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 

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

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 th

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.
s 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

ost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib only 

vices estimate of $100,000 based on crib only (which covered not only emissions testing but also 

tory equipment, retooling and other capital costs was chosen based on industry's estimate that 

o bring a product to market .

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

Wood Stoves (R&D)334 125 $223,004

Pellet Stoves (R&D, R&R)4, 8 29 125 $199,681

Pellet Stoves (certification)429 125 $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.)92 4 $130,169

MH - large companies (R&R, cert.)93 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, alt

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 t

nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by l

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 perce

1 Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 201

2

 Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certificat

3

 This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% 

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 on

5

Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 t

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 st

9

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of t

manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the 

# Manufacturers # Models

Average Annual Cost per Manufa

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart
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

dditional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 

veloped by that manufacturer.

are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burd

o be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496.

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 

h 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 wit

rs), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

onservatively 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 an

 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 

ndergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from 

op models to meet the more stringent 2017 Step 2 and 2022 Step 3 standards.

are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burd

&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimate

erage 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 

certification costs (through 2041)
2021

(Step 3 

compliance) 

2022

2023 

through 

2041 22013 2014 2015 2016 2017

$171,076 $171,076 $0 7,582,146 7,582,146 7,582,146 7,582,146 13,398,730

$154,821 $154,821 $7,031 5,790,753 5,790,753 5,790,753 5,790,753 10,076,657

$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

16,034,510 16,034,510 14,757,517 14,757,517 25,839,640

$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 7,746,133 13,623,945

$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

volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using 

e 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 

n round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs.

 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.

e, 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 repo

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 ongoin

 may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis conservatively assumes that these ef

e annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater 

ements under Subpart RRRR is estimated to be $37,872.

7-2022) to meet Step 3 level with ongoing 

Nationwide Annual Cost
2018 2019 2020 2021 2022

2023 through 

2041 2 

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

25,839,640 11,436,657 11,436,657 11,436,657 11,436,657 $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

QQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average 

costs under the existing NSPS.

fication costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers 

t Step 3 will certify in an ongoing basis starting in 2013. 

ervatively 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 1,226,184 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$5,466,157 $16,034,510 $5,828,073

2014 4$5,466,157 $16,034,510 $5,828,073 1,549 935 614 $9,498 1,549 935 614

2015 4$5,030,830 $14,757,517 $5,828,073 1,580 954 626 $9,311 3,129 1,889 1,240

2016 4$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 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 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

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). Years 2042 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.conferenceboard.org/data/globaloutlook.cfm). 

4

 Estimated 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)

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

$2,584,750 $7,582,146 $2,772,151

2014 4

$2,584,750 $7,582,146 $2,772,151 505 505 0 N/A 505 505 0

2015 4

$2,584,750 $7,582,146 $2,772,151 515 515 0 N/A 1,021 1,021 0

2016 4

$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

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). Years 2042 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.

4

 Estimated 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.

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.

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$1,999,632 $5,865,753 $2,441,029

2014 4$1,999,632 $5,865,753 $2,441,029 184 184 0 N/A 184 184 0

2015 4$1,999,632 $5,865,753 $2,441,029 187 187 0 N/A 371 371 0

2016 4$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

4

 Estimated 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.

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 PM2.5 emissions from Pellet 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). Years 2042 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 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$881,775 $2,586,611 $614,893

2014 4$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

2017 4$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

2022 4$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 PM2.5 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). Years 2042 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 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$4,829,241 $14,166,171 $4,772,249

2014 4$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

2017 4$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

2022 4$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

Nationwide cumulative cost $138,395,222 1,256,849 $110 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 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.

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). Years 2042 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.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, Step 2 standard in 2017, and Step 3 standard in 2022. 

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

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

2014 4

$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

2017 4

$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

2022 4

$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 PM2.5 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). Years 2042 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 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

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

2014 4

$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

2017 4

$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

2022 4 $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 PM2.5 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). Years 2042 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 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$10,295,398 $30,200,681 $10,600,322

2014 4$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

2017 4$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

2022 4$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

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.

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 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). Years 2042 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.

4

 Estimated 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 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