# 12/2/2010, revised 12/3/2012, 1/5/2013 and 2/4/2013

**DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation**
**R&D Annual Cost Summary Development of 4 Model Fireboxes**  **Round One 6-year R&D**  **Period Direct Annual Costs (DAC)** 

Operator labor $141,667

Outside Consultants $26,667
**Total Direct Costs (DC)** $168,333
**Indirect Annual Costs (IAC)**

Laboratory Equipment1, 2 

# $10,490
Re-tooling1 

# $25,175

Other Capital Costs1, 3 

# $51,400
**Total Indirect Costs (IAC)** $87,065 **Round One Total Annual Cost**  $255,399 **Total Annual Cost** $63,850

0.34 Note: Fraction that Capital Cost is of Total Cost = 3

# 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. 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

# It is assumed that the same lab equipment can be used for round two R&D, so the round two costs exclude the lab equipment cost.

# DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation

**Round Two 6- year R&D**  **Period**

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $141,667 Annual outside consultant cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $26,667
$168,333

The laboratory equipment cost of $50,000 was amortized over 6 years at an interest rate of 7%. $0 The re-tooling cost of $120,000 was amortized over 6 years at an interest rate of 7%. $25,175
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 7%. $51,400
$76,575 **Round Two 2**  

# Annual cost for development of 4 model fireboxes. $244,909 Average annual cost per firebox model. $61,227

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 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 .

It is assumed that the same lab equipment can be used for round two R&D, so the round two costs exclude the lab equipment cost.

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

2013 Wood Stoves (R&D)3 

# 34 125 $223,004 Pellet Stoves (R&D, R&R)4, 8 

# 29 125 $199,681 Pellet Stoves (certification)4 

# 29 125 $2,586 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 

# 3 20 $862,204

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 

# 7 50 $917,148 Hydronic Heating Systems (R&D, R&R, cert.)6, 8 

# 30 120 $258,204

MH - large companies (R&D, R&R, cert.)9 

# 2 4 $130,169 MH - large companies (R&R, cert.)9 

# 3 9 $9,704 MH - large companies (R&R, software cert.)7, 9 

# 1 8 $11,378 MH - small companies (R&R, software cert.)7, 9 

# 42 85 $3,852

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. Appliance Type

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. 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 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. 1

# Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 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 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs 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 conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013.

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 2017 Step 2 and 2022 Step 3 standards.

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.# Manufacturers # ModelsAverage Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing

QQQQ: Central Heaters

RRRR: Masonry Heaters AAA: Room Heaters NSPS Subpart

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

(Step 1 compliance) 2014 2015 2016 (Step 2 compliance) 2017 2018 2019 2020 $223,004 $223,004 $223,004 $394,080 $394,080 $171,076 $171,076 $199,681 $199,681 $199,681 $347,471 $347,471 $154,821 $154,821 $2,586 $2,586 $2,586 $2,586 $2,586 $3,793 $3,793 $862,204 $436,539 $436,539 $763,085 $763,085 $340,087 $340,087
$917,148 $461,079 $461,079 $810,949 $810,949 $360,594 $360,594 $258,204 $258,204 $258,204 $454,131 $454,131 $201,933 $201,933
$130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802

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. 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. For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS. 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. This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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 2017 Step 2 and 2022 Step 3 standards.

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 initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing certification costs (through 2041)

# 2021 (Step 3 compliance) 2022 2023

through 20412 

# 2013 2014 2015 2016 2017 $171,076 $171,076 $0 7,582,146 7,582,146 7,582,146 7,582,14613,398,730 $154,821 $154,821 $7,031 5,790,753 5,790,753 5,790,753 5,790,75310,076,657 $3,793 $3,793 $8,621 75,000 75,000 75,000 75,000 75,000 $340,087 $340,087$24,208 2,586,611 2,586,611 1,309,618 1,309,618 2,289,254 16,034,51016,034,51014,757,51714,757,51725,839,640 $360,594 $360,594$33,582 6,420,038 6,420,038 3,227,556 3,227,556 5,676,644 $201,933 $201,933$18,806 7,746,133 7,746,133 7,746,133 7,746,13313,623,945 $14,166,171$14,166,171$10,973,689$10,973,689$19,300,588 $6,469 $6,469 $6,469 $260,337 $260,337 $260,337 $260,337 $260,337 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328$10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $462,616 $417,466 $417,466 $417,466 $417,466
$30,663,297$30,618,147$26,148,672$26,148,672$45,557,694

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
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 For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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

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 initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing Nationwide Annual Costs

# 2018 2019 2020 2021 2022 2023 through 20412 

# 13,398,730 5,816,584 5,816,584 5,816,584 5,816,584 $0 10,076,657 4,489,813 4,489,813 4,489,813 4,489,813 $203,909 75,000 110,000 110,000 110,000 110,000 $250,000 2,289,254 1,020,261 1,020,261 1,020,261 1,020,261 $72,625 25,839,64011,436,65711,436,65711,436,65711,436,657 $526,534 5,676,644 2,524,161 2,524,161 2,524,161 2,524,161 $235,073 13,623,945 6,057,987 6,057,987 6,057,987 6,057,987 $564,176 $19,300,588$8,582,148$8,582,148$8,582,148$8,582,148 $799,249 $260,337 $12,939 $12,939 $12,939 $12,939 $12,939 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $417,466 $170,067 $170,067 $170,067 $170,067 $170,067
$45,557,694$20,188,873$20,188,873$20,188,873$20,188,873$1,495,850

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 Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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 Nationwide Annual Costs1

# Period Nationwide Cost of the Rule Year 2022 $20,188,873 Year 2023 & following $1,495,850

Cumulative (2013 through 2033) $313,870,820

# SCC **Appliance Population**  **Total Tons Burned Emission Inventory Category**  **Pollutant Baseline**  **Emission factor**  **(lb/ton) Baseline** 

**Emissions (tons)**  **Baseline**

**Tons/appl Step 1** 

**Emission Factor**  2104008220 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Primary PM2.5 8.76 5,371 0.0041 8.76 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Primary PM2.5 9.72 2,023 0.0047 9.72 2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Primary PM2.5 8.76 6,745 0.0077 8.76 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Primary PM2.5 9.72 3,769 0.0101 9.72 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Primary PM2.5 3.06 1,798 0.0021 3.06 2,206,470 4,668,250Single Burn Rate Stoves Primary PM2.5 30.6 71,424 0.0324 8.76 2104008610 364,560 3,654,153Hydronic heater: outdoor Primary PM2.5 27.6 50,427 0.1383 2.76 2104008510 351,023 2,624,115Furnace: indoor, cordwood Primary PM2.5 27.6 36,213 0.1032 6.9 0.0060Baseline 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) 20133 $5,466,157$16,034,510 $5,828,073 20144 $5,466,157$16,034,510 $5,828,073 1,549 935 614 $9,498 1,549 935 614 20154 $5,030,830$14,757,517 $5,828,073 1,580 954 626 $9,311 3,129 1,889 1,240 20164 $5,030,830$14,757,517 $5,828,073 1,611 973 638 $9,129 4,740 2,862 1,878 2017 $8,808,721$25,839,640 $5,828,073 1,644 692 951 $6,125 6,384 3,554 2,829 2018 $8,808,721$25,839,640 $5,828,073 1,677 706 971 $6,005 8,060 4,260 3,800 2019 $3,898,751$11,436,657 $5,828,073 1,710 720 990 $5,887 9,770 4,980 4,790 2020 $3,898,751$11,436,657 $5,828,073 1,744 735 1,010 $5,772 11,514 5,715 5,800 2021 $3,898,751$11,436,657 $5,828,073 1,779 749 1,030 $5,659 13,294 6,464 6,830 2022 $3,898,751$11,436,657 $5,828,073 1,815 397 1,417 $4,112 15,108 6,861 8,247 2023 $0 $526,534 $5,828,073 1,851 405 1,446 $4,031 16,959 7,267 9,692 2024 $0 $526,534 $5,828,073 1,888 413 1,475 $3,952 18,847 7,680 11,167 2025 $0 $526,534 $5,828,073 1,926 422 1,504 $3,875 20,773 8,102 12,671 2026 $0 $526,534 $5,828,073 1,964 430 1,534 $3,799 22,737 8,532 14,205 2027 $0 $526,534 $5,828,073 2,004 439 1,565 $3,724 24,741 8,971 15,770 2028 $0 $526,534 $5,828,073 2,044 448 1,596 $3,651 26,785 9,418 17,366 2029 $0 $526,534 $5,828,073 2,085 456 1,628 $3,580 28,869 9,875 18,994 2030 $0 $526,534 $5,828,073 2,126 466 1,661 $3,510 30,995 10,340 20,655 2031 $0 $526,534 $5,828,073 2,169 475 1,694 $3,441 33,164 10,815 22,349 2032 $0 $526,534 $5,828,073 2,212 484 1,728 $3,373 35,376 11,300 24,076 2033 $0 $526,534 $5,828,073 2,256 494 1,762 $3,307 37,632 11,794 25,839 2034 $0 $526,534 $5,828,073 2,301 504 1,798 $3,242 38,385 11,362 27,023 2035 $0 $526,534 $5,828,073 2,348 514 1,833 $3,179 39,153 10,923 28,230 2036 $0 $526,534 $5,828,073 2,394 524 1,870 $3,116 39,936 10,474 29,462 2037 $0 $526,534 $5,828,073 2,442 535 1,908 $3,055 40,735 10,317 30,418 2038 $0 $526,534 $5,828,073 2,491 546 1,946 $2,995 41,549 10,156 31,393 2039 $0 $526,534 $5,828,073 2,541 556 1,985 $2,937 42,380 9,992 32,388 2040 $0 $526,534 $5,828,073 2,592 568 2,024 $2,879 43,228 9,826 33,402 2041 $0 $526,534 $5,828,073 2,644 579 2,065 $2,823 44,092 9,655 34,437 2042 42,278 9,258 33,020 2043 40,427 8,853 31,574 2044 38,539 8,439 30,100 2045 36,613 8,017 28,596 2046 34,649 7,587 27,061 2047 32,645 7,149 25,497 2048 30,601 6,701 23,900 2049 28,517 6,245 22,272 2050 26,391 5,779 20,612 2051 24,222 5,304 18,918 2052 22,010 4,820 17,190 2053 19,753 4,326 15,428 2054 17,452 3,822 13,630 2055 15,105 3,308 11,797 2056 12,710 2,783 9,927 2057 10,268 2,248 8,019 2058 7,777 1,703 6,074 2059 5,236 1,146 4,089 2060 2,644 579 2,065

$169,014,114 384,206 $440 **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)**

Nationwide cumulative cost5

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDPpredicted 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).

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves and pellet stoves, estimates conservatively assume that most models meet Step 1 and that manufacturers will certify and sell existing models meeting Step 1 from 2014 through 2016. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2017. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

32013 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 Emission Reduction, cumulative per year Annual SnapshotsBaseline 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) 20133 $2,584,750$7,582,146 $2,772,151 20144 $2,584,750$7,582,146 $2,772,151 505 505 0 N/A 505 505 0 20154 $2,584,750$7,582,146 $2,772,151 515 515 0 N/A 1,021 1,021 0 20164 $2,584,750$7,582,146 $2,772,151 526 526 0 N/A 1,546 1,546 0 2017 $4,567,621$13,398,730 $2,772,151 536 373 163 $16,982 2,082 1,919 163 2018 $4,567,621$13,398,730 $2,772,151 547 380 167 $16,649 2,629 2,300 330 2019 $1,982,871$5,816,584 $2,772,151 558 388 170 $16,323 3,187 2,688 500 2020 $1,982,871$5,816,584 $2,772,151 569 396 173 $16,003 3,756 3,083 673 2021 $1,982,871$5,816,584 $2,772,151 580 404 177 $15,689 4,336 3,487 849 2022 $1,982,871$5,816,584 $2,772,151 592 214 378 $7,336 4,928 3,701 1,227 2023 $0 $0 $2,772,151 604 218 385 $7,193 5,532 3,919 1,613 2024 $0 $0 $2,772,151 616 223 393 $7,051 6,148 4,142 2,006 2025 $0 $0 $2,772,151 628 227 401 $6,913 6,776 4,369 2,407 2026 $0 $0 $2,772,151 641 232 409 $6,778 7,417 4,601 2,816 2027 $0 $0 $2,772,151 654 236 417 $6,645 8,071 4,838 3,233 2028 $0 $0 $2,772,151 667 241 426 $6,514 8,737 5,079 3,659 2029 $0 $0 $2,772,151 680 246 434 $6,387 9,417 5,325 4,093 2030 $0 $0 $2,772,151 694 251 443 $6,262 10,111 5,575 4,535 2031 $0 $0 $2,772,151 707 256 452 $6,139 10,818 5,831 4,987 2032 $0 $0 $2,772,151 722 261 461 $6,018 11,540 6,092 5,448 2033 $0 $0 $2,772,151 736 266 470 $5,900 12,276 6,359 5,917 2034 $0 $0 $2,772,151 751 272 479 $5,785 12,522 6,125 6,397 2035 $0 $0 $2,772,151 766 277 489 $5,671 12,772 5,887 6,885 2036 $0 $0 $2,772,151 781 283 499 $5,560 13,027 5,643 7,384 2037 $0 $0 $2,772,151 797 288 509 $5,451 13,288 5,559 7,729 2038 $0 $0 $2,772,151 813 294 519 $5,344 13,554 5,472 8,082 2039 $0 $0 $2,772,151 829 300 529 $5,239 13,825 5,384 8,441 2040 $0 $0 $2,772,151 845 306 540 $5,137 14,101 5,294 8,807 2041 $0 $0 $2,772,151 862 312 550 $5,036 14,383 5,202 9,181 2042 13,791 4,988 8,803 2043 13,188 4,770 8,418 2044 12,572 4,547 8,025 2045 11,943 4,320 7,624 2046 11,303 4,088 7,215 2047 10,649 3,852 6,797 2048 9,982 3,610 6,372 2049 9,302 3,365 5,938 2050 8,609 3,114 5,495 2051 7,901 2,858 5,044 2052 7,180 2,597 4,583 2053 6,444 2,331 4,113 2054 5,693 2,059 3,634 2055 4,927 1,782 3,145 2056 4,146 1,500 2,647 2057 3,349 1,211 2,138 2058 2,537 918 1,619 2059 1,708 618 1,090 2060 862 312 550

$80,392,378 102,431 $785

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, 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).

32013 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.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Cumulative Emission Reduction over 20-year stove lifespan Nationwide cumulative cost5 **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Wood Stoves**

Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

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) 20133 $1,999,632$5,865,753 $2,441,029 20144 $1,999,632$5,865,753 $2,441,029 184 184 0 N/A 184 184 0 20154 $1,999,632$5,865,753 $2,441,029 187 187 0 N/A 371 371 0 20164 $1,999,632$5,865,753 $2,441,029 191 191 0 N/A 563 563 0 2017 $3,460,695$10,151,657 $2,441,029 195 176 20 $125,135 758 738 20 2018 $3,460,695$10,151,657 $2,441,029 199 179 20 $122,682 957 917 39 2019 $1,568,074$4,599,813 $2,441,029 203 183 20 $120,276 1,160 1,100 60 2020 $1,568,074$4,599,813 $2,441,029 207 186 21 $117,918 1,367 1,286 80 2021 $1,568,074$4,599,813 $2,441,029 211 190 21 $115,606 1,578 1,476 102 2022 $1,568,074$4,599,813 $2,441,029 215 101 115 $21,304 1,793 1,577 216 2023 $0 $453,909 $2,441,029 220 103 117 $20,887 2,013 1,680 333 2024 $0 $453,909 $2,441,029 224 105 119 $20,477 2,237 1,785 452 2025 $0 $453,909 $2,441,029 229 107 122 $20,076 2,465 1,892 574 2026 $0 $453,909 $2,441,029 233 109 124 $19,682 2,699 2,001 698 2027 $0 $453,909 $2,441,029 238 111 127 $19,296 2,936 2,112 824 2028 $0 $453,909 $2,441,029 243 114 129 $18,918 3,179 2,226 953 2029 $0 $453,909 $2,441,029 247 116 132 $18,547 3,426 2,341 1,085 2030 $0 $453,909 $2,441,029 252 118 134 $18,183 3,679 2,459 1,219 2031 $0 $453,909 $2,441,029 257 120 137 $17,826 3,936 2,580 1,356 2032 $0 $453,909 $2,441,029 263 123 140 $17,477 4,199 2,703 1,496 2033 $0 $453,909 $2,441,029 268 125 142 $17,134 4,466 2,828 1,638 2034 $0 $453,909 $2,441,029 273 128 145 $16,798 4,556 2,772 1,784 2035 $0 $453,909 $2,441,029 279 130 148 $16,469 4,647 2,715 1,932 2036 $0 $453,909 $2,441,029 284 133 151 $16,146 4,740 2,657 2,083 2037 $0 $453,909 $2,441,029 290 136 154 $15,829 4,835 2,617 2,218 2038 $0 $453,909 $2,441,029 296 138 157 $15,519 4,931 2,576 2,355 2039 $0 $453,909 $2,441,029 302 141 160 $15,215 5,030 2,535 2,495 2040 $0 $453,909 $2,441,029 308 144 164 $14,916 5,130 2,492 2,638 2041 $0 $453,909 $2,441,029 314 147 167 $14,624 5,233 2,449 2,784 2042 5,018 2,348 2,669 2043 4,798 2,245 2,553 2044 4,574 2,141 2,433 2045 4,345 2,034 2,312 2046 4,112 1,925 2,188 2047 3,874 1,813 2,061 2048 3,632 1,700 1,932 2049 3,384 1,584 1,801 2050 3,132 1,466 1,666 2051 2,875 1,345 1,529 2052 2,612 1,223 1,390 2053 2,344 1,097 1,247 2054 2,071 969 1,102 2055 1,793 839 954 2056 1,508 706 803 2057 1,219 570 648 2058 923 432 491 2059 621 291 331 2060 314 147 167

$70,789,844 31,060 $2,279

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For pellet stoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.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 PM 2.5** **emissions from Pellet Stoves**

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, 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).

32013 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 CostsNationwide

Annual Cost1Nationwide

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) 20133 

### $881,775 $2,586,611 $614,893 20144 

### $881,775 $2,586,611 $614,893 860 246 614 $1,002 860 246 614 2015 $446,448 $1,309,618 $614,893 877 251 626 $982 1,737 497 1,240 2016 $446,448 $1,309,618 $614,893 895 256 638 $963 2,631 753 1,878 20174 

### $780,405 $2,289,254 $614,893 912 144 769 $800 3,544 897 2,647 2018 $780,405 $2,289,254 $614,893 931 147 784 $784 4,474 1,043 3,431 2019 $347,806 $1,020,261 $614,893 949 149 800 $769 5,424 1,193 4,231 2020 $347,806 $1,020,261 $614,893 968 152 816 $754 6,392 1,345 5,046 2021 $347,806 $1,020,261 $614,893 988 155 832 $739 7,379 1,501 5,878 20224 

### $347,806 $1,020,261 $614,893 1,007 82 925 $665 8,387 1,583 6,803 2023 $0 $72,625 $614,893 1,027 84 943 $652 9,414 1,667 7,747 2024 $0 $72,625 $614,893 1,048 86 962 $639 10,462 1,753 8,709 2025 $0 $72,625 $614,893 1,069 88 981 $626 11,531 1,841 9,690 2026 $0 $72,625 $614,893 1,090 89 1,001 $614 12,622 1,930 10,692 2027 $0 $72,625 $614,893 1,112 91 1,021 $602 13,734 2,021 11,713 2028 $0 $72,625 $614,893 1,134 93 1,042 $590 14,868 2,114 12,754 2029 $0 $72,625 $614,893 1,157 95 1,062 $579 16,025 2,209 13,817 2030 $0 $72,625 $614,893 1,180 97 1,084 $567 17,206 2,305 14,900 2031 $0 $72,625 $614,893 1,204 99 1,105 $556 18,410 2,404 16,006 2032 $0 $72,625 $614,893 1,228 101 1,127 $545 19,638 2,504 17,133 2033 $0 $72,625 $614,893 1,253 103 1,150 $535 20,890 2,607 18,283 2034 $0 $72,625 $614,893 1,278 105 1,173 $524 21,308 2,466 18,842 2035 $0 $72,625 $614,893 1,303 107 1,196 $514 21,734 2,321 19,413 2036 $0 $72,625 $614,893 1,329 109 1,220 $504 22,169 2,174 19,995 2037 $0 $72,625 $614,893 1,356 111 1,245 $494 22,612 2,141 20,471 2038 $0 $72,625 $614,893 1,383 113 1,270 $484 23,064 2,108 20,956 2039 $0 $72,625 $614,893 1,411 115 1,295 $475 23,526 2,074 21,452 2040 $0 $72,625 $614,893 1,439 118 1,321 $465 23,996 2,039 21,957 2041 $0 $72,625 $614,893 1,468 120 1,347 $456 24,476 2,004 22,472 2042 23,469 1,921 21,547 2043 22,441 1,837 20,604 2044 21,393 1,752 19,642 2045 20,324 1,664 18,660 2046 19,234 1,575 17,659 2047 18,122 1,484 16,638 2048 16,987 1,391 15,596 2049 15,830 1,296 14,534 2050 14,650 1,199 13,450 2051 13,446 1,101 12,345 2052 12,218 1,000 11,218 2053 10,965 898 10,068 2054 9,688 793 8,895 2055 8,385 686 7,698 2056 7,055 578 6,478 2057 5,700 467 5,233 2058 4,317 353 3,963 2059 2,906 238 2,668 2060 1,468 120 1,347

$17,831,892 250,714 $71

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. 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 PM 2.5** 

### emissions from Single Burn Rate Stoves

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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 CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $4,829,241$14,166,171 $4,772,249 20144 $4,829,241$14,166,171 $4,772,249 4,038 825 3,213 $1,485 4,038 825 3,213 2015 $3,740,925$10,973,689 $4,772,249 4,119 842 3,277 $1,456 8,157 1,667 6,490 2016 $3,740,925$10,973,689 $4,772,249 4,201 858 3,343 $1,428 12,358 2,525 9,833 20174 $6,579,561$19,300,588 $4,772,249 4,285 214 4,071 $1,172 16,643 2,739 13,903 2018 $6,579,561$19,300,588 $4,772,249 4,371 219 4,152 $1,149 21,014 2,958 18,056 2019 $2,925,650$8,582,148 $4,772,249 4,458 223 4,235 $1,127 25,472 3,181 22,291 2020 $2,925,650$8,582,148 $4,772,249 4,547 227 4,320 $1,105 30,019 3,408 26,611 2021 $2,925,650$8,582,148 $4,772,249 4,638 232 4,406 $1,083 34,658 3,640 31,017 20224 $2,925,650$8,582,148 $4,772,249 4,731 95 4,636 $1,029 39,389 3,735 35,654 2023 $0 $799,249 $4,772,249 4,826 97 4,729 $1,009 44,214 3,831 40,383 2024 $0 $799,249 $4,772,249 4,922 98 4,824 $989 49,137 3,930 45,207 2025 $0 $799,249 $4,772,249 5,021 100 4,920 $970 54,157 4,030 50,127 2026 $0 $799,249 $4,772,249 5,121 102 5,019 $951 59,278 4,132 55,146 2027 $0 $799,249 $4,772,249 5,224 104 5,119 $932 64,502 4,237 60,265 2028 $0 $799,249 $4,772,249 5,328 107 5,221 $914 69,830 4,344 65,486 2029 $0 $799,249 $4,772,249 5,435 109 5,326 $896 75,264 4,452 70,812 2030 $0 $799,249 $4,772,249 5,543 111 5,432 $878 80,808 4,563 76,245 2031 $0 $799,249 $4,772,249 5,654 113 5,541 $861 86,462 4,676 81,786 2032 $0 $799,249 $4,772,249 5,767 115 5,652 $844 92,229 4,791 87,437 2033 $0 $799,249 $4,772,249 5,883 118 5,765 $828 98,111 4,909 93,202 2034 $0 $799,249 $4,772,249 6,000 120 5,880 $812 100,074 4,204 95,870 2035 $0 $799,249 $4,772,249 6,120 122 5,998 $796 102,075 3,485 98,590 2036 $0 $799,249 $4,772,249 6,243 125 6,118 $780 104,117 2,751 101,365 2037 $0 $799,249 $4,772,249 6,367 127 6,240 $765 106,199 2,664 103,534 2038 $0 $799,249 $4,772,249 6,495 130 6,365 $750 108,323 2,576 105,747 2039 $0 $799,249 $4,772,249 6,625 132 6,492 $735 110,489 2,485 108,004 2040 $0 $799,249 $4,772,249 6,757 135 6,622 $721 112,699 2,393 110,306 2041 $0 $799,249 $4,772,249 6,892 138 6,754 $707 114,953 2,299 112,654 2042 110,222 2,204 108,018 2043 105,396 2,108 103,288 2044 100,474 2,009 98,465 2045 95,453 1,909 93,544 2046 90,332 1,807 88,526 2047 85,109 1,702 83,407 2048 79,781 1,596 78,185 2049 74,346 1,487 72,859 2050 68,803 1,376 67,427 2051 63,149 1,263 61,886 2052 57,382 1,148 56,234 2053 51,499 1,030 50,469 2054 45,499 910 44,589 2055 39,379 788 38,591 2056 33,136 663 32,474 2057 26,769 535 26,234 2058 20,274 405 19,869 2059 13,649 273 13,376 2060 6,892 138 6,754

$138,395,222 1,256,849 $110 Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)**

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. 1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDPpredicted 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).

32013 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.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton) Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

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) 20133 

### $2,188,588$6,420,038 $1,559,018 20144 

### $2,188,588$6,420,038 $1,559,018 2,809 702 2,106 $740 2,809 702 2,106 2015 $1,100,272 $3,227,556 $1,559,018 2,865 716 2,149 $726 5,673 1,418 4,255 2016 $1,100,272 $3,227,556 $1,559,018 2,922 731 2,192 $711 8,595 2,149 6,446 20174 

### $1,935,165 $5,676,644 $1,559,018 2,980 149 2,831 $551 11,576 2,298 9,278 2018 $1,935,165 $5,676,644 $1,559,018 3,040 152 2,888 $540 14,616 2,450 12,166 2019 $860,485 $2,524,161 $1,559,018 3,101 155 2,946 $529 17,717 2,605 15,112 2020 $860,485 $2,524,161 $1,559,018 3,163 158 3,005 $519 20,880 2,763 18,117 2021 $860,485 $2,524,161 $1,559,018 3,226 161 3,065 $509 24,106 2,924 21,181 20224 

### $860,485 $2,524,161 $1,559,018 3,291 66 3,225 $483 27,396 2,990 24,406 2023 $0 $235,073 $1,559,018 3,356 67 3,289 $474 30,753 3,057 27,696 2024 $0 $235,073 $1,559,018 3,424 68 3,355 $465 34,177 3,126 31,051 2025 $0 $235,073 $1,559,018 3,492 70 3,422 $456 37,669 3,196 34,473 2026 $0 $235,073 $1,559,018 3,562 71 3,491 $447 41,231 3,267 37,964 2027 $0 $235,073 $1,559,018 3,633 73 3,561 $438 44,864 3,340 41,524 2028 $0 $235,073 $1,559,018 3,706 74 3,632 $429 48,570 3,414 45,156 2029 $0 $235,073 $1,559,018 3,780 76 3,704 $421 52,349 3,489 48,860 2030 $0 $235,073 $1,559,018 3,856 77 3,778 $413 56,205 3,566 52,639 2031 $0 $235,073 $1,559,018 3,933 79 3,854 $405 60,138 3,645 56,493 2032 $0 $235,073 $1,559,018 4,011 80 3,931 $397 64,149 3,725 60,424 2033 $0 $235,073 $1,559,018 4,092 82 4,010 $389 68,241 3,807 64,433 2034 $0 $235,073 $1,559,018 4,173 83 4,090 $381 69,605 3,188 66,417 2035 $0 $235,073 $1,559,018 4,257 85 4,172 $374 70,997 2,557 68,440 2036 $0 $235,073 $1,559,018 4,342 87 4,255 $366 72,417 1,914 70,504 2037 $0 $235,073 $1,559,018 4,429 89 4,340 $359 73,866 1,853 72,013 2038 $0 $235,073 $1,559,018 4,517 90 4,427 $352 75,343 1,792 73,551 2039 $0 $235,073 $1,559,018 4,608 92 4,516 $345 76,850 1,729 75,121 2040 $0 $235,073 $1,559,018 4,700 94 4,606 $338 78,387 1,665 76,722 2041 $0 $235,073 $1,559,018 4,794 96 4,698 $332 79,955 1,599 78,356 2042 76,664 1,533 75,131 2043 73,307 1,466 71,841 2044 69,884 1,398 68,486 2045 66,392 1,328 65,064 2046 62,830 1,257 61,573 2047 59,197 1,184 58,013 2048 55,491 1,110 54,381 2049 51,711 1,034 50,677 2050 47,855 957 46,898 2051 43,923 878 43,044 2052 39,911 798 39,113 2053 35,820 716 35,103 2054 31,647 633 31,014 2055 27,390 548 26,842 2056 23,048 461 22,587 2057 18,619 372 18,247 2058 14,102 282 13,819 2059 9,494 190 9,304 2060 4,794 96 4,698

$45,211,511 874,191 $52

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.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 PM 2.5** 

### emissions from Forced Air Furnaces

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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 CostsNationwide

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) 20133 

### $2,640,653$7,746,133 $3,213,231 20144 

### $2,640,653$7,746,133 $3,213,231 1,229 123 1,106 $2,904 1,229 123 1,106 2015 $2,640,653$7,746,133 $3,213,231 1,254 125 1,129 $2,847 2,483 248 2,235 2016 $2,640,653$7,746,133 $3,213,231 1,279 128 1,151 $2,791 3,762 376 3,386 20174 

### $4,644,396$13,623,945 $3,213,231 1,305 65 1,239 $2,593 5,067 441 4,626 2018 $4,644,396$13,623,945 $3,213,231 1,331 67 1,264 $2,542 6,398 508 5,890 2019 $2,065,165$6,057,987 $3,213,231 1,357 68 1,289 $2,492 7,755 576 7,179 2020 $2,065,165$6,057,987 $3,213,231 1,384 69 1,315 $2,443 9,140 645 8,494 2021 $2,065,165$6,057,987 $3,213,231 1,412 71 1,342 $2,395 10,552 716 9,836 20224 

### $2,065,165$6,057,987 $3,213,231 1,440 29 1,412 $2,276 11,992 745 11,248 2023 $0 $564,176 $3,213,231 1,469 29 1,440 $2,232 13,461 774 12,688 2024 $0 $564,176 $3,213,231 1,499 30 1,469 $2,188 14,960 804 14,156 2025 $0 $564,176 $3,213,231 1,529 31 1,498 $2,145 16,489 834 15,654 2026 $0 $564,176 $3,213,231 1,559 31 1,528 $2,103 18,048 866 17,182 2027 $0 $564,176 $3,213,231 1,590 32 1,559 $2,062 19,638 897 18,741 2028 $0 $564,176 $3,213,231 1,622 32 1,590 $2,021 21,260 930 20,330 2029 $0 $564,176 $3,213,231 1,655 33 1,621 $1,982 22,915 963 21,952 2030 $0 $564,176 $3,213,231 1,688 34 1,654 $1,943 24,603 997 23,606 2031 $0 $564,176 $3,213,231 1,721 34 1,687 $1,905 26,324 1,031 25,293 2032 $0 $564,176 $3,213,231 1,756 35 1,721 $1,867 28,080 1,066 27,014 2033 $0 $564,176 $3,213,231 1,791 36 1,755 $1,831 29,871 1,102 28,769 2034 $0 $564,176 $3,213,231 1,827 37 1,790 $1,795 30,468 1,016 29,453 2035 $0 $564,176 $3,213,231 1,863 37 1,826 $1,760 31,078 928 30,150 2036 $0 $564,176 $3,213,231 1,901 38 1,863 $1,725 31,699 838 30,861 2037 $0 $564,176 $3,213,231 1,939 39 1,900 $1,691 32,333 811 31,522 2038 $0 $564,176 $3,213,231 1,977 40 1,938 $1,658 32,980 784 32,196 2039 $0 $564,176 $3,213,231 2,017 40 1,977 $1,626 33,639 757 32,883 2040 $0 $564,176 $3,213,231 2,057 41 2,016 $1,594 34,312 729 33,584 2041 $0 $564,176 $3,213,231 2,098 42 2,056 $1,563 34,998 700 34,298 2042 33,558 671 32,887 2043 32,089 642 31,447 2044 30,590 612 29,978 2045 29,062 581 28,480 2046 27,502 550 26,952 2047 25,912 518 25,394 2048 24,290 486 23,804 2049 22,635 453 22,183 2050 20,948 419 20,529 2051 19,226 385 18,842 2052 17,470 349 17,121 2053 15,679 314 15,366 2054 13,853 277 13,576 2055 11,989 240 11,749 2056 10,089 202 9,887 2057 8,150 163 7,987 2058 6,173 123 6,049 2059 4,156 83 4,073 2060 2,098 42 2,056

$93,183,711 382,658 $244

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 in 2022.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. 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 PM 2.5** 

### emissions from Hydronic Heating Systems

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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 CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $10,295,398$30,200,681$10,600,322 20144 $10,295,398$30,200,681$10,600,322 5,587 1,760 3,827 $2,770 5,587 1,760 3,827 2015 $8,771,756$25,731,206$10,600,322 5,699 1,795 3,903 $2,716 11,285 3,556 7,730 2016 $8,771,756$25,731,206$10,600,322 5,812 1,831 3,981 $2,663 17,098 5,387 11,711 20174 $15,388,282$45,140,228$10,600,322 5,929 906 5,022 $2,111 23,026 6,294 16,733 2018 $15,388,282$45,140,228$10,600,322 6,047 925 5,123 $2,069 29,074 7,218 21,856 2019 $6,824,401$20,018,806$10,600,322 6,168 943 5,225 $2,029 35,242 8,161 27,081 2020 $6,824,401$20,018,806$10,600,322 6,292 962 5,330 $1,989 41,534 9,123 32,411 2021 $6,824,401$20,018,806$10,600,322 6,417 981 5,436 $1,950 47,951 10,104 37,847 20224 $6,824,401$20,018,806$10,600,322 6,546 492 6,054 $1,751 54,497 10,596 43,901 2023 $0 $1,325,783 $10,600,322 6,677 502 6,175 $1,717 61,174 11,098 50,076 2024 $0 $1,325,783 $10,600,322 6,810 512 6,298 $1,683 67,984 11,610 56,374 2025 $0 $1,325,783 $10,600,322 6,946 522 6,424 $1,650 74,930 12,132 62,798 2026 $0 $1,325,783 $10,600,322 7,085 533 6,553 $1,618 82,016 12,664 69,351 2027 $0 $1,325,783 $10,600,322 7,227 543 6,684 $1,586 89,243 13,208 76,035 2028 $0 $1,325,783 $10,600,322 7,372 554 6,818 $1,555 96,614 13,762 82,853 2029 $0 $1,325,783 $10,600,322 7,519 565 6,954 $1,524 104,133 14,327 89,806 2030 $0 $1,325,783 $10,600,322 7,669 576 7,093 $1,494 111,803 14,903 96,899 2031 $0 $1,325,783 $10,600,322 7,823 588 7,235 $1,465 119,626 15,491 104,134 2032 $0 $1,325,783 $10,600,322 7,979 600 7,380 $1,436 127,605 16,091 111,514 2033 $0 $1,325,783 $10,600,322 8,139 612 7,527 $1,408 135,744 16,703 119,041 2034 $0 $1,325,783 $10,600,322 8,302 624 7,678 $1,381 138,459 15,567 122,892 2035 $0 $1,325,783 $10,600,322 8,468 636 7,831 $1,354 141,228 14,408 126,820 2036 $0 $1,325,783 $10,600,322 8,637 649 7,988 $1,327 144,052 13,225 130,827 2037 $0 $1,325,783 $10,600,322 8,810 662 8,148 $1,301 146,933 12,981 133,952 2038 $0 $1,325,783 $10,600,322 8,986 675 8,311 $1,276 149,872 12,732 137,140 2039 $0 $1,325,783 $10,600,322 9,166 689 8,477 $1,251 152,870 12,478 140,392 2040 $0 $1,325,783 $10,600,322 9,349 703 8,646 $1,226 155,927 12,219 143,708 2041 $0 $1,325,783 $10,600,322 9,536 717 8,819 $1,202 159,045 11,954 147,091 2042 152,500 11,462 141,037 2043 145,823 10,960 134,863 2044 139,013 10,449 128,564 2045 132,066 9,926 122,140 2046 124,981 9,394 115,587 2047 117,754 8,851 108,903 2048 110,382 8,297 102,086 2049 102,863 7,731 95,132 2050 95,194 7,155 88,039 2051 87,371 6,567 80,804 2052 79,392 5,967 73,424 2053 71,253 5,356 65,897 2054 62,951 4,732 58,220 2055 54,483 4,095 50,388 2056 45,846 3,446 42,400 2057 37,037 2,784 34,253 2058 28,051 2,108 25,942 2059 18,885 1,419 17,466 2060 9,536 717 8,819

$307,409,335 1,641,055 $187

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, 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).

32013 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.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. No emission reductions are estimated for woodstoves and pellet stoves until 2017, although emission reductions are estimated for all other devices starting in 2014. **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **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