12/2/2010, revised 12/3/2012 and 1/5/2013

DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation

R&D Annual Cost Summary

Development of 4 Model Fireboxes

6-year R&D 

Period

Direct Annual Costs (DAC)

Operator labor $141,667

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates 

of Residential Wood Heating Appliances", spread over 6 years. 

Outside Consultants $26,667

Annual outside consultant cost from Table 3 of the memorandum "Unit 

Cost Estimates of Residential Wood Heating Appliances", spread over 6 

years.

Total Direct Costs (DC) $168,333

Indirect Annual Costs (IAC)

Laboratory Equipment1$9,230

The laboratory equipment cost of $50,000 was amortized over 6 years at 

an interest rate of 3%. 

Re-tooling1$22,152

The re-tooling cost of $120,000 was amortized over 6 years at an interest 

rate of 3%.

Other Capital Costs1, 2 $45,226

Other capital costs include costs for prototypes ($25,000), test fuel 

($30,000+$15,000), testing services ($100,000+$50,000), and marketing 

($25,000) and were amortized over 6 years at an interest rate of 3%. 

Total Indirect Costs (IAC) $76,608

Total Annual Cost $244,941 Annual cost for development of 4 model fireboxes.

Total Annual Cost $61,235 Average annual cost per firebox model.

1

An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's 

estimate that approximately 6 years of R&D are required to bring a product to market .

2 To conservatively estimate the additional cost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based 

on crib only was increased by $15,000 and the testing services estimate of $100,000 based on crib only (which covered not only 

emissions testing but also efficiency and safety testing) was increased by $50,000.
0.31

Note: Fraction that Capital Cost is of 

Total Cost =
Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2013-2018) and through model lifespan (2019-2038)

2013

(Step 1 

compliance) 

2014 2015 2016 2017 2018

(Step 2 

compliance) 

2019

2020 through 

203822013

(Step 1 

compliance) 

2014 2015 2016 2017 2018

(Step 2 

compliance) 

2019

2020 through 

20382

Wood Stoves (R&D)334 125 $213,873 $213,873 $213,873 $213,873 $213,873 $213,873 $0 $0 $7,271,695 $7,271,695 $7,271,695 $7,271,695 $7,271,695 $7,271,695 $0 $0

Pellet Stoves (R&D, R&R)4,8 29 125 $191,793 $191,793 $191,793 $191,793 $191,793 $191,793 $7,031 $7,031 $5,562,000 $5,562,000 $5,562,000 $5,562,000 $5,562,000 $5,562,000 $203,909 $203,909

Pellet Stoves (certification)429 125 $2,586 $2,586 $2,586 $2,586 $2,586 $2,586 $8,621 $8,621 $75,000 $75,000 $75,000 $75,000 $75,000 $75,000 $250,000 $250,000

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $827,346 $827,346 $419,111 $419,111 $419,111 $419,111 $24,208 $24,208 $2,482,038 $2,482,038 $1,257,332 $1,257,332 $1,257,332 $1,257,332 $72,625 $72,625

$15,390,733 $15,390,733 $14,166,026 $14,166,026 $14,166,026 $14,166,026 $526,534 $526,534

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $879,801 $879,801 $442,406 $442,406 $442,406 $442,406 $33,582 $33,582 $6,158,606 $6,158,606 $3,096,839 $3,096,839 $3,096,839 $3,096,839 $235,073 $235,073

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $247,747 $247,747 $247,747 $247,747 $247,747 $247,747 $18,806 $18,806 $7,432,415 $7,432,415 $7,432,415 $7,432,415 $7,432,415 $7,432,415 $564,176 $564,176

$13,591,020 $13,591,020 $10,529,254 $10,529,254 $10,529,254 $10,529,254 $799,249 $799,249

MH - large companies (R&D, R&R, cert.)92 4 $124,940 $124,940 $124,940 $124,940 $124,940 $124,940 $6,469 $6,469 $249,880 $249,880 $249,880 $249,880 $249,880 $249,880 $12,939 $12,939

MH - large companies (R&R, cert.)93 9 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112

MH - large companies (R&R, software cert.)7, 9 1 8 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328

MH - small companies (R&R, software cert.)7, 9 42 85 $3,852 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688

$452,158 $407,008 $407,008 $407,008 $407,008 $407,008 $170,067 $170,067 Period Nationwide Cost of the Rule

R&D year average (2013-

2018) $26,538,638

$29,433,911 $29,388,761 $25,102,289 $25,102,289 $25,102,289 $25,102,289 $1,495,850 $1,495,850 Year 2022 $1,495,850

Cumulative 

(2013 through 2038) $189,148,831

NSPS Subpart Appliance Type

7 For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software 

certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer.

Annual Cost of the Rule

6

 For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 2 so that approximately 100% of the models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in 

this analysis beginning in 2019.

1 Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2013 through 2018). Ongoing certification costs are incurred through 2038 (based on a model brought to market in 2019 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

2

 Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

3

 This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 2 already so that 95% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2020 through 2038 exclude the ongoing certification costs and ongoing reporting and 

recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing NSPS.

4

For pellet stoves, the analysis assumes that 30% meet Step 2 already so that 70% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2013. The analysis reflects the certification 

costs beginning in 2013 for the 30% of models meeting Step 2, and beginning in 2019 for the remaining 70% of models which underwent R&D re-design.

5

Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis conservatively assumes 

that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more stringent 2019 Step 2 standard.

8

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. 

These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496.

9

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater 

manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872.

Average Annual Cost per Manufacturer based on 6-year R&D round (2013-2018) to meet Step 1 and Step 2 limits with 

ongoing certification costs (through 2038)

# Manufacturers # Models

Nationwide Annual Costs1

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters
SCC

Appliance 

Population Total Tons Burned Emission Inventory Category Pollutant

Baseline 

Emission 

factor 

(lb/ton)

Baseline 

Emissions 

(tons)

Baseline 

Tons/appl

2014 

Step 1 

Emission 

Factor

2104008220 1,303,142 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Primary PM2.5 8.76 5,371 0.0041 8.76

2104008230 427,224 416,187 Woodstove: fireplace inserts; EPA certified; catalytic Primary PM2.5 9.72 2,023 0.0047 9.72

2104008320 873,357 1,540,026 Woodstove: freestanding, EPA certified, non-catalytic Primary PM2.5 8.76 6,745 0.0077 8.76

2104008330 374,154 775,602 Woodstove: freestanding, EPA certified, catalytic Primary PM2.5 9.72 3,769 0.0101 9.72

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Primary PM2.5 3.06 1,798 0.0021 3.06

2,206,470 4,668,250 Single Burn Rate Stoves Primary PM2.5 30.6 71,424 0.0324 8.76

2104008610 364,560 3,654,153 Hydronic heater: outdoor Primary PM2.5 27.6 50,427 0.1383 2.76

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Primary PM2.5 27.6 36,213 0.1032 6.9

0.0060 Baseline woodstove weighted average (Tons/appl)
2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 126,527 80,851 77,617 79,169 80,752 82,367 84,015 85,695 87,409

Single Burn Rate 

Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,091 27,633

Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,305 90,072

Furnace: indoor, 

cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,769 28,324

Hydronic Heating 

Systems 13,385 8,553 8,211 8,375 8,543 8,713 8,888 9,065 9,247

2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 761 486 467 476 486 495 505 515 526

Single Burn Rate 

Stoves 1,295 827 794 810 826 843 860 877 895

Pellet Stoves 277 177 170 173 177 180 184 187 191

Furnace: indoor, 

cordwood 4,230 2,703 2,595 2,647 2,699 2,753 2,809 2,865 2,922

Hydronic Heating 

Systems 1,851 1,183 1,136 1,158 1,182 1,205 1,229 1,254 1,279

Total 8,414 5,376 5,161 5,265 5,370 5,477 5,587 5,699 5,812

Table 4. Estimated Annual Shipped Units

Table 5. Estimated PM 2.5 Emissions (Tons) -- Baseline
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$4,813,613 $15,390,733 $3,768,317

2014 4$4,813,613 $15,390,733 $3,768,317 1,549 935 614 $6,141 1,549 935 614

2015 4$4,430,573 $14,166,026 $3,768,317 1,580 954 626 $6,021 3,129 1,889 1,240

2016 4$4,430,573 $14,166,026 $3,768,317 1,611 973 638 $5,902 4,740 2,862 1,878

2017 4$4,430,573 $14,166,026 $3,768,317 1,644 992 651 $5,787 6,384 3,854 2,529

2018 4$4,430,573 $14,166,026 $3,768,317 1,677 1,012 664 $5,673 8,060 4,867 3,193

2019 $0 $526,534 $3,768,317 1,710 374 1,336 $2,822 9,770 5,241 4,529

2020 $0 $526,534 $3,768,317 1,744 382 1,362 $2,766 11,514 5,623 5,891

2021 $0 $526,534 $3,768,317 1,779 390 1,390 $2,712 13,294 6,013 7,281

2022 $0 $526,534 $3,768,317 1,815 397 1,417 $2,659 15,108 6,410 8,698

2023 $0 $526,534 $3,768,317 1,851 405 1,446 $2,607 16,959 6,815 10,144

2024 $0 $526,534 $3,768,317 1,888 413 1,475 $2,556 18,847 7,229 11,618

2025 $0 $526,534 $3,768,317 1,926 422 1,504 $2,505 20,773 7,651 13,122

2026 $0 $526,534 $3,768,317 1,964 430 1,534 $2,456 22,737 8,081 14,657

2027 $0 $526,534 $3,768,317 2,004 439 1,565 $2,408 24,741 8,519 16,221

2028 $0 $526,534 $3,768,317 2,044 448 1,596 $2,361 26,785 8,967 17,818

2029 $0 $526,534 $3,768,317 2,085 456 1,628 $2,315 28,869 9,423 19,446

2030 $0 $526,534 $3,768,317 2,126 466 1,661 $2,269 30,995 9,889 21,106

2031 $0 $526,534 $3,768,317 2,169 475 1,694 $2,225 33,164 10,364 22,800

2032 $0 $526,534 $3,768,317 2,212 484 1,728 $2,181 35,376 10,848 24,528

2033 $0 $526,534 $3,768,317 2,256 494 1,762 $2,138 37,632 11,342 26,290

2034 $0 $526,534 $3,768,317 2,301 504 1,798 $2,096 38,385 10,911 27,474

2035 $0 $526,534 $3,768,317 2,348 514 1,833 $2,055 39,153 10,471 28,681

2036 $0 $526,534 $3,768,317 2,394 524 1,870 $2,015 39,936 10,023 29,913

2037 $0 $526,534 $3,768,317 2,442 535 1,908 $1,975 40,735 9,565 31,169

2038 $0 $526,534 $3,768,317 2,491 546 1,946 $1,937 41,549 9,098 32,451

2039 39,839 8,724 31,115

2040 38,095 8,342 29,753

2041 36,316 7,952 28,364

2042 34,501 7,555 26,946

2043 32,650 7,150 25,501

2044 30,762 6,736 24,026

2045 28,836 6,315 22,522

2046 26,872 5,884 20,988

2047 24,869 5,446 19,423

2048 22,825 4,998 17,827

2049 20,740 4,542 16,199

2050 18,614 4,076 14,538

2051 16,445 3,601 12,844

2052 14,233 3,117 11,117

2053 11,977 2,623 9,354

2054 9,675 2,119 7,557

2055 7,328 1,605 5,723

2056 4,934 1,080 3,853

2057 2,491 546 1,946

$97,976,255 362,045 $271

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves and pellet stoves, estimates conservatively assume that most models already 

meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 2014 through 2018. Therefore no emission reductions are estimated to result from 

woodstoves and pellet stoves until Step 2 in 2019.

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis 

because it is prior to the rule compliance date.

Cumulative Emission Reduction 

over 20-year stove lifespan 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,274,299 $7,271,695 $1,678,083

2014 4

$2,274,299 $7,271,695 $1,678,083 505 505 0 N/A 505 505 0

2015 4

$2,274,299 $7,271,695 $1,678,083 515 515 0 N/A 1,021 1,021 0

2016 4

$2,274,299 $7,271,695 $1,678,083 526 526 0 N/A 1,546 1,546 0

2017 4

$2,274,299 $7,271,695 $1,678,083 536 536 0 N/A 2,082 2,082 0

2018 4

$2,274,299 $7,271,695 $1,678,083 547 547 0 N/A 2,629 2,629 0

2019 $0 $0 $1,678,083 558 202 356 $4,713 3,187 2,831 356

2020 $0 $0 $1,678,083 569 206 363 $4,620 3,756 3,037 719

2021 $0 $0 $1,678,083 580 210 370 $4,530 4,336 3,247 1,090

2022 $0 $0 $1,678,083 592 214 378 $4,441 4,928 3,461 1,468

2023 $0 $0 $1,678,083 604 218 385 $4,354 5,532 3,679 1,853

2024 $0 $0 $1,678,083 616 223 393 $4,269 6,148 3,902 2,246

2025 $0 $0 $1,678,083 628 227 401 $4,185 6,776 4,129 2,647

2026 $0 $0 $1,678,083 641 232 409 $4,103 7,417 4,361 3,056

2027 $0 $0 $1,678,083 654 236 417 $4,022 8,071 4,597 3,473

2028 $0 $0 $1,678,083 667 241 426 $3,943 8,737 4,838 3,899

2029 $0 $0 $1,678,083 680 246 434 $3,866 9,417 5,084 4,333

2030 $0 $0 $1,678,083 694 251 443 $3,790 10,111 5,335 4,776

2031 $0 $0 $1,678,083 707 256 452 $3,716 10,818 5,591 5,227

2032 $0 $0 $1,678,083 722 261 461 $3,643 11,540 5,852 5,688

2033 $0 $0 $1,678,083 736 266 470 $3,572 12,276 6,118 6,158

2034 $0 $0 $1,678,083 751 272 479 $3,502 12,522 5,885 6,637

2035 $0 $0 $1,678,083 766 277 489 $3,433 12,772 5,646 7,126

2036 $0 $0 $1,678,083 781 283 499 $3,366 13,027 5,403 7,624

2037 $0 $0 $1,678,083 797 288 509 $3,300 13,288 5,155 8,133

2038 $0 $0 $1,678,083 813 294 519 $3,235 13,554 4,902 8,652

2039 12,996 4,700 8,295

2040 12,427 4,495 7,932

2041 11,847 4,285 7,562

2042 11,255 4,071 7,184

2043 10,651 3,852 6,799

2044 10,035 3,629 6,405

2045 9,407 3,402 6,004

2046 8,766 3,170 5,595

2047 8,112 2,934 5,178

2048 7,446 2,693 4,753

2049 6,766 2,447 4,319

2050 6,072 2,196 3,876

2051 5,365 1,940 3,424

2052 4,643 1,679 2,964

2053 3,907 1,413 2,494

2054 3,156 1,142 2,015

2055 2,390 865 1,526

2056 1,609 582 1,027

2057 813 294 519

$43,630,168 96,523 $452

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis 

because it is prior to the rule compliance date.

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves, estimates conservatively assume that most models already meet the Step 1 limit 

and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year stove lifespan 5 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction (tons)

2013 3

$1,763,031 $5,637,000 $1,650,007

2014 4

$1,763,031 $5,637,000 $1,650,007 184 184 0 N/A 184 184 0

2015 4

$1,763,031 $5,637,000 $1,650,007 187 187 0 N/A 371 371 0

2016 4

$1,763,031 $5,637,000 $1,650,007 191 191 0 N/A 563 563 0

2017 4

$1,763,031 $5,637,000 $1,650,007 195 195 0 N/A 758 758 0

2018 4

$1,763,031 $5,637,000 $1,650,007 199 199 0 N/A 957 957 0

2019 $0 $453,909 $1,650,007 203 95 108 $15,282 1,160 1,052 108

2020 $0 $453,909 $1,650,007 207 97 110 $14,982 1,367 1,148 218

2021 $0 $453,909 $1,650,007 211 99 112 $14,689 1,578 1,247 330

2022 $0 $453,909 $1,650,007 215 101 115 $14,401 1,793 1,348 445

2023 $0 $453,909 $1,650,007 220 103 117 $14,118 2,013 1,451 562

2024 $0 $453,909 $1,650,007 224 105 119 $13,841 2,237 1,556 681

2025 $0 $453,909 $1,650,007 229 107 122 $13,570 2,465 1,663 803

2026 $0 $453,909 $1,650,007 233 109 124 $13,304 2,699 1,772 927

2027 $0 $453,909 $1,650,007 238 111 127 $13,043 2,936 1,883 1,053

2028 $0 $453,909 $1,650,007 243 114 129 $12,787 3,179 1,997 1,182

2029 $0 $453,909 $1,650,007 247 116 132 $12,537 3,426 2,112 1,314

2030 $0 $453,909 $1,650,007 252 118 134 $12,291 3,679 2,231 1,448

2031 $0 $453,909 $1,650,007 257 120 137 $12,050 3,936 2,351 1,585

2032 $0 $453,909 $1,650,007 263 123 140 $11,813 4,199 2,474 1,725

2033 $0 $453,909 $1,650,007 268 125 142 $11,582 4,466 2,599 1,867

2034 $0 $453,909 $1,650,007 273 128 145 $11,355 4,556 2,543 2,012

2035 $0 $453,909 $1,650,007 279 130 148 $11,132 4,647 2,486 2,161

2036 $0 $453,909 $1,650,007 284 133 151 $10,914 4,740 2,428 2,312

2037 $0 $453,909 $1,650,007 290 136 154 $10,700 4,835 2,368 2,466

2038 $0 $453,909 $1,650,007 296 138 157 $10,490 4,931 2,308 2,623

2039 4,728 2,213 2,515

2040 4,521 2,116 2,405

2041 4,310 2,017 2,293

2042 4,095 1,916 2,178

2043 3,875 1,814 2,062

2044 3,651 1,709 1,942

2045 3,422 1,602 1,821

2046 3,189 1,493 1,697

2047 2,951 1,381 1,570

2048 2,709 1,268 1,441

2049 2,462 1,152 1,310

2050 2,209 1,034 1,175

2051 1,952 913 1,038

2052 1,689 791 899

2053 1,421 665 756

2054 1,148 537 611

2055 870 407 463

2056 586 274 312

2057 296 138 157

$42,900,174 29,269 $1,466

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For pellet stoves, estimates conservatively assume that most models already meet the Step 1 limit 

and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because 

it is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction (tons)

2013 3$776,284 $2,482,038 $440,227

2014 4$776,284 $2,482,038 $440,227 860 246 614 $717 860 246 614

2015 $393,244 $1,257,332 $440,227 877 251 626 $703 1,737 497 1,240

2016 $393,244 $1,257,332 $440,227 895 256 638 $690 2,631 753 1,878

2017 $393,244 $1,257,332 $440,227 912 261 651 $676 3,544 1,014 2,529

2018 $393,244 $1,257,332 $440,227 931 266 664 $663 4,474 1,281 3,193

2019 4$0 $72,625 $440,227 949 78 872 $505 5,424 1,359 4,065

2020 $0 $72,625 $440,227 968 79 889 $495 6,392 1,438 4,954

2021 $0 $72,625 $440,227 988 81 907 $486 7,379 1,519 5,861

2022 $0 $72,625 $440,227 1,007 82 925 $476 8,387 1,601 6,786

2023 $0 $72,625 $440,227 1,027 84 943 $467 9,414 1,685 7,729

2024 $0 $72,625 $440,227 1,048 86 962 $458 10,462 1,771 8,691

2025 $0 $72,625 $440,227 1,069 88 981 $449 11,531 1,859 9,673

2026 $0 $72,625 $440,227 1,090 89 1,001 $440 12,622 1,948 10,674

2027 $0 $72,625 $440,227 1,112 91 1,021 $431 13,734 2,039 11,695

2028 $0 $72,625 $440,227 1,134 93 1,042 $423 14,868 2,132 12,736

2029 $0 $72,625 $440,227 1,157 95 1,062 $414 16,025 2,227 13,799

2030 $0 $72,625 $440,227 1,180 97 1,084 $406 17,206 2,323 14,882

2031 $0 $72,625 $440,227 1,204 99 1,105 $398 18,410 2,422 15,988

2032 $0 $72,625 $440,227 1,228 101 1,127 $390 19,638 2,522 17,115

2033 $0 $72,625 $440,227 1,253 103 1,150 $383 20,890 2,625 18,265

2034 $0 $72,625 $440,227 1,278 105 1,173 $375 21,308 2,483 18,824

2035 $0 $72,625 $440,227 1,303 107 1,196 $368 21,734 2,339 19,395

2036 $0 $72,625 $440,227 1,329 109 1,220 $361 22,169 2,192 19,977

2037 $0 $72,625 $440,227 1,356 111 1,245 $354 22,612 2,042 20,570

2038 $0 $72,625 $440,227 1,383 113 1,270 $347 23,064 1,888 21,176

2039 22,115 1,811 20,304

2040 21,147 1,731 19,415

2041 20,159 1,651 18,509

2042 19,152 1,568 17,584

2043 18,124 1,484 16,640

2044 17,076 1,398 15,678

2045 16,007 1,311 14,697

2046 14,917 1,221 13,696

2047 13,805 1,130 12,674

2048 12,670 1,037 11,633

2049 11,513 943 10,571

2050 10,333 846 9,487

2051 9,129 747 8,382

2052 7,901 647 7,254

2053 6,649 544 6,104

2054 5,371 440 4,931

2055 4,068 333 3,735

2056 2,739 224 2,514

2057 1,383 113 1,270

$11,445,912 236,254 $48

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to 

bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

CE based on total cost 

& cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP predicted 

by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it 

is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$4,250,734 $13,591,020 $3,280,155

2014 4

$4,250,734 $13,591,020 $3,280,155 4,038 825 3,213 $1,021 4,038 825 3,213

2015 $3,293,135 $10,529,254 $3,280,155 4,119 842 3,277 $1,001 8,157 1,667 6,490

2016 $3,293,135 $10,529,254 $3,280,155 4,201 858 3,343 $981 12,358 2,525 9,833

2017 $3,293,135 $10,529,254 $3,280,155 4,285 876 3,410 $962 16,643 3,401 13,242

2018 $3,293,135 $10,529,254 $3,280,155 4,371 893 3,478 $943 21,014 4,294 16,720

2019 4

$0 $799,249 $3,280,155 4,458 89 4,369 $751 25,472 4,383 21,089

2020 $0 $799,249 $3,280,155 4,547 91 4,456 $736 30,019 4,474 25,545

2021 $0 $799,249 $3,280,155 4,638 93 4,546 $722 34,658 4,567 30,091

2022 $0 $799,249 $3,280,155 4,731 95 4,636 $707 39,389 4,661 34,727

2023 $0 $799,249 $3,280,155 4,826 97 4,729 $694 44,214 4,758 39,457

2024 $0 $799,249 $3,280,155 4,922 98 4,824 $680 49,137 4,856 44,280

2025 $0 $799,249 $3,280,155 5,021 100 4,920 $667 54,157 4,957 49,201

2026 $0 $799,249 $3,280,155 5,121 102 5,019 $654 59,278 5,059 54,219

2027 $0 $799,249 $3,280,155 5,224 104 5,119 $641 64,502 5,164 59,338

2028 $0 $799,249 $3,280,155 5,328 107 5,221 $628 69,830 5,270 64,560

2029 $0 $799,249 $3,280,155 5,435 109 5,326 $616 75,264 5,379 69,886

2030 $0 $799,249 $3,280,155 5,543 111 5,432 $604 80,808 5,490 75,318

2031 $0 $799,249 $3,280,155 5,654 113 5,541 $592 86,462 5,603 80,859

2032 $0 $799,249 $3,280,155 5,767 115 5,652 $580 92,229 5,718 86,511

2033 $0 $799,249 $3,280,155 5,883 118 5,765 $569 98,111 5,836 92,276

2034 $0 $799,249 $3,280,155 6,000 120 5,880 $558 100,074 5,131 94,943

2035 $0 $799,249 $3,280,155 6,120 122 5,998 $547 102,075 4,411 97,664

2036 $0 $799,249 $3,280,155 6,243 125 6,118 $536 104,117 3,678 100,439

2037 $0 $799,249 $3,280,155 6,367 127 6,240 $526 106,199 2,930 103,269

2038 $0 $799,249 $3,280,155 6,495 130 6,365 $515 108,323 2,166 106,156

2039 103,865 2,077 101,787

2040 99,317 1,986 97,331

2041 94,679 1,894 92,785

2042 89,948 1,799 88,149

2043 85,122 1,702 83,420

2044 80,200 1,604 78,596

2045 75,179 1,504 73,676

2046 70,058 1,401 68,657

2047 64,835 1,297 63,538

2048 59,507 1,190 58,317

2049 54,072 1,081 52,991

2050 48,529 971 47,558

2051 42,875 857 42,017

2052 37,108 742 36,365

2053 31,225 625 30,601

2054 25,225 504 24,720

2055 19,105 382 18,723

2056 12,862 257 12,605

2057 6,495 130 6,365

Nationwide cumulative cost $85,284,037 1,184,357 $72 5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis 

because it is prior to the rule compliance date.

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. 

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

Year lifespan (per ton)

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$1,926,169 $6,158,606 $1,131,001

2014 4

$1,926,169 $6,158,606 $1,131,001 2,809 702 2,106 $537 2,809 702 2,106

2015 $968,569 $3,096,839 $1,131,001 2,865 716 2,149 $526 5,673 1,418 4,255

2016 $968,569 $3,096,839 $1,131,001 2,922 731 2,192 $516 8,595 2,149 6,446

2017 $968,569 $3,096,839 $1,131,001 2,980 745 2,235 $506 11,576 2,894 8,682

2018 $968,569 $3,096,839 $1,131,001 3,040 760 2,280 $496 14,616 3,654 10,962

2019 4

$0 $235,073 $1,131,001 3,101 62 3,039 $372 17,717 3,716 14,001

2020 $0 $235,073 $1,131,001 3,163 63 3,100 $365 20,880 3,779 17,100

2021 $0 $235,073 $1,131,001 3,226 65 3,162 $358 24,106 3,844 20,262

2022 $0 $235,073 $1,131,001 3,291 66 3,225 $351 27,396 3,910 23,487

2023 $0 $235,073 $1,131,001 3,356 67 3,289 $344 30,753 3,977 26,776

2024 $0 $235,073 $1,131,001 3,424 68 3,355 $337 34,177 4,045 30,131

2025 $0 $235,073 $1,131,001 3,492 70 3,422 $330 37,669 4,115 33,554

2026 $0 $235,073 $1,131,001 3,562 71 3,491 $324 41,231 4,186 37,044

2027 $0 $235,073 $1,131,001 3,633 73 3,561 $318 44,864 4,259 40,605

2028 $0 $235,073 $1,131,001 3,706 74 3,632 $311 48,570 4,333 44,236

2029 $0 $235,073 $1,131,001 3,780 76 3,704 $305 52,349 4,409 47,941

2030 $0 $235,073 $1,131,001 3,856 77 3,778 $299 56,205 4,486 51,719

2031 $0 $235,073 $1,131,001 3,933 79 3,854 $293 60,138 4,564 55,573

2032 $0 $235,073 $1,131,001 4,011 80 3,931 $288 64,149 4,645 59,504

2033 $0 $235,073 $1,131,001 4,092 82 4,010 $282 68,241 4,726 63,514

2034 $0 $235,073 $1,131,001 4,173 83 4,090 $277 69,605 4,108 65,498

2035 $0 $235,073 $1,131,001 4,257 85 4,172 $271 70,997 3,477 67,521

2036 $0 $235,073 $1,131,001 4,342 87 4,255 $266 72,417 2,833 69,584

2037 $0 $235,073 $1,131,001 4,429 89 4,340 $261 73,866 2,177 71,689

2038 $0 $235,073 $1,131,001 4,517 90 4,427 $255 75,343 1,507 73,836

2039 72,242 1,445 70,797

2040 69,079 1,382 67,698

2041 65,853 1,317 64,536

2042 62,562 1,251 61,311

2043 59,206 1,184 58,022

2044 55,782 1,116 54,667

2045 52,290 1,046 51,244

2046 48,728 975 47,754

2047 45,095 902 44,193

2048 41,389 828 40,562

2049 37,609 752 36,857

2050 33,754 675 33,079

2051 29,821 596 29,225

2052 25,810 516 25,294

2053 21,718 434 21,284

2054 17,545 351 17,194

2055 13,288 266 13,022

2056 8,946 179 8,767

2057 4,517 90 4,427

$29,406,034 823,770 $36

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

CE based on total cost 

& cumulative emission 

reduction over 20-year 

stove lifespan (per 

ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it 

is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,324,566 $7,432,415 $2,149,154

2014 4

$2,324,566 $7,432,415 $2,149,154 1,229 123 1,106 $1,942 1,229 123 1,106

2015 $2,324,566 $7,432,415 $2,149,154 1,254 125 1,129 $1,904 2,483 248 2,235

2016 $2,324,566 $7,432,415 $2,149,154 1,279 128 1,151 $1,867 3,762 376 3,386

2017 $2,324,566 $7,432,415 $2,149,154 1,305 130 1,174 $1,830 5,067 507 4,560

2018 $2,324,566 $7,432,415 $2,149,154 1,331 133 1,198 $1,794 6,398 640 5,758

2019 4

$0 $564,176 $2,149,154 1,357 27 1,330 $1,616 7,755 667 7,088

2020 $0 $564,176 $2,149,154 1,384 28 1,357 $1,584 9,140 695 8,445

2021 $0 $564,176 $2,149,154 1,412 28 1,384 $1,553 10,552 723 9,829

2022 $0 $564,176 $2,149,154 1,440 29 1,412 $1,522 11,992 752 11,241

2023 $0 $564,176 $2,149,154 1,469 29 1,440 $1,493 13,461 781 12,680

2024 $0 $564,176 $2,149,154 1,499 30 1,469 $1,463 14,960 811 14,149

2025 $0 $564,176 $2,149,154 1,529 31 1,498 $1,435 16,489 842 15,647

2026 $0 $564,176 $2,149,154 1,559 31 1,528 $1,407 18,048 873 17,175

2027 $0 $564,176 $2,149,154 1,590 32 1,559 $1,379 19,638 905 18,734

2028 $0 $564,176 $2,149,154 1,622 32 1,590 $1,352 21,260 937 20,323

2029 $0 $564,176 $2,149,154 1,655 33 1,621 $1,325 22,915 970 21,945

2030 $0 $564,176 $2,149,154 1,688 34 1,654 $1,299 24,603 1,004 23,599

2031 $0 $564,176 $2,149,154 1,721 34 1,687 $1,274 26,324 1,038 25,286

2032 $0 $564,176 $2,149,154 1,756 35 1,721 $1,249 28,080 1,073 27,006

2033 $0 $564,176 $2,149,154 1,791 36 1,755 $1,224 29,871 1,109 28,762

2034 $0 $564,176 $2,149,154 1,827 37 1,790 $1,200 30,468 1,023 29,445

2035 $0 $564,176 $2,149,154 1,863 37 1,826 $1,177 31,078 935 30,143

2036 $0 $564,176 $2,149,154 1,901 38 1,863 $1,154 31,699 845 30,854

2037 $0 $564,176 $2,149,154 1,939 39 1,900 $1,131 32,333 753 31,580

2038 $0 $564,176 $2,149,154 1,977 40 1,938 $1,109 32,980 660 32,320

2039 31,622 632 30,990

2040 30,238 605 29,633

2041 28,826 577 28,249

2042 27,385 548 26,838

2043 25,916 518 25,398

2044 24,418 488 23,929

2045 22,889 458 22,431

2046 21,330 427 20,903

2047 19,739 395 19,345

2048 18,117 362 17,755

2049 16,463 329 16,133

2050 14,775 296 14,480

2051 13,054 261 12,793

2052 11,298 226 11,072

2053 9,507 190 9,317

2054 7,680 154 7,526

2055 5,817 116 5,700

2056 3,916 78 3,838

2057 1,977 40 1,938

$55,878,003 360,587 $155

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 in 2019. 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis 

because it is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3$9,064,348 $28,981,753 $7,048,473

2014 4$9,064,348 $28,981,753 $7,048,473 5,587 1,760 3,827 $1,842 5,587 1,760 3,827

2015 $7,723,708 $24,695,280 $7,048,473 5,699 1,795 3,903 $1,806 11,285 3,556 7,730

2016 $7,723,708 $24,695,280 $7,048,473 5,812 1,831 3,981 $1,770 17,098 5,387 11,711

2017 $7,723,708 $24,695,280 $7,048,473 5,929 1,868 4,061 $1,736 23,026 7,255 15,771

2018 $7,723,708 $24,695,280 $7,048,473 6,047 1,905 4,142 $1,702 29,074 9,161 19,913

2019 4$0 $1,325,783 $7,048,473 6,168 464 5,705 $1,236 35,242 9,624 25,618

2020 $0 $1,325,783 $7,048,473 6,292 473 5,819 $1,211 41,534 10,097 31,437

2021 $0 $1,325,783 $7,048,473 6,417 482 5,935 $1,188 47,951 10,579 37,372

2022 $0 $1,325,783 $7,048,473 6,546 492 6,054 $1,164 54,497 11,071 43,425

2023 $0 $1,325,783 $7,048,473 6,677 502 6,175 $1,141 61,174 11,573 49,600

2024 $0 $1,325,783 $7,048,473 6,810 512 6,298 $1,119 67,984 12,085 55,899

2025 $0 $1,325,783 $7,048,473 6,946 522 6,424 $1,097 74,930 12,607 62,323

2026 $0 $1,325,783 $7,048,473 7,085 533 6,553 $1,076 82,016 13,140 68,876

2027 $0 $1,325,783 $7,048,473 7,227 543 6,684 $1,055 89,243 13,683 75,560

2028 $0 $1,325,783 $7,048,473 7,372 554 6,818 $1,034 96,614 14,237 82,377

2029 $0 $1,325,783 $7,048,473 7,519 565 6,954 $1,014 104,133 14,802 89,331

2030 $0 $1,325,783 $7,048,473 7,669 576 7,093 $994 111,803 15,379 96,424

2031 $0 $1,325,783 $7,048,473 7,823 588 7,235 $974 119,626 15,967 103,659

2032 $0 $1,325,783 $7,048,473 7,979 600 7,380 $955 127,605 16,566 111,039

2033 $0 $1,325,783 $7,048,473 8,139 612 7,527 $936 135,744 17,178 118,566

2034 $0 $1,325,783 $7,048,473 8,302 624 7,678 $918 138,459 16,042 122,417

2035 $0 $1,325,783 $7,048,473 8,468 636 7,831 $900 141,228 14,883 126,345

2036 $0 $1,325,783 $7,048,473 8,637 649 7,988 $882 144,052 13,701 130,352

2037 $0 $1,325,783 $7,048,473 8,810 662 8,148 $865 146,933 12,495 134,439

2038 $0 $1,325,783 $7,048,473 8,986 675 8,311 $848 149,872 11,265 138,607

2039 143,704 10,801 132,903

2040 137,412 10,328 127,084

2041 130,995 9,846 121,149

2042 124,449 9,354 115,095

2043 117,772 8,852 108,920

2044 110,962 8,340 102,622

2045 104,016 7,818 96,198

2046 96,930 7,286 89,645

2047 89,703 6,742 82,961

2048 82,332 6,188 76,143

2049 74,812 5,623 69,189

2050 67,143 5,047 62,096

2051 59,320 4,459 54,862

2052 51,341 3,859 47,482

2053 43,202 3,247 39,955

2054 34,900 2,623 32,277

2055 26,433 1,987 24,446

2056 17,796 1,338 16,458

2057 8,986 675 8,311

$183,260,291 1,546,402 $119

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots

1

 Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2013-2018 ), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2038). Years 2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis 

because it is prior to the rule compliance date.

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. No emission reductions are estimated to result from woodstoves and pellet stoves until 2019, 

although emission reductions are estimated for all other devices starting in 2014 .

DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, Pellet 

Stoves, and Single Burn Rate Stoves)

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan