analytical Methods for Air Emissions

.......................................................................... 16-8 16.2.5 Effects on Power Plant Emissions

................................................................................. 16-9 16.2.6 Effects on Building Emissions

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

................................................................ 16-13 16.2.8 Economic Value of Emission Reductions

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

........................................................................................ 16-21 16.4 SOCIOECONOMIC IMPACTS

.................................................................................. 16-21 16.5 ENVIRONMENTAL JUSTICE IMPACTS

................................................................ 16-23 16.6 NOISE AND AESTHETICS

....................................................................................... 16-23 16.7 SUMMARY OF ENVIRONMENTAL IMPACTS

..................................................... 16-24

LIST OF TABLES Table 16.2.1 Impact of Conventional Cooking Product and Microwave Oven Efficiency Standards on Cumulative Energy-Related Emissions of CO 2 between 2012-2042 by Trial Standard Level (Million Metric Tons of CO 2 )

................... 16-7 Table 16.2.2 Power Sector Emissions Forecast from AEO2008Reference Case

................. 16-10 Table 16.2.3 Power Sector Emissions Imp act Forecasts for Conventional Cooking Products

............................................................................................................ 16-11 Table 16.2.4 Power Sector Emissions Impact Forecasts for Microwave Oven Energy Factor

............................................................................................................... 16-12 Table 16.2.5 Change in Household Emissi ons for Conventional Cooking Products

........... 16-13 Table 16.2.6 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct Power Plant Com bustion Emissions

................................................................ 16-14 Table 16.2.7 Estimates of Savings from CO 2 Emissions Reductions under Conventional Cooking Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

.................................................................................................................. 16-17 Table 16.2.8 Estimates of Savings from CO 2 Emissions Reductions under Microwave Oven Energy Factor Trial Standard Le vels at 7% Discount Rate and 3% Discount Rate

................................................................................................... 16-17

16-iLIST OF FIGURE Table 16.2.9 Monetary Savings from NO XEmissions Reductions under Conventional Cooking Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

.................................................................................................................. 16-18 Table 16.2.10 Monetary Savings from NO XEmissions Reductions under Microwave Oven Energy Factor Trial Standard Le vels at 7% Discount Rate and 3% Discount Rate

................................................................................................... 16-18 Table 16.2.11 High Emission Rate Estimates of Monetary Savings from Hg Emissions Reductions under Conventional Cooking Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

.............................................................. 16-19 Table 16.2.12 High Emission Rate Estimates of Monetary Savings from Hg Emissions Reductions under Microwave Oven Ener gy Factor Trial Standard Levels at 7% Discount Rate an d 3% Discount Rate

.................................................... 16-19 Table 16.4.1 Mean Life-Cycle Cost Sa vings for Consumers and Sub-Groups, Conventional Cooking Products

...................................................................... 16-22 Table 16.4.2 Mean Life-Cycle Cost Sa vings for Consumers and Sub-Groups, Microwave Ovens

............................................................................................ 16-23 Table 16.7.1 Environmental Impact Analys is Results Summary for Conventional Cooking Products

............................................................................................. 16-25 Table 16.7.2 Environmental Impact Analysis Results Summary for Microwave Ovens

..... 16-27

16-iiCHAPTER 16. ENVIRONMENTAL ASSESSMENT

16.1 INTRODUCTION This chapter describes potential environmen tal effects that may result from amended energy conservation standards for residential cooking products. Th e U.S. Department of Energy (DOE)’s proposed energy conservation standards ar e 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 leve ls (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 ener gy savings can be found in the national impact analysis in Chapter 11 of this technical suppor t 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, mu ch of this chapter describes the air quality analysis. The latter part of the chapter desc ribes potential impacts to other environmental
resources. The TSD for DOE’s notice of proposed rulemaking (NOPR) covered conventional cooking products (i.e., cooktops and ovens), mi crowave oven energy factor (EF), microwave oven standby power consumption, and commercial clothes washers (CCW). 1 This chapter presents information and results pertaining solely to conventional cooking products and microwave oven EF. The impact of more-efficient equipment on microwave oven standby power and CCWs will be addressed in subsequent TSDs.

16.2 AIR EMISSIONS ANALYSIS The primary focus of the environmental analys is is the impact on air quality of amended energy conservation standards for residentia l cooking products. The outcomes of the environmental analysis are driven by changes in power plant types and qu antities of electricity generated under each of the alternatives. Cha nges in generation are described in the utility impact analysis in Chapter 14.

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 pollutant s: nitrogen oxides (NO x ), mercury (Hg), and sulfur dioxide (SO 2 ). An air pollutant is a ny substance in the air that

16-1can 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 allo wed 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 en forcement of the emissions ceiling. But to the extent reduced power generation demand decreas es the demand for and price of emissions allowance permits, there is an environmenta lly related economic be nefit from the proposed energy conservation standards reducing SO 2 emissions allowance demand. Furthermore, over time, if emissions decline, there is greater fl exibility 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 (NOx ) 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 la yer 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 fo rmation 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 residentia l sources that burn fossil fuels. NO x can also be formed naturally. Electric utilities acc ount for about 22 percent of NO x emissions in the United States. Mercury Coal-fired power plants emit Hg found in co al during the burning pr ocess. While coalfired power plants are the largest remaining s ource of human-generated Hg emissions in the United States, they contribute very little to th e global Hg pool or to contamination of U.S.

aMore information on air pollution characteristics and regul ations is available on the U.S. Environment Protection Agent (EPA)’s website at www.epa.gov.

16-2waters. U.S. coal-fired power plants emit Hg inthree different forms: oxidized Hg (likely to deposit within the United States); elemental H g, 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 estuarie s through rain, snow, and dry deposition. Once there, it can transform into methylmercur y 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 increasedrisk of poor performa nce 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 po llutant (see below), but it is of interest because of its classifi cation 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 occurri ng GHGs include water vapor, CO 2 , methane (CH 4 ), nitrous oxide (N 2 O), and ozone (O 3 ). Human activities, however, add to th e 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 pr oducts 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 m ovement of carbon between the atmosphere and the land and oceans is dominated by natural processe s, 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 th e atmosphere annually. In the U. S., CO 2 emissions from both energy generation and industrial processes account for 8 4.6 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 nationa l air quality standards for six co mmon 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 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.

16-3In 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 St ates. CAIR achieves large reductions of SO 2 and/or NOx emissions across 28 eastern states and the Di strict 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 plan ts to participate in an EPA-administered interstate cap-and-trade system th at caps emissions in two stages, or 2) meet an individual state emissions budget through measures of th e 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 en titled “Standards of Performance for New and Existing Stationary Sources: Electric Steam Ge nerating 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 estab lished 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 App eals for the District of Columbia Circuit (D.C. Circuit) issued its deci sion 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 fo r 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. Envi ronmental 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 gl obal concern because it is expected to have widespread, adverse effects on natural resour ces and systems. A growing body of evidence points to anthropogenic sources of gree nhouse gases, such as carbon dioxide (CO 2 ), as major contributors to climate change. Because this Rule, if finalized, will likely decrease CO 2 emission rates from the fossil fuel sector in the United St ates, 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.

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

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

dSee http://www.epa.gov/cleanairinterstaterule/.

16-4Impacts of Climate Chan ge on the Environment Climate is usually defined as the average we ather, 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 variabil ity of its properties (e.g., temperature or precipitation) over an extended perio d, typically decades or longer. The World Meteorological Organization a nd United Nations E nvironment Programme (UNEP) established the Intergovernmental Pa nel on Climate Change (IPCC) to provide an objective source of information about climat e change. According to the IPCC Fourth Assessment Report (IPCC Report), published in2007, climate change is consistent with observed changes to the world’s na tural 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 i ce 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 a nd more frequent heat waves in many locations worldwide, and numerous ecological changes. Looking forward, the IPCC describes con tinued 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 t oday. These increases vary depending on the model and emissions scenarios. The IPCC Report describes incremental impacts a ssociated with the rise in temperature. At ranges of incremental increases to the global average temperature, IPCC reports, with either high or very high confidence, that there is likely to be an increas ing degree of impacts such as coral reef bleaching, loss of wild life habitat, loss to specific ecosystems, and negative yield impacts for major cereal crops in the tropics, but al so 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. 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 ther eby alters the energy balance of the planet, which gradually increases its average temperature. The IPCC

16-5Report 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 ma jority (74%) of the CO 2 attributable to fossil fuel use. For the fu ture, 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. Th e residence time of CO 2 in the atmosphere is long compared to the emission processes. Therefore, the gl obal cumulative emissions of CO 2 over long periods determine CO 2 concentrations because it takes hundreds of y ears 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 globa l climate stabilization, and the emission rates associated with achieving the “stabilizing” concentrations by partic ular 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 this low 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 leve ls). To achieve concentrations between 350 ppm to 400 ppm, the IPCC scenarios pr esent that there would have to be a rapid downward trend in total annual gl obal emissions of greenhouse gase s 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 re ductions 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 forci ng) on a global climate syst em 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 deforest ation and decay from agriculture biomass; agricultural and industrial emissions of methane; and emissions of nitrous oxide and fluorocarbons.

g IPCC Working Group 3 Table TS 2

16-6The Beneficial Impact of the Rule on CO 2 Emissions If finalized, it is anticipated thatthe 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 2 008 Annual Energy Outlook ( AEO2008 ) 2 that U.S. annual energy-related emissions of CO 2 in 2005 were about 6.0 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 we re attributed to residential and commercial buildings sector (including related energy–using equipment such as residential cooking products). Most of the greenhouse ga s 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 AEO2008Reference Case, EIA projectedthat annual energy-related CO 2 emissions would grow from 6.0 billion metric tons in 2005 to 6.9 billion metric tons in 2030, an increase of 15 percent (see AEO2008 ), while emissions attributable to buildings would grow to 2.9 billion tons, an increase of 26 percent.
As shown in Table 16.2.2 in the AEO2008Reference Case, the cumulative U.S. energyrelated power sector CO 2 emissions between 2012 and 2042 are described at about 86 billion metric tons. The estimated cumulative CO 2 emission reductions from a residential cooking product efficiency standard (shown as a range of alternative Trial Standa rd Levels) during this same 30-year period are indicate d in Table 16.2.1. Estimated CO 2 emission reductions in Table 16.2.1 come from two sources: electricity generati on (i.e., power plants) and fossil fuel-fired appliances. The estimated CO 2 emission reductions from electrici ty generation are calculated using the NEMS-BT model. The estimated CO 2 emission reductions from fossil fuel-fired appliances (i.e., gas cooking pr oducts) are derived from emissions factors for residential and commercial natural gas combustion.
Table 16.2.1 Impact of Conventional Cooking Pro duct and Microwave Oven Efficiency Standards on Cumulative Energy-Related Emissions of CO 2 between 2012

- 2042 by Trial Standard Level (Million Metric Tons of CO 2 ) Trial Standard Levels TSL 1 TSL 2 TSL 3 TSL 4 Conventional Cooking Products (CCP) -13.74 -15.46 -23.39 -34.96 Microwave Ovens (MWO) EF - 22.88 -33.46 -53.89 -74.67 Total -36.82 -48.92 -77.28 -109.63 Percent of Total Cumulative Emissions Reduction from 2012 to 2042 compared with the AEO 2008 Reference Case -0.042 -0.057 -0.090 -0.127

* All results in million metric tons, equivalent to 1.1 sh ort 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 0.127 percent of U.S. energy-related emissions of CO 2 (total emissions reported for TSL 4 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

16-7compared to U.S. CO 2 emissions absent an increase in the required efficiency of residential cooking products and microwave ovens. The Incremental Impact of th e Rule on Climate Change It is difficult to correlate specific emissi on rates with atmospheri c concentrations of CO 2 and specific atmospheric concentrations with future temperatures because the IPCC Report describes a clear lag in the climate syst em between any given concentration of CO 2 (even if maintained for long periods) and the subsequent average worldwide and regional temperature, precipitation, and extreme weathe r 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. Th e 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 sp ecific temperature levels. Because of how complex global climate systems ar e, it is difficult to know to what extent and when particular CO 2 emissions rates will impact glob al 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 provisi ons include New Source Performance Standards, and Re vised New Source Performance St andards. The version of NEMS-BT in 2008 also included provisions for the CAIR, which imposes stricter restrictions on SO 2 and NO Xfor 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 vaca ting the CAMR. Although the constraints on Hg in CAMR have sin ce been vacated by a court decision, the AEO2008 Reference Case assumes that emissions of Hg wo uld decline over time as shown in Table 16.2.2.
Because the courts vacated CAMR, the 2008 version of NEMS-BT could not be used directly to estimate emissions impacts for H g. Instead, DOE established a range of Hg reductions due to standards. DOE’s high estimate used a Hg emission rate based on the AEO2008 . Because virtually all Hg emitted from electricity generation is from coal-fired power plants, DOE based the emission rate from the t ons of Hg emitted per TWh of coal-generated electricity. DOE based the emission rate on the average value reported in the AEO2008for the

16-8year 2006. This emission rate is 0.0230 tons per TWh (0.0253 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 Hg emissions from the power sector, DOE multip lied the emission rate by the reduction in coal-generatedelectricity 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 cooking pr oducts in Table 16.2.3 and Table 16.2.4 for the period from 2012 to 2042. Coal-fired electric generation is the single largest source of electricity in the United States. Because the mix of coals used signifi cantly affects the emissions produced, the model includes a detailed representation of coal suppl y. The model considers the rank of the coal as well as the sulfur contents of the fuel us ed when determining optimal dispatch. Within the NEMS-BT model, pl anning 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 lo w emission rates. These methods for reducing emission are compared to dispatching options su ch as fuel switching and allowance trading. Environmental regulations also a ffect 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 invo lve purchasing allowances or over complying at an existing unit. Modeling of SO 2 trading tends to imply that the phys ical 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 assu mption is consistent with previous DOE environmental assessment documents. As noted in Chapter 14, NEMS-BT model for ecasts end in year 2030. Emissions impacts beyond 2030 were extrapolated for th is rulemaking in Table 16.2.3 and 16.2.4.

16.2.5 Effects on Power Plant Emissions Table 16.2.2 shows reference power plant emi ssions in selected y ears along with the change from the AEO2008Reference Case. The Reference case emissions are the emissions shown by the NEMS-BT model to result if none of the TSLs are promulgated.

16-9Table 16.2.2 Power Sector Emissions Forecast from AEO2008 Reference Case NEMS-BT Results*: 2005 2010 2015 2020 2025 2030 CO 2 (Million metric tons/year)** 2,39 7 2,413 2,519 2,627 2,771 2,948 NO X(Thousand metric tons/year) † 3,301 2,115 1,911 1,917 1,939 1,962 Hg (metric tons/year) † 46.92 33.78 22.46 17.44 15.32 13.56 * All results in metric tons, equivalent to 1.1 short tons and negative values refer to a reduction compared with the Base Case ** Comparable to Table A17 of AEO2008 : Electric Generators † Comparable to Table A8 of AEO2008 : Emissions
Table 16.2.3 and Table 16.2.4 show the estima ted 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 though 16.2.4 are extremely small.

16-10Table 16.2.3 Power Sector Emissions Impact Fo recasts for Conventional Cooking Products NEMS-BT Results* Difference from AEO2008 Reference Case Extrapolation 2012 2015 2020 2025 2030 2035 2040 2042 Total 2012-2042

Trial Standard Level 1 CO 2(Mt/a) NOx (kt/a) Hg (t/a) High Low

Trial Standard Level 2 CO 2(Mt/a) NOx (kt/a) Hg (t/a) High Low

Trial Standard Level 3 CO 2(Mt/a) NOx (kt/a) Hg (t/a) High Low

Trial Standard Level 4 CO 2(Mt/a) Hg (t/a) High Low -0.09 -0.13 -0.14 -0.19 -0.25 -0.25 -0.25 0.00 -0.02 -0.01 -0.02 -0.03 -0.03 -0.03

0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00

-0.11 -0.16 -0.18 -0.24 -0.33 -0.33 -0.33 0.00 -0.02 -0.01 -0.02 -0.03 -0.03 -0.03

0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00

-0.14 -0.21 -0.24 -0.34 -0.48 -0.48 -0.48 0.00 -0.03 -0.01 -0.03 -0.05 -0.05 -0.05

0.00 0.00 -0.01 -0.01 -0.01 -0.01 -0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00

-0.19 -0.30 -0.35 -0.51 -0.74 -0.74 -0.74

-0.01 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -0.25 -0.03

-0.01 0.00

-0.33 -0.03

-0.01 0.00

-0.48 -0.05

-0.01 0.00

-0.74

-0.02 0.00 -6.02 -0.61

-0.15 0.00

-7.74 -0.78

-0.19 0.00

-11.11

-1.12

-0.28 0.00

-16.76

-0.41 0.00

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

16-11Table 16.2.4 Power Sector Emissions Impact Fo recasts for Microwave Oven Energy Factor NEMS-BT Results* Difference from AEO2008 Reference Case Extrapolation Total

Trial S tandard Level 1 CO 2(Mt/a) NO x (kt/a) Hg (t/a) High Low

Trial S tandard Level 2 CO 2(Mt/a) NO x (kt/a) Hg (t/a) High Low

Trial S tandard Level 3 CO 2(Mt/a) NO x (kt/a) Hg (t/a) High Low

Trial S tandard Level 4 CO 2(Mt/a) NO x (kt/a) Hg (t/a) High Low 2012 2015 2020 2025 2030

0.00 -0.55 -0.78 -0.84 -0.80 0.00 -0.08 -0.04 -0.10 -0.09

0.00 -0.01 -0.01 -0.02 -0.02 0.00 0.00 0.00 0.00 0.00

0.00 -0.78 -1.06 -1.21 -1.21 0.00 -0.11 -0.06 -0.14 -0.14

0.00 -0.01 -0.02 -0.03 -0.03 0.00 0.00 0.00 0.00 0.00

0.00 -1.24 -1.63 -1.93 -1.98 0.00 -0.17 -0.09 -0.22 -0.23

-0.01 -0.01 -0.03 -0.04 -0.04 0.00 0.00 0.00 0.00 0.00

0.00 -1.70 -2.20 -2.66 -2.78 0.00 -0.24 -0.12 -0.30 -0.32

-0.01 -0.02 -0.04 -0.06 -0.06 0.00 0.00 0.00 0.00 0.00 2035 2040

-0.80 -0.80 -0.09 -0.09

-0.02 -0.02 0.00 0.00

-1.21 -1.21 -0.14 -0.14

-0.03 -0.03 0.00 0.00

-1.98 -1.98 -0.23 -0.23

-0.04 -0.04 0.00 0.00

-2.78 -2.78 -0.32 -0.32

-0.06 -0.06 0.00 0.00 2042

-0.80 -0.09

-0.02 0.00

-1.21 -0.14

-0.03 0.00

-1.98 -0.23

-0.04 0.00

-2.78 -0.32

-0.06 0.00 2012-2042

-22.88

-2.55

-0.46 0.00

-33.46

-3.75

-0.68 0.00

-53.89

-6.06

-1.10 0.00

-74.67

-8.42

-1.52 0.00

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

16.2.6 Effects on Building Emissions For residential cooking products, impact s on household emissions and commercial building emissions, respectively, at the site ar e also reported. These estimates are based on exogenous emissions factors for residential a nd commercial natural ga s 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. Household emissions from residential micr owave ovens are not reported because all savings are from electricity.
The emissions factors DOE used are derive d from what are reported in the AP-42 for residential water heaters because no explicit lis ting was provided for cooking products. However, the AP-42 sources does provide a method for estima ting the share of residential emissions from

16-12cooking products 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. 3 hAs 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. 4 i For these reasons, the Department opted to simply use the water h eating emissions factor as a way of providing a rough estimates for the emissions savings associ ated with these effici ency standards, but acknowledging that these estimates are only general approximations. Table 16.2.5 shows the estimated changes in bu ilding emissions in selected years for the conventional cooking product TSLs.
Table 16.2.5 Change in Household Emissions fo r Conventional Cooking Products NEMS-BT Results* Difference from AEO2008 Reference Case

2012 2015 2020 2025 2030 Extrapolation 2035 2040 2042 Total 2012-2042

Trial Standard Level 1 CO 2(Mt/a) NOx (kt/a)

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

Trial Standard Level 3 CO 2(Mt/a) NOx (kt/a)

Trial Standard Level 4 CO 2(Mt/a) NOx (kt/a) -0.03 -0.11 -0.22 -0.29 -0.30 -0.02 -0.09 -0.18 -0.23 -0.24

-0.03 -0.11 -0.22 -0.29 -0.30 -0.02 -0.09 -0.18 -0.23 -0.24

-0.04 -0.16 -0.33 -0.45 -0.50 -0.03 -0.13 -0.26 -0.36 -0.40

-0.06 -0.22 -0.47 -0.66 -0.76 -0.05 -0.18 -0.37 -0.52 -0.60 -7.72 -6.10

-7.72 -6.10

-12.28

-9.70

-18.20 -14.38 -0.30 -0.30 -0.30 -0.24 -0.24 -0.24

-0.30 -0.30 -0.30 -0.24 -0.24 -0.24

-0.50 -0.50 -0.50 -0.40 -0.40 -0.40

-0.76 -0.76 -0.76 -0.60 -0.60 -0.60
* All results in metric tons (t), equivalent to 1.1 short tons

16.2.7 Effects on Upstream Fuel-Cycle Emissions Fuel-cycle emissions refer to the emissions associated with the am ount of energy used in the upstream production and downstream consumpti on 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

hThe AP-42 source does list an appro ach for how to estimate residential cooking related emissions as a function of the share of total gas deliverie s (http://www.epa.gov/ttn/chief/eiip /techreport/volume03/ng.pdf).

i See section 3.2 of a AGA report.

16-13consumption, but does not account for upstream emissions (i.e., emissions from energy losses during coal and natural gas produc tion). Thus, this analysis re ports 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 ma gnitude of upstream effects. These upstream emissions would be in addition to emissions from direct combustion. Relativ e 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. 5 Transportation emissions include emissions from the fuel used by the mode of transportati on that moves the coal from the mine to the power plant.
In addition, based on Dr. DeLu chi’s work, DOE estimated that approximately an amount equal to 14 percent of emissions from natural ga s production result from upstream processes. Emission factor estimates and corresponding percen tages of contributions of upstream emissions from coal and natural gas production, relative to power plant emissions, are shown in Table 16.2.6 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 16.2.6 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 16.2.6 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

16.2.8 Economic Value of Emission Reductions In examining the impact of potential standard s, DOE assessed potential monetary benefits from reduced emissions of CO 2 , NO x , Hg, and SO 2 associated with this rulemaking. With regard to CO 2 , the monetary estimates presente d below in Tables 16.2.10 through 16.2.13 are based on an assumption of no benefit to an average benefit value reported by the

16-14Intergovernmental Panel on Climate Change (IPCC). j It is important to note that the IPCC estimate used as the upper bound value was derived from an estimate of the mean value of worldwide impacts from potential climate impacts caused by CO 2 emissions, and not just the effects likely to occur within the United Stat es. As DOE considers a monetary value for CO 2 emission reductions, the value shou ld be restricted to a represen tation of those costs/benefits likely to be experienced in the United States. As DOE expects that such values would be lower than comparable global values, however, there cu rrently are no consensus estimates for the U.S. benefits likely to result from CO 2 emission reductions. However, DOE believes it is appropriate to use U.S. benefit values, where available, and not world benefit va lues in its analysis. k Because U.S. specific estimates are not available, and DOE did not receive any additional information that would help serve to narrow th e proposed range as a representative range for domestic U.S. benefits, DOE belie ves it is appropriate to propose the global mean value as an appropriate upper bound U.S. value for purposes of sensitivity analysis. Given the uncertainty surrounding estimates of the societal cost of carbon (SCC), relying on any single study may be inadvisable since its estimate of the SCC will depend on many assumptions made by its authors. The Wo rking Group II’s contribution to the Fourth Assessment Report of the IPCC notes that: The large ranges of SCC are due in the large part to differenc es in assumptions regarding climate sensitivity, response lags, the treatm ent of risk and equity, economic and noneconomic impacts, the inclusion of potential ly catastrophic losses, and discount rates. 6
Because of this uncertainty, DOE is relying on research performed by Tol, 7 which was presented in the IPCC’s Fourth Assessment Repo rt, and was a comprehensive meta-analysis of estimates for the value of SCC. As a result, DOE is relying on the Tol study reported by the IPCC as the basis for its analysis. DOE continues to believe that the most approp riate monetary values for consideration in the development of efficiency standards are those drawn from studies that attempt to estimate the present value of the marginal economic benefits likely to result from reducing greenhouse gas

j During the preparation of its most recent review of the state of climate sc ience, the Intergovernmental Panel on Climate Change (IPCC) identified various estimates of th e present value of reducing carbon-dioxide emissions by one ton over the life that these emissions would remain in the atmosphere. The estimates reviewed by the IPCC spanned a range of values. In the absence of a consensus on any single estimate of the monetary value of CO 2 emissions, DOE used the estimates identified by the study cited in Summary for Policymakers prepared by Working Group II of the IPCC’s Fourth Assessment Report to estimate the potential monetary value of CO 2reductions likely to result from standards finalized in this rulemaking. A ccording to IPCC, the mean so cial cost of carbon (SCC) reported in studies published in peer-reviewed journals was $43 per ton of carbon. This translates into about $12 per ton of carbon dioxide. The literature review (Tol 2005) from which this mean was derived did not report the year in which these dollars were denominated. However, we unders tand this estimate was denominated in 1995 dollars. Updating that estimate to 2007 dollars yields a SCC of $15 per ton of carbon dioxide.

k In contrast, most of the estimates of costs and benefits of increasing the efficiency of residential cooking products include only economic values of impacts that would be experienced in the U.S. For example, in determining impacts on manufacturers, DOE generally does not consider impacts that occur solely outside of the United States.

16-15emissions, rather than estimates that are based on the market value of emission allowances under existing cap and trade programs or estimates that are based on the cost of reducing emissions - both of which are largely determined by policy decisions that set the timing and extent of emission reductions and do not necessarily reflec t the benefit of reductions. DOE also believes that the studies it relie s upon generally should be studies that were the su bject of a peer review process and were published in reputable journals. For this analysis, DOE is essentially proposi ng to rely on a range of values based on the values presented in the Tol studay. Additionally, DOE has applied an annual growth rate of 2.4 percent to the value of SCC, as suggested by the IPCC Working Group II, 8 based on estimated increases in damages from future emissions reported in published studies. Because the values in the Tol study were presented in 1995 dollars, DOEis assigning a range for the SCC of $0 to $20 (in $2007) per ton of CO 2 emissions. DOE is proposing to use the median estimated social cost of CO 2 as an upper bound of the range. This value is based on the Tol studa y, which reviewed 103 estimates of the SCC from 28 published studies, and concluded that when only peer-reviewed studies published in recognized journals are considere d, “that climate change impacts ma y be very uncertain but [it] is unlikely that the marginal damage costs of carbon dioxide emissions exceed $50 per ton carbon [comparable to a 2007 value of $20 per t on carbon dioxide when expressed in 2007 U.S. dollars with a 2.4% growth rate].” In proposing a lower bound of $0 for the es timated range, DOE agrees with the IPCC Working Group II report that “significant warming across the globe a nd the locations of significant observed changes in many systems consistent with warming is very unlikely to be due solely to natural variability of temperatur es or natural variability of the systems”, 9 and, thus, tentatively concludes that a gl obal value of zero for reducing emissions cannot be justified. However, DOE also believes that it is reasonabl e to allow for the possibility that the U.S. portion of the global cost of carbon dioxide emissions may be quite low. In fact, some of the studies looked at in Tol reported negative values for the S CC. DOE is using U.S. benefit values, and not world benefit values, in its analysis, and, further, DOE believes that U.S. domestic values will be lower than the global values. Additionally, th e statutory criteria in EPCA do not require consideration of global effects. Therefore, DOE is propos ing to use a lower bound of $0 per ton of CO 2 emissions in estimating the potential benefits of today’s proposed rule. The resulting estimates of the potential range of net present value benefits associated with the reduction of CO 2 emissions are reflectedin Tables 16.2.7 and 16.2.8.

16-16Table 16.2.7 Estimates of Savings from CO 2 Emissions Reductions under Conventional Cooking Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative CO 2 Emission

Reductions (Million metric tons) Value of Estimated CO 2 Emission Reductions Based on IPCC Range at 7% Discount Rate

(Million 2007$) Value of Estimated CO 2 Emission Reductions Based on IPCC Range at 3% Discount Rate

(Million 2007$) TSL 1 13.74 $0 – $109 $0 – $241 TSL 2 15.46 $0 – $122 $0 – $270 TSL 3 23.39 $0 – $182 $0 – $408 TSL 4 34.96 $0 – $269 $0 – $610

Table 16.2.8 Estimates of Savings from CO 2 Emissions Reductions under Microwave Oven Energy Factor Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative CO 2 Emission

Reductions (Million metric tons) Value of Estimated CO 2 Emission Reductions Based on IPCC Range at 7% Discount Rate

(Million 2007$) Value of Estimated CO 2 Emission Reductions Based on IPCC Range at 3% Discount Rate

(Million 2007$) TSL 1 22.88 $0 – $192 $0 – $404 TSL 2 33.46 $0 – $277 $0 – $589 TSL 3 53.89 $0 – $443 $0 – $948 TSL 4 74.67 $0 – $612 $0 – $1313

DOE also investigated the potential monetary impact resulting from the impact of potential efficiency standards on NO x and Hg emissions. As discussed earlier, with respect to NO x the CAIR rule has been vacated by the courts, so projected annual NO x allowances from NEMS-BT are no longer relevant. Therefore, DOE’ estimates of NO x emissions are not controlled by a nati onwide regulatory system. For the range of NO x reduction estimates and Hg reduction estimat es, DOE estimated the national monetized benefits of emissions reductions based on environm ental damage estimates from the literature. Available estimates suggest a very wi de range of monetary values for NO x emissions, ranging from $370 per ton to $3,800 per ton of NO x from stationary sources , measured in 2001$ or a range of $421 per ton to $4,326 per ton in 2006$. 10 The resulting estimates of the potential range of the present value benefits associated with the national reduction of NO x are presented in Tables 16.2.9 through 16.2.10. Because DOE estimated NO x emissions with high and low emission rate estimates, two sets of results are presented for each product.

16-17Table 16.2.9 Monetary Savings from NO XEmissions Reductions under Conventional Cooking Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative NO X Emission

Reductions (Thousand metric tons) Value of Estimated NO X Emission Reductions at 7% Discount Rate

(Million 2006$) Value of Estimated NO X Emission Reductions at 3% Discount Rate

(Million 2006$) TSL 1 6.71 $0.7 – $7.3 $1.5 – $15.4 TSL 2 6.88 $0.7 – $7.5 $1.5– $15.7 TSL 3 10.82 $1.1 – $11.5 $2.4 – $24.5 TSL 4 16.07 $1.6 – $16.8 $3.5 – $36.1

Table 16.2.10 Monetary Savings from NO XEmissions Reductions under Microwave Oven Energy Factor Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative NO X Emission

Reductions (Thousand metric tons) Value of Estimated NO X Emission Reductions at 7% Discount Rate

(Million 2006$) Value of Estimated NO X Emission Reductions at 3% Discount Rate

(Million 2006$) TSL 1 2.55 $0.3 – $3.2 $0.6 – $6.1 TSL 2 3.75 $0.4 – $4.6 $0.9 – $8.9 TSL 3 6.06 $0.7 – $7.3 $1.4 – $14.4 TSL 4 8.42 $1.0 – $10.2 $1.9 – $19.9

DOE has determined that the basic science linking mercury emissions from power plants to impacts on humans is considered highly uncertain. However, DOE identified two estimates of the environmental damages of mercury based on two estimates of the adverse impact of childhood exposure to methyl mercury on IQ for Ameri can children, and subse quent loss of lifetime economic productivity resulting from these IQ losses. The high-end estimate is based on an estimate of the current aggregate co st of the loss of IQ in Americ an children that results from exposure to mercury of U.S. power plant origin ($1.3 billion per year in 2000$), which translates to $31.7 million per ton emitted per year (2006$). 11 The low-end estimate was $664,000 per ton emitted in 2004$ or $709,000 per ton in 2006$, which DOE derived from a published evaluation of mercury control using different methods and assumptions from the first study, but also based on the present value of the lifetime earnings of children exposed. 12 l The resulting estimates of the potential range of the present value benefits as sociated with the nation al reduction of Hg are presented in Tables 16.2.11 and 16.2.12. DOE es timated Hg emissions with high and low emission rate estimates. But because the low emission rate estimate is zero, there is only the need to provide results based on th e high Hg emission rate estimate.

The estimate was derived by back-calculating the annual benefits per ton from the net present value of benefits reported in the study.

16-18 lTable 16.2.11 High Emission Rate Estimates of Mo netary Savings from Hg Emissions Reductions under Conventional Cookin g Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative Hg Emission Reductions (metric tons) Value of Estimated Hg Emission Reductions at 7% Discount Rate

(Million 2006$) Value of Estimated Hg Emission Reductions at 3% Discount Rate

(Million 2006$) TSL 1 0.15 $0.0 – $1.3 $0.1 – $2.6 TSL 2 0.19 $0.0 – $1.6 $0.1 – $3.3 TSL 3 0.28 $0.1 – $2.2 $0.1 – $4.6 TSL 4 0.41 $0.1 – $3.3 $0.2 – $6.9

Table 16.2.12 High Emission Rate Estimates of Mo netary Savings from Hg Emissions Reductions under Microwave Oven Ener gy Factor Trial Standard Levels at 7% Discount Rate and 3% Discount Rate

Trial Standard Level Estimated Cumulative Hg Emission Reductions (metric tons) Value of Estimated Hg Emission Reductions at 7% Discount Rate

(Million 2006$) Value of Estimated Hg Emission Reductions at 3% Discount Rate

(Million 2006$) TSL 1 0.46 $0.1 – $3.7 $0.2 – $7.8 TSL 2 0.68 $0.1 – $5.4 $0.2 – $11.3 TSL 3 1.10 $0.2 – $8.6 $0.4 – $18.2 TSL 4 1.52 $0.3 – $11.8 $0.6 – $25.2

With regard to SO 2 emissions, unlike the other pollutant s considered in this analysis, these emissions have for some time been subj ect to a national cap w ith corresponding annual allowances openly traded; therefor e, considerable market experience with these instruments has already been accumulated. It has been argued that imposition of any standard that lowers U.S. national electricity consumption creates beneficial downward pre ssure on the prices of these allowances, and this cost reduction benefit should be considered in any analysis of a proposed standard. While this assertion is fundamenta lly sound (i.e., reduced electricity demand should ceteris paribus bring about lower SO 2 allowance prices) there are a myriad of complications impeding any meaningful quantification of any associated benefit. While complexity of analysis alone clearly cannot justify disregarding a potenti al consequence of a standard, DOE additionally believes these benefits to be both volatile and de minimis when compared to the direct effects of a standard as estimated in this analysis. Some of the problems to be confronted in an allowance price effect forecast are:

• Only any net lowering of the total allowance bill to generators free of transfers is the potential source of a benefit. Any such compliance cost saving would need to be accurately estimated, and this effect is no diffe rent from the benefit derived from a cost reduction for other inputs, such as fuel. When the SO 2 allowance market that was created in 1995 under the Clean Air Act Amendments be gan, initial allowance allocations were directly granted to large affected units based on their historic (1985-87) use of fuel. For

16-1930 years, allowances for the following year ar e issued every spring at a declining rate to these entitled parties, and thereafter can be freely used, traded, or banked. Some additional allowances are allocated in dive rse ways (e.g. as rewards to generators installing control equipment). In other word s, the entitled generators holding emission rights are losers when the valu e of allowances declines, wh ile the buyers of allowances are gainers. Before they are used, allowa nces may be traded many times at prices reflecting the marginal not average cost of compliance.

• The trading system allows for allowance banki ng. Consequently, any observed change in a forecast year could represent the manife station of market fundamentals but could similarly just indicate deposit or withdrawal of allowances. In general, used allowances have fallen short of the cap so emissions may exceed the specified cap for future years.

• Control efforts could further reduce the SO 2 cap for some jurisdictions, creating regulatory uncertainty that pe rturbs the allowance market. The issuance of the proposed and final CAIR rules were likely contributing factors to allowance price increases leading to a dramatic 2005 allowance price spike. While prices had already fallen far below their historic highs by the time CAIR was vacated in the summer of 2008, spot allowance prices nonetheless made a further precipitous drop following the D.C. Circuit Court ruling.

• Because allowances can be traded freely by generators, brokers, and investors, they can serve as financial instruments, and, especi ally since 2003, allowance prices have been volatile. Between 2000, when a tightened Clean Air Amendment cap came into force, and 2007, allowances traded between a low of about $120/short ton in 2002 and a high of about $1600/short ton, withthe 2005 spike being particularly dramatic. 13 14 Since there is no reason to believe that these conditions w ill alter over the life of a proposed standard, the challenge of forecasting prices is muchmore complex than a simple supply-demand balance might suggest. Also, note that any quan tification of the bene fit likely depends on the level of prices as well as their net change. To believe that a simple delta in the prices could be used to estimate the benefit is to believe that the same numerical reduction in price would result from the standard whether the prevailing trad ing price were $100 or $1000 per short ton. As noted earlier, the forecasting tool used for this analysis is the AEO2008version of NEMS-BT, which generates forecasts of both SO 2 emissions and allowance prices. Unfortunately, this model was released before CA IR was overturned so its forecast enforces the tighter CAIR cap in the affected east of countr y, and does not represent current conditions. Given the timing of the CAIR ruling relative to the pr ogress of this analysis , attaining projections absent CAIR has not been possible. Nonetheles s, as a indicative bounding case, the net average price delta for the period 2012 to 2030 for the maximum technologically feasible (Max Tech) TSLs reported by the AEO2008NEMS-BT are -0.02 percent for cooking products (TSL 4) and -0.05 percent for microwave ovens (TSL 4). These estimates represent the average of percentage changes from the interpolated Max Tech standards for each of the products in the EMM East region. DOE considers this effect to be inconseque ntial relative to other elements in the benefits

16-20analysis, and given the significant e ffort that would be required to develop a refined estimate, the SO 2 allowance price effect is not considered further in this analysis. If future analysis suggests that the SO 2 allowance price effect is both significan t and estimable using NEMS-BT, it may be added to supporting material.

16.3 WETLAND, ENDANGERED AND THREATENED SPECIES, AND CULTURAL RESOURCES DOE’s action is not site-specific, nor woul d it affect land disturbance or use due to cooking products being installed in residential build ings. Therefore, none of the TSLs are expected to affect the quality of wetlands, or threatened or endangered species. Further, this action is not expected to impactcultural resources such as hist orical or archaeological sites.

16.4 SOCIOECONOMIC IMPACTS DOE's analysis has shown that the increase inthe first cost of pur chasing more efficientcooking products at the proposed standard level is completely offset by a reduction in the lifecycle 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 e quipment even through the first cost increases. The complete analysis and its conclusions are presented in Chapter 8 of the TSD. For subgroups of low-income and senior consumers that purchase cooking products, DOE determined that the average LCC impact is similar to that for the full sample of consumers. Therefore, DOE concludes that the proposed ac tion would have no significant socioeconomic impact. For a complete discussion on the LCC impacts on consumer subgroups, see Chapter 12 of the TSD.
Tables 16.4.1 and 16.4.2 show the mean L CC savings for both the full sample of consumers and subgroup of consumers for conven tional cooking products a nd microwave ovens.

16-21Table 16.4.1 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, Conventional Cooking Products Trial Standard Level 1 2 3 4 Electric Coil Cooktops All Consumers NA $4 $4 $4 Low-Income Consumer Subgroup NA $4 $4 $4 Senior-Only Consumer Subgroup NA $3 $3 $3 Electric Smooth Cooktops All Consumers NA NA NA -$238 Low-Income Consumer Subgroup NA NA NA -$238 Senior-Only Consumer Subgroup NA NA NA -$239 Gas Cooktops All Consumers $15 $15 $15 -$8 Low-Income Consumer Subgroup $21 $21 $21 -$1 Senior-Only Consumer Subgroup $16 $16 $16 -$7 Electric Standard Ovens All Consumers NA $11 $11 -$50 Low-Income Consumer Subgroup NA $10 $10 -$51 Senior-Only Consumer Subgroup NA $7 $7 -$56 Electric Self-Cleaning Ovens All Consumers NA NA NA -$143 Low-Income Consumer Subgroup NA NA NA -$155 Senior-Only Consumer Subgroup NA NA NA -$205 Gas Standard Ovens All Consumers $9 $9 $9 -$81 Low-Income Consumer Subgroup $9 $9 $9 -$84 Senior-Only Consumer Subgroup $9 $9 $9 -$78 Gas Self-Cleaning Ovens All Consumers NA NA $3 -$4 Low-Income Consumer Subgroup NA NA -$3 -$10 Senior-Only Consumer Subgroup NA NA -$2 -$10

16-22Table 16.4.2 Mean Life-Cycle Cost Savings for Consumers and Sub-Groups, Microwave Ovens Trial Standard Level 1 2 3 4 All Consumers -$7 -$21 -$40 -$66 Low-Income Consumer S ubgroup -$7 -$20 -$40 -$66 Senior-Only Consumer S ubgroup -$8 -$21 -$40 -$67

16.5 ENVIRONMENTAL JUSTICE IMPACTS According to Executive Order 12898 of February 11, 1994, “Federal Actions to Address Environmental Justice in Minorit y 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 cooking products, (2) manufacturers of niche products related to cooking products, and (3) small businesses operat ed by disadvantaged or minority populations. For conventional cooking products, DOE id entified three manufacturers of gas-fired ovens, stoves, and cooktops with standing pilot lights. Two of the three manufacturers are classified as small businesses by the Small Bu siness Administration. As described in the Manufacturer Impact Analysis, Chapter 13 of th e TSD, though the small manufactures shared many of the concerns as the large manufacturer, the small bus inesses will be much more impacted by a standard that eliminates standing pilots. The two small businesses indicated that 25 percent or more of their enti re production consists of such niche products, now that most manufacturers have switched to el ectronic ignition in their gas- fired cooking appliances. In addition to the elimination of standing pilots, an y rule affecting products manufactured by these small businesses will impact them disproportionately because of their size and their focus on cooking appliances. However, due to the low number of competitors that agreed to be interviewed, DOE could not characterize this industry segment with a separate cash-flow analysis due to concerns about maintaining conf identiality. Therefore, DOE is able to only qualify the potential impacts to small businesses.

16.6 NOISE AND AESTHETICS Improvements in efficiency of cooking products is expected to result from changes in the choice of components and other de sign features. These changes ar e described in Chapter 5 of this TSD. These design changes are not expect ed 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 loude r than less efficient equipment. Changes to the design to improve the efficiency levels ar e not anticipated to a ffect the equipment’s aesthetics.

16-2316.7 SUMMARY OF ENVIRONMENTAL IMPACTS
Table 16.7.1 and Table 16.7.2 summarize antici pated environmental impacts for each of the TSLs across all equipment types. Air qual ity impacts were modeled for each of the TSLs. The summary table shows cumulativ e changes in emissions for CO 2 , NOx, and Hg over the period 2012 to 2042. The resulting changes in emi ssion quantities are very small. Cumulative CO 2 , NO x , and Hg emissions show a decrease compar ed 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 inhow power plants are di spatched, or the timing within the model of when pow er 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 approa ch suggests that upstream fuel cycle emissions would decrease and provides a sense for the ma gnitude of effects, how ever 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 envi ronmental justice; wetlands, endangered and threatened species, and cultural resources; ornoise and aesthetics.

16-24Table 16.7.1 Environmental Impact Analysis Results Summary for Conventional Cooking Products

Environmental Effects Reference Case* Trial Standard Level 1 2 3 4 Cumulative Total Emission Reductions** CO 2 (Million metric tons) 86,206 -13.74 -15.46 -23.39 -34.96 NO X(Thousand tons) 60,796 -6.71 -6.88 -10.82 -16.07 Hg (tons) High Emission Rate Estimate 519 -0.15 -0.19 -0.28 -0.41 Low Emission Rate Estimate 519 0.00 0.00 0.00 0.00 Cumulative Power Sector Emission Reductions** CO 2 (Million metric tons) 86,207 -6.02 -7.74 -11.11 -16.76 NO X (Thousand tons) 60,796 -0.61 -0.78 -1.12 -1.69 Hg (tons) High Emission Rate Estimate 519 -0.15 -0.19 -0.28 -0.41 Low Emission Rate Estimate 519 0.00 0.00 0.00 0.00 Cumulative Household Emission Reductions** CO 2 (Million metric tons)

- -7.72 -7.72 -12.28 -18.20 NO X(Thousand tons)

- -6.10 -6.10 -9.70 -14.38 Fuel-Cycle (Upstream) Emissions NA *** *** *** *** Wetlands, Endangered and Threatened Species, Cultural Resources NA None None None None Socioeconomic Impacts - Mean LCC Savings† Electric Coil Cooktops All Consumers

- NA $4 $4 $4 Low-Income Consumer Subgroup

- NA $4 $4 $4 Senior-Only Consumer Subgroup

- NA $3 $3 $3 Electric Smooth Cooktops All Consumers

- NA NA NA -$238 Low-Income Consumer Subgroup

- NA NA NA -$238 Senior-Only Consumer Subgroup

- NA NA NA -$239 Gas Cooktops All Consumers

- $15 $15 $15 -$8 Low-Income Consumer Subgroup

- $21 $21 $21 -$1 Senior-Only Consumer Subgroup

- $16 $16 $16 -$7 Electric Standard Ovens All Consumers

- NA $11 $11 -$50 Low-Income Consumer Subgroup

- NA $10 $10 -$51 Senior-Only Consumer Subgroup

- NA $7 $7 -$56 Electric Self-Cleaning Ovens All Consumers

- NA NA NA -$143 Low-Income Consumer Subgroup

- NA NA NA -$155 Senior-Only Consumer Subgroup

- NA NA NA -$205 Gas Standard Ovens All Consumers

- $9 $9 $9 -$81 Low-Income Consumer Subgroup

- $9 $9 $9 -$84 Senior-Only Consumer Subgroup

- $9 $9 $9 -$78 Gas Self-Cleaning Ovens All Consumers

- NA NA $3 -$4 Low-Income Consumer Subgroup

- NA NA -$3 -$10 Senior-Only Consumer Subgroup

- NA NA -$2 -$10

16-25Environmental Effects Reference Case* Trial Standard Level 1 2 3 4 Environmental Justice NA †† †† †† †† Noise and Aesthetics NA None None None None * The reference case values reflect total cumulative emissions a nd life cycle cost s in the absence of an energy conservation standard. ** Cumulative total is over a time period from 2012 to 2042. Negative values refer to emission reductions. *** DOE does not report actual estimates of the effects of sta ndards 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. †† DOE identified two small businesses that produce gas cooking products but was not able to quantify potential impacts to thes e businesses.

16-26Table 16.7.2 Environmental Impact Analysis Re sults Summary for Microwave Ovens

Environmental Effects Reference Case* Trial Standard Level 1 2 3 4

CO 2 (Million metric tons) 86,206 -22.88 -33.46 -53.89 -74.67 NO X (Thousand tons) 60,796 -2.55 -3.75 -6.06 -8.42 Hg (tons) High Emission Rate Estimate 519 -0.46 -0.68 -1.10 -1.52 Low Emission Rate Estimate 519 0.00 0.00 0.00 0.00 Fuel-Cycle (Upstream) Emissions NA *** *** *** *** Wetlands, Endangered and Threatened Species, Cultural Resources NA None None None None Socioeconomic Impacts - Mean LCC Savings† All Consumers

- -$7 -$21 -$40 -$66 Low-Income Consumer Subgroup

- -$7 -$20 -$40 -$66 Senior-Only Consumer Subgroup

- -$8 -$21 -$40 -$67 Environmental Justice NA None None None None Noise and Aesthetics NA None None None None * The reference case values reflect total cumulative emissions and life cycle cost s in the absence of an energy conservation standard. ** Cumulative total is over a time peri od from 2012 to 2042. Negative values refer to emission reductions. All emissions from power sector. *** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 16.2.7 provides a sense for the possible magnitude of effects. † Values refer to life-cycle cost savings over the equipment lifetime.

16-27REFERENCES

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 Dishwa shers, Dehumidifiers, Cooking Products, and Commercial Clothes Washers , September, 2008. Washington, DC. < http://www1.eere.energy.gov/buildings/appliance_ standards/residential/home_appl_tsd.html >

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16-2811 Trasande, L., C. Schechter, K.A. Haynes, and P.J. Landrigan, “Applying Cost Analyses to Drive Policy that Pr otects Children,” 1076 ANN. N.Y. ACAD. SCI . 911 (2006).

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