Notes Notes

Wood stove 7.5 to 4.5 High Low median 2013 dollars High Low median 2013 dollars 

Capital Costs Capital Costs

 R&D/Engineering costs R&D/Engineering costs

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 45,500 19,000 32,250

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 91,000 38,000 64,500

adjust design/test until emission target is met 47,500 30,000 38,750 adjust design/test until emission target is met 95,000 60,000 77,500

construct final prototypes, safety test check. 

Eng. Drawings/specs, patent application 27,000 17,000 22,000

construct final prototypes, safety test check. 

Eng. Drawings/specs, patent application 54,000 34,000 44,000

confirm final prototype performance 0 0 0 confirm final prototype performance 0 0 0

 R&D/Engineering Total costs 120,000 66,000 93,000 R&D/Engineering Total costs 240,000 132,000 186,000

 Tooling Tooling

Steel Stove 31,200 9,700 20,450 Steel Stove 31,200 9,700 20,450

Cast Iron Stove 62,000 31,000 46,500 Cast Iron Stove 62,000 31,000 46,500

 Average tooling cost 46,600 20,350 33,475 Average tooling cost 46,600 20,350 33,475

Other Capital Cost components 14,000 6,000 10,000

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above Other Capital Cost components 14,000 6,000 10,000

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

Total Capital Cost per model 180,600 92,350 136,475 Total Capital Cost per model 300,600 158,350 229,475

Fixed Costs per model Fixed Costs per model

 Certification Certification

EPA testing, Confirmation safety testing or full 

safety testing, shipping of prototype 19,000 14,500 16,750

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

EPA testing, Confirmation safety testing or full 

safety testing, shipping of prototype 19,000 14,500 16,750

HBPA costs for personal at lab 

and travel expenses not 

accepted as independent third 

party testing costs

Owner's manual, labeling 3,500 1,800 2,650 Owner's manual, labeling 3,500 1,800 2,650

 Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS

Total Fixed Capital Cost per model 22,500 16,300 19,400 Total Fixed Capital Cost per model 22,500 16,300 19,400

Total Costs per Model 203,100 108,650 155,875 Total Costs per Model 323,100 174,650 248,875

Annualized capital cost per model 42,610 22,794 32,702

annualized over 6 years at 7% 

interest (note: NERA annualized 

over 10 years) Annualized capital cost per model 67,785 36,641 52,213

annualized over 6 years at 7% 

interest (note: NERA annualized 

over 10 years)

Annual cost for development of 4 models 170,438 91,177 130,808 Annual cost for development of 4 models 271,140 146,563 208,852

Adjustable Burn Rate Stoves, 

Pellet Stoves & Single Burn Rate 

Stoves

Single Burn Rate Stoves, first 2 

years (doubled R&D / 

Engineering Costs)
Hydronic Heater Uncontrolled to 0.32 High Low median

Capital Costs

 R&D/Engineering costs

Market research, aesthetic design, initial prototype 

design/construction/testing, formulate design changes, 

modify/test prototype 180,000 115,000 147,500

Formulate design changes 4,500 2,500 3,500

Modify prototype 16,000 9,000 12,500

Test/Retest 615,000 410,000 512,500

Construct final prototype, confirm testing, safety testing 133,500 88,500 111,000

Document final changes 8,000 6,000 7,000

 R&D/Engineering total costs 957,000 631,000 794,000

 Manuracturing/Manufacturing Engineering

Programming and Tooling - Steel parts 22,000 13,000 17,500

Tooling - Refractory 45,000 28,000 36,500

Electronic Control System 10,000 5,000 7,500

Final Production samples/Confirm product. Fitup 25,000 15,000 20,000

Create QA/QC specs 4,000 2,000 3,000

 Manuracturing/Manufacturing Engineering total costs 106,000 63,000 84,500

 Other Capital Cost components

Purchased parts sourcing 41,000 23,500 32,250

Test first production heaters 200,000 150,000 175,000

Equipment and facilities 75,000 25,000 50,000

 Other Capital Cost components total costs 316,000 198,500 257,250

Total Capital Cost per model 1,379,000 892,500 1,135,750

Fixed Costs per model

 Certification

Hydronic Heaters & Forced-Air 

Furnaces
EPA testing, Confirmation safety testing or full safety testing, 

shipping of prototype 72,500 36,000 54,250

Owner's manual, labeling 6,500 3,500 5,000

 Certification Total Costs 79,000 39,500 59,250

 Roll-out 0 0 0

Total Fixed Capital Cost per model 79,000 39,500 59,250

Total Costs per Model 1,458,000 932,000 1,195,000

Annualized capital cost per model 305,882 195,530 250,706

Annual cost for development of 4 models 1,223,529 782,119 1,002,824
Notes

2013 dollars High

Capital Costs

 R&D/Engineering costs

Market research, aesthetic design, initial prototype 

design/construction/testing, formulate design 

changes, modify/test prototype 360,000

Formulate design changes 9,000

Modify prototype 32,000

Test/Retest 1,230,000

Construct final prototype, confirm testing, safety 

testing 267,000

Document final changes 16,000

App. A (NERA) concludes erroneously 

$887,000 for high cost and $581,000 

for low cost. R&D/Engineering total costs 1,914,000

 Manuracturing/Manufacturing Engineering

Programming and Tooling - Steel parts 22,000

Tooling - Refractory 45,000

Electronic Control System 10,000

Final Production samples/Confirm product. Fitup 25,000

Create QA/QC specs 4,000

 Manuracturing/Manufacturing Engineering total costs106,000

 Other Capital Cost components

Purchased parts sourcing 41,000

Test first production heaters 200,000

HPBA costs for equipment and 

integration not included because these 

are considered duplicative of R&D 

costs, above Equipment and facilities 75,000

 Other Capital Cost components total costs 316,000

Total Capital Cost per model 2,336,000

Fixed Costs per model

 Certification

Forced air furnaces, First 2 ye

(doubled R&D / Engineerin
HBPA costs for personal at lab and 

travel expenses not accepted as 

independent third party testing costs

EPA testing, Confirmation safety testing or full safety 

testing, shipping of prototype 72,500

Owner's manual, labeling 6,500

 Certification Total Costs 79,000

roll-out considered normal business 

operation and not due to NSPS Roll-out 0

Total Fixed Capital Cost per model 79,000

Total Costs per Model 2,415,000

annualized over 6 years at 7% interest 

(note: NERA annualized over 10 years) Annualized capital cost per model 506,657

Annual cost for development of 4 models 2,026,627
Notes

Low median 2013 dollars

230,000 295,000

5,000 7,000

18,000 25,000

820,000 1,025,000

177,000 222,000

12,000 14,000

1,262,000 1,588,000

App. A (NERA) concludes 

erroneously $887,000 for high 

cost and $581,000 for low cost.

13,000 17,500

28,000 36,500

5,000 7,500

15,000 20,000

2,000 3,000

63,000 84,500

23,500 32,250

150,000 175,000

25,000 50,000

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

198,500 257,250

1,523,500 1,929,750

Forced air furnaces, First 2 years 

(doubled R&D / Engineering 

costs)
36,000 54,250

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

3,500 5,000

39,500 59,250

0 0

roll-out considered normal 

business operation and not due 

to NSPS

39,500 59,250

1,563,000 1,989,000

327,911 417,284

annualized over 6 years at 7% 

interest (note: NERA annualized 

over 10 years)

1,311,643 1,669,135
Table 9. Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2015-2020) and through model lifespan (2020-2029)

(Step 1 

compliance) 

2015 2016 2017 2018 2019

(Step 2 

compliance) 

2020

2021 through 

20292 

(Step 1 

compliance) 

2015 2016 2017 2018 2019

(Step 2 

compliance) 

2020

2021 through 

20292 

Wood Stoves (R&D)334 125 $88,968 $88,968 $88,968 $88,968 $88,968 $88,968 $0 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $0

Pellet Stoves (R&D, R&R, cert)4,7 29 125 $51,179 $51,179 $51,179 $53,941 $53,941 $53,941 $14,240 $1,484,192 $1,484,192 $1,484,192 $1,564,285 $1,564,285 $1,564,285 $412,963

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 7 3 20 $352,506 $352,506 $352,506 $226,704 $226,704 $226,704 $22,025 $1,057,518 $1,057,518 $1,057,518 $680,112 $680,112 $680,112 $66,074

$5,566,638 $5,566,638 $5,566,638 $5,269,325 $5,269,325 $5,269,325 $479,037

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 7 7 50 $2,986,523 $2,986,523 $1,796,681 $1,799,034 $1,799,034 $1,799,034 $36,849 $20,905,663 $20,905,663 $12,576,770 $12,593,240 $12,593,240 $12,593,240 $257,941

Hydronic Heaters (R&D, R&R, cert.)7,830 120 $828,513 $828,513 $828,513 $829,831 $829,831 $829,831 $20,635 $24,855,398 $24,855,398 $24,855,398 $24,894,927 $24,894,927 $24,894,927 $619,059

$45,761,061 $45,761,061 $37,432,168 $37,488,168 $37,488,168 $37,488,168 $877,000

Period

Nationwide Cost of 

the Rule

$51,327,699 $51,327,699 $42,998,805 $42,757,493 $42,757,493 $42,757,493 $1,356,037

R&D year average (2015-

2020) $45,654,447

Post R&D year average 

(2021-2029) $1,356,037

Subpart: Years Annual $

AAA: 2015-2017 Laboratories $55,000

Third-Party Certifiers $16,000

AAA: 2018-2020 Laboratories $73,000

Third-Party Certifiers $9,000

QQQQ: 2015-2017 Laboratories $36,000

Third-Party Certifiers $15,000

QQQQ: 2018-2020 Laboratories $49,000

Third-Party Certifiers $5,000

* Reporting and Recordkeeping (R&R) costs for laboratories and certifying entities are not included in this cost analysis but are estimated as follows: 

1 Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2015 through 2020). Ongoing certification and reporting & recordkeeping costs are incurred through 2029 (based on a model brought to market in 2020 with a lifespan of 10 years).

Annual Cost of the Rule

6

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

in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015.

5

Based on conversations with industry (e.g., 2/8/13), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2014 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 assumes that these efforts will intensify in 2015 and 2016. Therefore estimated R&D costs are doubled in 2015 and 2016 to reflect model development to meet the more stringent 2020 Step 2 standard. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis 

beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015.

4

For pellet stoves, the analysis assumes that 70% meet Step 2 already so that 30% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 70% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2015. The analysis 

reflects the certification costs beginning in 2015 for the 70% of models meeting Step 2, and beginning in 2020 for the remaining 30% of models which underwent R&D re-design. The analysis also reflects ongoing reporting & recordkeeping costs for 100% of the models beginning in 2015.

3

 This analysis considers additional costs resulting from the NSPS. For wood stoves, the analysis assumes that 26% meet Step 2 already so that 74% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2021 through 2029 exclude the ongoing certification and reporting & recordkeeping costs incurred 

by wood stove manufacturers who already had to certify and report under the existing 1988 NSPS.

2

 Since certification is required every 5 years , it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

7

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are estimates of the ongoing R&R burden to manufacturers associated with the NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is approximately $179,000 for years 2015 through 

2017 and $352,000 for years 2018 through 2020. For Subpart QQQQ, the R&R burden to manufacturers is estimated to be $141,000 for years 2015 through 2017 and $197,00 for years 2018 through 2020. Although the 2018 through 2020 costs are carried forward to 2029 for this analysis, actual R&R costs from 2021 through 2029 may 

vary slightly. These R&R costs do not include the R&R burden to laboratories and certifying entities, which are calculated separately and provided below.*

8 For hydronic heaters, the analysis assumes that 18% of models meet Step 2 already so that 82% must undergo R&D to meet Step 2 in 2020. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models 

are estimated beginning in 2015.

Average Annual Cost per Manufacturer based on 6-year R&D round (2015-2020) to meet Step 1 and Step 2 

limits with ongoing certification costs (through 2029)

# Manufacturers # Models

Nationwide Annual Costs1

QQQQ: Central Heaters

AAA: Room Heaters

NSPS Subpart Appliance Type
SCC

Appliance 

Population

Total Tons 

Burned Emission Inventory Category Pollutant

Baseline 

Emission 

factor 

(lb/ton)

Baseline 

Emissions 

(tons)

Baseline 

Tons/appl

2015 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 64 116,933 0.3208 6.4

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Primary PM2.5 64 83,972 0.2392 16

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 79,557 81,546 83,585 85,674 87,816 90,012

Single Burn Rate 

Stoves 40,000 25,560 24,538 25,151 25,780 26,424 27,085 27,762 28,456

Pellet Stoves 130,381 83,313 79,981 81,980 84,030 86,131 88,284 90,491 92,753

Furnace: indoor, 

cordwood 41,000 26,199 25,151 25,780 26,424 27,085 27,762 28,456 29,167

Hydronic Heating 

Systems 13,385 8,553 8,211 8,416 13,100 13,428 13,763 14,107 14,460

2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 563 360 345 354 363 372 381 391 401

Single Burn Rate 

Stoves 1,295 827 794 814 835 855 877 899 921

Pellet Stoves 83 53 51 52 54 55 56 58 59

Furnace: indoor, 

cordwood 9,808 6,267 6,017 6,167 6,321 6,479 6,641 6,807 6,977

Hydronic Heating 

Systems 3,520 2,250 2,160 2,214 3,446 3,532 3,620 3,710 3,803

Total 15,269 9,757 9,367 9,601 11,018 11,293 11,575 11,865 12,161

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)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)6

2015 4$3,024,928 $1,209,971 391 391 0 N/A 391 391 0

2016 $3,024,928 $1,209,971 401 401 0 N/A 791 791 0

2017 $3,024,928 $1,209,971 411 411 0 N/A 1,202 1,202 0

2018 $3,024,928 $1,209,971 445 445 0 N/A 1,647 1,647 0

2019 $3,024,928 $1,209,971 456 456 0 N/A 2,103 2,103 0

2020 4$3,024,928 $1,209,971 468 262 206 $5,874 2,571 2,365 206

2021 $0 $1,209,971 479 268 211 $5,731 3,050 2,633 417

2022 $0 $1,209,971 491 275 216 $5,591 3,541 2,908 634

2023 $0 $1,209,971 503 282 222 $5,455 4,045 3,189 855

2024 $0 $1,209,971 516 289 227 $5,322 4,561 3,478 1,083

2025 $0 $1,209,971 529 296 233 $5,192 5,090 3,774 1,316

2026 $0 $1,209,971 542 303 239 $5,065 5,632 4,077 1,555

2027 $0 $1,209,971 556 311 245 $4,942 6,188 4,388 1,799

2028 $0 $1,209,971 570 319 251 $4,821 6,757 4,707 2,050

2029 $0 $1,209,971 584 327 257 $4,704 7,341 5,033 2,308

2030 7,341 5,033 2,308

2031 7,341 5,033 2,308

2032 7,341 5,033 2,308

2033 7,341 5,033 2,308

2034 7,341 5,033 2,308

2035 6,950 4,643 2,308

2036 6,550 4,242 2,308

2037 6,139 3,832 2,308

2038 5,694 3,387 2,308

2039 5,238 2,930 2,308

2040 4,771 2,669 2,102

2041 4,291 2,401 1,891

2042 3,800 2,126 1,674

2043 3,297 1,844 1,452

2044 2,781 1,556 1,225

2045 2,252 1,260 992

2046 1,709 956 753

2047 1,154 645 508

2048 584 327 257

$18,149,566 36,238 $501

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

Year 3

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 emitting 

lifespan (per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020 ). Years 2030 through 2048 are past 

the 10-year model design lifespan used in this analysis.

2

 Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 

2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus wood stoves shipped in 2029 will be emitting through 2048.

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For woodstoves, estimates assume that most models already meet the Step 1 limit 

and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS assuming a 10-year model life. 

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year emitting lifespan 5 
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction (tons)6

2015 4$1,484,192 $857,473 58 58 0 N/A 58 58 0

2016 $1,484,192 $857,473 59 59 0 N/A 117 117 0

2017 $1,484,192 $857,473 61 61 0 N/A 177 177 0

2018 $1,564,285 $857,473 62 62 0 N/A 239 239 0

2019 $1,564,285 $857,473 64 64 0 N/A 303 303 0

2020 4$1,564,285 $857,473 65 29 36 $23,667 368 332 36

2021 $412,963 $857,473 67 30 37 $23,090 435 362 73

2022 $412,963 $857,473 69 30 38 $22,526 504 392 111

2023 $412,963 $857,473 70 31 39 $21,977 574 423 150

2024 $412,963 $857,473 72 32 40 $21,441 646 455 190

2025 $412,963 $857,473 74 33 41 $20,918 720 488 231

2026 $412,963 $857,473 76 34 42 $20,408 795 522 273

2027 $412,963 $857,473 78 34 43 $19,910 873 556 317

2028 $412,963 $857,473 79 35 44 $19,425 952 592 361

2029 $412,963 $857,473 81 36 45 $18,951 1,034 628 406

2030 1,034 628 406

2031 1,034 628 406

2032 1,034 628 406

2033 1,034 628 406

2034 1,034 628 406

2035 976 570 406

2036 917 511 406

2037 856 450 406

2038 794 388 406

2039 731 325 406

2040 665 296 370

2041 599 266 333

2042 530 236 294

2043 460 204 255

2044 388 172 215

2045 314 140 174

2046 238 106 132

2047 161 72 89

2048 81 36 45

$12,862,099 6,374 $2,018

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount pellet stoves already meeting the Step 2 limit (i.e., 70% of pellet stoves already meet the 

Step 2 limit).

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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-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 2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus pellet stoves shipped in 2029 will be emitting through 2048.

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For pellet stoves, estimates assume that most models already meet the Step 1 limit and 

that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

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

costs to bring these stoves to market from 2015 through 2029. 

CE based on total cost 

& cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
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)

2015 4$1,057,518 $387,171 899 257 641 $604 899 257 641

2016 $1,057,518 $387,171 921 264 657 $589 1,820 521 1,299

2017 $1,057,518 $387,171 944 270 674 $575 2,764 791 1,973

2018 $680,112 $387,171 968 277 691 $561 3,732 1,068 2,663

2019 $680,112 $387,171 992 284 708 $547 4,724 1,352 3,371

2020 4$680,112 $387,171 1,017 129 887 $436 5,740 1,482 4,259

2021 $66,074 $387,171 1,042 133 910 $426 6,783 1,614 5,168

2022 $66,074 $387,171 1,068 136 932 $415 7,851 1,750 6,101

2023 $66,074 $387,171 1,095 139 956 $405 8,946 1,889 7,056

2024 $66,074 $387,171 1,122 143 980 $395 10,068 2,032 8,036

2025 $66,074 $387,171 1,150 146 1,004 $386 11,218 2,179 9,040

2026 $66,074 $387,171 1,179 150 1,029 $376 12,398 2,329 10,069

2027 $66,074 $387,171 1,209 154 1,055 $367 13,606 2,482 11,124

2028 $66,074 $387,171 1,239 158 1,081 $358 14,845 2,640 12,205

2029 $66,074 $387,171 1,270 162 1,108 $349 16,115 2,802 13,313

2030 16,115 2,802 13,313

2031 16,115 2,802 13,313

2032 16,115 2,802 13,313

2033 16,115 2,802 13,313

2034 16,115 2,802 13,313

2035 15,216 2,544 12,672

2036 14,295 2,281 12,014

2037 13,351 2,010 11,341

2038 12,383 1,733 10,650

2039 11,391 1,449 9,942

2040 10,374 1,320 9,054

2041 9,332 1,187 8,145

2042 8,264 1,051 7,213

2043 7,169 912 6,257

2044 6,047 769 5,277

2045 4,896 623 4,273

2046 3,717 473 3,244

2047 2,509 319 2,189

2048 1,270 162 1,108

$5,807,558 183,259 $32

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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-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 2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus single burn rate stoves shipped in 2029 will be emitting through 2048.

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. 

5

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

to bring these stoves to market from 2015 through 2029. 

CE based on total cost 

& cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$5,566,638 $2,454,615 1,347 706 641 $3,827 1,347 706 641

2016 $5,566,638 $2,454,615 1,381 723 657 $3,734 2,728 1,429 1,299

2017 $5,566,638 $2,454,615 1,415 741 674 $3,643 4,143 2,170 1,973

2018 $5,269,325 $2,454,615 1,475 784 691 $3,554 5,618 2,955 2,663

2019 $5,269,325 $2,454,615 1,512 804 708 $3,467 7,130 3,758 3,371

2020 4$5,269,325 $2,454,615 1,550 420 1,130 $2,173 8,679 4,178 4,501

2021 $479,037 $2,454,615 1,588 430 1,158 $2,120 10,268 4,609 5,659

2022 $479,037 $2,454,615 1,628 441 1,187 $2,068 11,896 5,050 6,846

2023 $479,037 $2,454,615 1,669 452 1,216 $2,018 13,564 5,502 8,062

2024 $479,037 $2,454,615 1,710 464 1,247 $1,969 15,275 5,966 9,309

2025 $479,037 $2,454,615 1,753 475 1,278 $1,921 17,028 6,441 10,587

2026 $479,037 $2,454,615 1,797 487 1,310 $1,874 18,825 6,928 11,897

2027 $479,037 $2,454,615 1,842 499 1,343 $1,828 20,667 7,427 13,240

2028 $479,037 $2,454,615 1,888 512 1,376 $1,783 22,554 7,938 14,616

2029 $479,037 $2,454,615 1,935 524 1,411 $1,740 24,490 8,463 16,027

2030 24,490 8,463 16,027

2031 24,490 8,463 16,027

2032 24,490 8,463 16,027

2033 24,490 8,463 16,027

2034 24,490 8,463 16,027

2035 23,143 7,757 15,385

2036 21,762 7,034 14,728

2037 20,346 6,292 14,054

2038 18,872 5,508 13,363

2039 17,360 4,704 12,655

2040 15,810 4,285 11,526

2041 14,222 3,854 10,368

2042 12,594 3,413 9,181

2043 10,925 2,961 7,965

2044 9,215 2,497 6,718

2045 7,462 2,022 5,440

2046 5,665 1,535 4,130

2047 3,823 1,036 2,787

2048 1,935 524 1,411

$36,819,222 225,872 $163

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters already meeting the Step 2 limit (i.e., 26% of wood stoves and 70% of 

pellet stoves are estimated to already meet the Step 2 limit).

CE based on total 

cost & cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

3

 These heaters have in-home emitting lifespans of at least 20 years; thus room heaters shipped in 2029 will be emitting through 2048.

Cumulative Emission Reduction 

over 20-year emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year

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

Nationwide cumulative cost5 

5

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

costs to bring these stoves to market from 2015 through 2029. 

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and 

reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 

2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. In order to not overestimate emission reductions resulting from the rule, for 

woodstoves and pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 

2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2020. 
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)

2015 4$20,905,663 $6,299,286 6,807 6,807 0 N/A 6,807 6,807 0

2016 4$20,905,663 $6,299,286 6,977 5,669 1,308 $4,815 13,785 12,476 1,308

2017 4$12,576,770 $6,299,286 7,152 1,788 5,364 $1,174 20,937 14,264 6,672

2018 $12,593,240 $6,299,286 7,331 1,833 5,498 $1,146 28,267 16,097 12,170

2019 $12,593,240 $6,299,286 7,514 1,878 5,635 $1,118 35,781 17,976 17,806

2020 4$12,593,240 $6,299,286 7,702 241 7,461 $844 43,483 18,216 25,267

2021 $257,941 $6,299,286 7,894 247 7,648 $824 51,377 18,463 32,914

2022 $257,941 $6,299,286 8,092 253 7,839 $804 59,469 18,716 40,753

2023 $257,941 $6,299,286 8,294 259 8,035 $784 67,763 18,975 48,788

2024 $257,941 $6,299,286 8,501 266 8,236 $765 76,264 19,241 57,024

2025 $257,941 $6,299,286 8,714 272 8,442 $746 84,978 19,513 65,465

2026 $257,941 $6,299,286 8,932 279 8,653 $728 93,910 19,792 74,118

2027 $257,941 $6,299,286 9,155 286 8,869 $710 103,065 20,078 82,987

2028 $257,941 $6,299,286 9,384 293 9,091 $693 112,449 20,371 92,077

2029 $257,941 $6,299,286 9,618 301 9,318 $676 122,067 20,672 101,395

2030 122,067 20,672 101,395

2031 122,067 20,672 101,395

2032 122,067 20,672 101,395

2033 122,067 20,672 101,395

2034 122,067 20,672 101,395

2035 115,260 13,865 101,395

2036 108,283 8,196 100,087

2037 101,131 6,408 94,723

2038 93,800 4,575 89,225

2039 86,286 2,696 83,590

2040 78,584 2,456 76,129

2041 70,690 2,209 68,481

2042 62,598 1,956 60,642

2043 54,304 1,697 52,607

2044 45,803 1,431 44,372

2045 37,089 1,159 35,930

2046 28,157 880 27,277

2047 19,002 594 18,409

2048 9,618 301 9,318

$94,489,287 1,470,557 $64

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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-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 2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus forced-air furnaces shipped in 2029 will be emitting through 2048.

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards 

in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020. 

5

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

costs to bring these heaters to market from 2014 through 2029. 

CE based on total cost 

& cumulative emission 

reduction over 20-year 

emitting lifespan (per 

ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)6

2015 4$24,855,398 $10,321,500.34 3,710 371 3,339 $3,091 3,710 371 3,339

2016 $24,855,398 $10,321,500.34 3,803 380 3,423 $3,015 7,514 751 6,762

2017 $24,855,398 $10,321,500.34 3,898 390 3,508 $2,942 11,412 1,141 10,271

2018 $24,894,927 $10,321,500.34 3,996 400 3,596 $2,870 15,408 1,541 13,867

2019 $24,894,927 $10,321,500.34 4,096 410 3,686 $2,800 19,503 1,950 17,553

2020 4$24,894,927 $10,321,500.34 4,198 131 4,067 $2,538 23,701 2,082 21,620

2021 $619,059 $10,321,500.34 4,303 134 4,168 $2,476 28,004 2,216 25,788

2022 $619,059 $10,321,500.34 4,411 138 4,273 $2,416 32,415 2,354 30,061

2023 $619,059 $10,321,500.34 4,521 141 4,380 $2,357 36,936 2,495 34,440

2024 $619,059 $10,321,500.34 4,634 145 4,489 $2,299 41,569 2,640 38,929

2025 $619,059 $10,321,500.34 4,750 148 4,601 $2,243 46,319 2,788 43,531

2026 $619,059 $10,321,500.34 4,868 152 4,716 $2,188 51,187 2,940 48,247

2027 $619,059 $10,321,500.34 4,990 156 4,834 $2,135 56,178 3,096 53,081

2028 $619,059 $10,321,500.34 5,115 160 4,955 $2,083 61,292 3,256 58,036

2029 $619,059 $10,321,500.34 5,243 164 5,079 $2,032 66,535 3,420 63,115

2030 66,535 3,420 63,115

2031 66,535 3,420 63,115

2032 66,535 3,420 63,115

2033 66,535 3,420 63,115

2034 66,535 3,420 63,115

2035 62,825 3,049 59,776

2036 59,022 2,669 56,353

2037 55,123 2,279 52,844

2038 51,128 1,879 49,248

2039 47,032 1,470 45,562

2040 42,834 1,339 41,495

2041 38,531 1,204 37,327

2042 34,120 1,066 33,054

2043 29,600 925 28,675

2044 24,966 780 24,186

2045 20,216 632 19,584

2046 15,348 480 14,868

2047 3

10,358 324 10,034

2048 3

5,243 164 5,079

$154,822,505 856,776 $181

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount hydronic heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are 

estimated to already meet the Step 2 limit).

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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 

2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus hydronic heaters shipped in 2029 will be emitting through 2048.

Year

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. 

5

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

costs to bring these heaters to market from 2014 through 2029. 

CE based on total cost 

& cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)6

2015 4$45,761,061 $16,620,786 10,518 7,178 3,339 $4,977 10,518 7,178 3,339

2016 4$45,761,061 $16,620,786 10,781 6,049 4,731 $3,513 21,298 13,228 8,071

2017 4$37,432,168 $16,620,786 11,050 2,178 8,872 $1,873 32,348 15,406 16,943

2018 $37,488,168 $16,620,786 11,326 2,232 9,094 $1,828 43,675 17,638 26,037

2019 $37,488,168 $16,620,786 11,610 2,288 9,322 $1,783 55,284 19,926 35,359

2020 4$37,488,168 $16,620,786 11,900 372 11,528 $1,442 67,184 20,298 46,887

2021 $877,000 $16,620,786 12,197 381 11,816 $1,407 79,382 20,679 58,703

2022 $877,000 $16,620,786 12,502 391 12,112 $1,372 91,884 21,070 70,814

2023 $877,000 $16,620,786 12,815 400 12,414 $1,339 104,699 21,470 83,229

2024 $877,000 $16,620,786 13,135 410 12,725 $1,306 117,834 21,881 95,953

2025 $877,000 $16,620,786 13,464 421 13,043 $1,274 131,297 22,301 108,996

2026 $877,000 $16,620,786 13,800 431 13,369 $1,243 145,097 22,733 122,365

2027 $877,000 $16,620,786 14,145 442 13,703 $1,213 159,243 23,175 136,068

2028 $877,000 $16,620,786 14,499 453 14,046 $1,183 173,741 23,628 150,114

2029 $877,000 $16,620,786 14,861 464 14,397 $1,154 188,603 24,092 164,510

2030 188,603 24,092 164,510

2031 188,603 24,092 164,510

2032 188,603 24,092 164,510

2033 188,603 24,092 164,510

2034 188,603 24,092 164,510

2035 178,085 16,914 161,171

2036 167,304 10,864 156,440

2037 156,254 8,686 147,568

2038 144,928 6,454 138,473

2039 133,318 4,166 129,152

2040 121,418 3,794 117,624

2041 109,221 3,413 105,808

2042 96,719 3,022 93,696

2043 83,904 2,622 81,282

2044 70,769 2,212 68,557

2045 57,305 1,791 55,514

2046 43,505 1,360 42,146

2047 3

29,360 917 28,442

2048 3

14,861 464 14,397

$249,311,792 2,327,333 $107

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount central heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are 

estimated to already meet the Step 2 limit).

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 

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

5

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

costs to bring these heaters to market from 2014 through 2029. 

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 

2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048. 

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards 

in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020. 

CE based on total 

cost & cumulative 

emission reduction 

over 20-year emitting 

Year lifespan (per ton) 3

Nationwide 

Annual Cost1 
Baseline PM2.5 

Emissions2 (tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline PM2.5 

Emissions (tons)

NSPS PM2.5 

Emissions (tons)

Emission 

Reduction 

(tons)6

2015 4$51,327,699 $19,075,401 11,865 7,884 3,981 $4,792 11,865 7,884 3,981

2016 4$51,327,699 $19,075,401 12,161 6,773 5,389 $3,540 24,026 14,657 9,369

2017 4$42,998,805 $19,075,401 12,465 2,919 9,546 $1,998 36,492 17,576 18,916

2018 $42,757,493 $19,075,401 12,801 3,016 9,785 $1,949 49,293 20,592 28,700

2019 $42,757,493 $19,075,401 13,121 3,092 10,030 $1,902 62,414 23,684 38,730

2020 4$42,757,493 $19,075,401 13,449 792 12,658 $1,507 75,864 24,476 51,388

2021 $1,356,037 $19,075,401 13,786 812 12,974 $1,470 89,649 25,288 64,362

2022 $1,356,037 $19,075,401 14,130 832 13,298 $1,434 103,779 26,119 77,660

2023 $1,356,037 $19,075,401 14,483 853 13,631 $1,399 118,263 26,972 91,291

2024 $1,356,037 $19,075,401 14,846 874 13,972 $1,365 133,108 27,846 105,262

2025 $1,356,037 $19,075,401 15,217 896 14,321 $1,332 148,325 28,742 119,583

2026 $1,356,037 $19,075,401 15,597 918 14,679 $1,300 163,922 29,660 134,262

2027 $1,356,037 $19,075,401 15,987 941 15,046 $1,268 179,909 30,601 149,308

2028 $1,356,037 $19,075,401 16,387 965 15,422 $1,237 196,296 31,566 164,730

2029 $1,356,037 $19,075,401 16,796 989 15,808 $1,207 213,092 32,555 180,537

2030 213,092 32,555 180,537

2031 213,092 32,555 180,537

2032 213,092 32,555 180,537

2033 213,092 32,555 180,537

2034 213,092 32,555 180,537

2035 201,227 24,671 176,556

2036 189,066 17,898 171,168

2037 176,600 14,979 161,622

2038 163,799 11,962 151,837

2039 150,678 8,871 141,807

2040 137,229 8,079 129,150

2041 123,443 7,267 116,176

2042 109,313 6,435 102,877

2043 94,829 5,583 89,247

2044 79,984 4,709 75,275

2045 64,767 3,813 60,954

2046 49,170 2,895 46,275

2047 3 33,183 1,954 31,230

2048 3

16,796 989 15,808

$286,131,014 2,553,205 $112

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit (i.e., 26% of wood 

stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

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 emitting 

lifespan (per ton)

Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 

5

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

costs to bring these heaters to market from 2014 through 2029. 

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Except for adjustments in years 2012 and 2018 based on an industry projections (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for 

shipments) of 2.5% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

 These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048. 

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards 

in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.