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 16,750HBPA 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 16,750HBPA 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 32,702annualized over 6 years at 7% interest (note: NERA annualized over 10 years) **Annualized capital cost per model** 67,785 36,641 52,213annualized 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 costs 106,000** 
**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 years (doubled R&D / Engineering** 

# 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 25,000 820,0001,025,000

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 50,000HPBA 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 54,250HBPA 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)3 34 125 $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.)7,8 30 120 $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: 1Nationwide 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

6For 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. 5Based 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. 4For 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. 3This 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. 2Since 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.

7Reporting 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$179,000for years 2015 through 2017 and$352,000for 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.*

8For 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 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Primary PM2.5 8.76 5,371 0.0041 8.76

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

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

2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Primary PM2.5 9.72 3,769 0.0101 9.72 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Primary PM2.5 3.06 1,798 0.0021 3.06

2,206,470 4,668,250Single Burn Rate Stoves Primary PM2.5 30.6 71,424 0.0324 8.76 2104008610 364,560 3,654,153Hydronic heater: outdoor Primary PM2.5 64 116,933 0.3208 6.4 2104008510 351,023 2,624,115Furnace: indoor, cordwood Primary PM2.5 64 83,972 0.2392 16 0.0060Baseline woodstove weighted average (Tons/appl)

## 2008 **2009 2010**  **2011 2012**  **2013 2014**  **2015 2016** 

Wood Stoves 126,527 80,851 77,617 79,557 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


### 20154 

### $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 20204 

### $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 PM 2.5** 

### emissions from Wood Stoves

Year3 

### 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 ). Years2030 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 over 20-year emitting lifespan Nationwide cumulative cost5

### 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


### 20154 

### $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 20204 

### $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 PM 2.5** 

### 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). Years2030 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. Year3 

### 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 lifespanBaseline 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) 20154 $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 20204 $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 PM 2.5** **emissions from Single Burn Rate Stoves**

1Estimated 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). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.5% from 2015 through 2029, for the purposes of a sensitivity analysis.

3These heaters have in-home emitting lifespans of at least 20 years; thus single burn rate stoves shipped in 2029 will be emitting through 2048. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020.

5The 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 lifespanBaseline 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
20154 $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 20204 $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

6In 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)

3These 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 Emission Reduction, cumulative per year Annual Snapshots **Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)**

Nationwide cumulative cost5

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D 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. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost

1Estimated 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). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except 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.

4Estimated 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) 20154 

### $20,905,663 $6,299,286 6,807 6,807 0 N/A 6,807 6,807 0 20164 

### $20,905,663 $6,299,286 6,977 5,669 1,308 $4,815 13,785 12,476 1,308 20174 

### $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 20204 

### $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 PM 2.5** 

### 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). Years2030 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. Year3 

### 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


### 20154 

### $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 20204 

### $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 20473 

### 10,358 324 10,034 20483 

### 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 PM 2.5** 

### 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). Years2030 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 lifespanBaseline 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
20154 $45,761,061 $16,620,786 10,518 7,178 3,339 $4,977 10,518 7,178 3,339 20164 $45,761,061 $16,620,786 10,781 6,049 4,731 $3,513 21,298 13,228 8,071 20174 $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 20204 $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 20473 29,360 917 28,442 20483 14,861 464 14,397

$249,311,792 2,327,333 $107 Nationwide Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

6In 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 PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)**

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D 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. 1Estimated 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). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except 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.

3These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048.

4Estimated 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 lifespan (per ton) Year3 Nationwide

Annual Cost1Baseline 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
20154 $51,327,699 $19,075,401 11,865 7,884 3,981 $4,792 11,865 7,884 3,981 20164 $51,327,699 $19,075,401 12,161 6,773 5,389 $3,540 24,026 14,657 9,369 20174 $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 20204 $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 20473 33,183 1,954 31,230 20483 16,796 989 15,808

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

6In 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 PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)** 

CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton) Emission Reduction, cumulative per year

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespan

5The 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. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots

1Estimated 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). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except 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.

3These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048.

4Estimated 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.