E

C

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122

MEMORANDUM

DATE: February 22, 2013

SUBJECT: Estimated Residential Wood Heater Manufacturer Cost Impacts

FROM: Jill Mozier, EC/R Inc.

Beth Friedman, EC/R Inc.

TO: Gil Wood, EPA/OAQPS

David Cole, EPA/OAQPS

The purpose of this memorandum is to document the estimated nationwide cost impacts 

on manufacturers of emission reduction options being considered for residential wood heaters as 

part of the New Source Performance Standards (NSPS) review of residential wood heaters. The 

underlying cost assumptions for two options are summarized herein – the proposed NSPS 

(“Proposal”) and an alternative approach (“Alternative”) which differ in the number of stepped 

emission limits and in the phased-in compliance dates.

I. Estimated Research and Development (R&D) Costs

A. Residential Wood Heaters – Room Heaters & Central Heaters 

We have heard various estimates of the costs to bring a wood heater from conception to 

completion, from $300,000 for a single model to $1,360,000 for a 4-firebox model line. A recent 

Hearth and Home article estimated the total cost to bring a model from conception to market as 

$645,000 to $750,000 for steel stoves and over $1 million for cast-iron, enameled wood stoves. 

The authors indicated that costs would decrease for separate models in the same line by up to 

25%. Based on this information, we estimate that a 4-model steel line would cost up to $328,125 

per model to develop. These costs include marketing, design, developing first generation, 

second generation and prototype units; NSPS and safety testing, equipment tooling, etc. The 

manufacturer supplying these figures for the article estimated that the NSPS and safety testing 

component of these costs would constitute $40,000 per model. This manufacturer said that 

development time is 12 to 14 months for non-catalytic heaters and 10 to 12 months for catalytic 

heaters.1

Another manufacturer estimated costs of new product development, including design, 

prototype development, testing, tooling equipment and other manufacturing changes, marketing 

support, materials, training, and education to be in excess of $300,000 over an 8- to 12-month 

schedule for a relatively uncomplicated product. Costs will increase for products that have more

 

1

James E. Houck and Paul Tiegs. There’s a Freight Train Comin’. Hearth and Home. December 2009.
2

sophisticated controls.2 One other manufacturer estimated that their typical model development 

costs are around $200,000/model.3

Two manufacturers suggested a 14- to 18-month timeframe is required to develop a new 

firebox, but added that it will take from 5 to 6 years of intensive engineering and R&D efforts to 

have a model line consisting of 4 boxes ready-for-manufacture. They agreed that knowledge of 

the process obtained during each firebox development will shorten (somewhat) the time 

necessary, but not enough to consider within a guiding framework. These manufacturers also 

provided estimated development costs for a 4-box model line, presented in Table 1.4

Table 1. Example of Manufacturers’ Estimates of Costs to Develop Model Line 

(4 Fireboxes)

Cost 

Component

Estimated 

Costs Notes

Salaries $850,000 Using 2-full time experienced employees to bring the products to market, salaries 

and benefits are estimated at $160,000 per year for at least 5.3 years. Tasks include 

design, prototyping, testing, production-line integration, and marketing.

Laboratory 

Equipment

$50,000 In order to accelerate R&D and avoid validating each result with independent 

testing labs (too costly for most manufacturers), new testing equipment will need to 

be purchased in order to sample flue gases, measure test load weight loss, record 

data automatically, and analyze flue gas composition.

Prototypes $25,000 Numerous prototypes will be needed until the final product can be approved. For 

each firebox, an estimated 8 prototypes will be needed, at a cost of $700 each. 

Numerous samples of various components will also have to be purchased from 

vendors. 

Test Fuel* $45,000* Each test costs at least $50 in fuel (assuming cribs are used), including waste. And 

estimated 150 tests will have to be conducted for each firebox for a total of $7,500, 

or $30,000 for a 4-firebox model line based on crib testing.* 

Testing 

Services*

$150,000* Testing services for emissions, efficiency, and safety are estimated to last 

approximately 3 weeks for each firebox. At an average of $1,500 per day plus 

travel expenses, this amounts to approximately $25,000 for each firebox, or 

$100,000 for a 4-firebox model line based on crib testing.*

Outside 

Consultants

$160,000 The average manufacturer will need outside help for design and testing. Testing 

equipment, knowledge of the test standard, and general guidance is normally 

offered by outside consultants (not necessarily certified EPA test labs). The average 

manufacturer will need approximately 300 hours of consulting services per year 

($40,000) for 4 years.

Re-tooling $120,000 For each firebox, new molds and jigs will need to be purchased or produced. Retooling charges will reach an estimated $30,000 per firebox, or $120,000 for a 4-

firebox model line.

Marketing $25,000 New pictures will need to be taken and all the current marketing material, including 

web sites and owner’s manuals, will have to be updated. 

Total $1,425,000 Equal to $356,250/model

*Note: The costs originally provided by industry for this table were presumed to be based on crib wood testing, not 

both crib wood and cord wood testing. Therefore we increased the industry-based “Test Fuel” cost by 50% (to the 

$45,000 shown above) as well as the industry-based “Testing Services” cost by 50% (to the $150,000 shown above) 

in order to estimate the additional cost to test with both crib wood and cord wood.

 

2 Comments from United States Stove Company, Small Entity Representative. July 13, 2010.

3 Confidential Business Information.

4 NSPS Review/Revision, and Impact on Our Companies: A Manufacturer’s Position Statement. Prepared by Stove 

Builder International and United States Stove Company. June 2010.
3

For this analysis, we used the costs provided in the Table 1 example, scaled to a single 

model and spread over a 6-year model development timeframe. We prepared an annualized 

R&D cost estimate by separating cost elements into direct annual costs (salaries) vs. indirect 

annual costs (laboratory equipment, retooling and other capital costs). We estimated annual 

capital costs during the amortized R&D cost period as the fraction that the indirect costs (IAC) 

are of the Total Annual Cost, approximately 34% annually. Ongoing costs such as taxes, 

overhead, and other routine expenses would be incurred regardless of the NSPS standard, and are 

not included in this analysis. Table 2 shows the estimated annualized cost of $63,850 per model, 

assuming an amortization period of 6 years and an interest rate of 7%.

Table 2. Annual Cost Summary: Development of 4 Model Fireboxes1,2

Direct Annual Costs (DAC)

 Operator labor $141,667 Annual salary cost from Table 1, spread over 6 years.

 Outside Consultants $26,667

Annual outside consultant cost from Table 1, spread over 6 

years.

Total Direct Costs (DC) $168,333

Indirect Annual Costs (IAC)

 Laboratory Equipment1$10,490

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

years at an interest rate of 7%. 

 Re-tooling1$25,175

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

an interest rate of 7%.

 Other Capital Costs1,2 $51,400

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%. 

Total Indirect Costs (IAC) $87,065

Total Annual Cost $255,399 Annual cost for development of 4 model fireboxes.

Total Annual Cost $63,850 Average annual cost per firebox model.

1 An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen 

based on industry's estimate that approximately 5 to 6 years of R&D are required to bring a product to market.

2 To estimate the additional cost to test with both cord wood and crib wood, the test fuel industry estimate of 

$30,000 based on crib only was increased by $15,000 and the testing services industry estimate of $100,000 

based on crib only (which covered not only emissions testing but also efficiency and safety testing) was 

increased by $50,000.

B. Masonry Heaters

Masonry heaters manufacturing cost impacts vary by the type of producer and the type of 

certification method. According to one manufacturer5, the masonry heater industry in the U.S. is 

dominated by the Finnish firm Tulikivi, which manufactures and imports about half of the U.S. 

masonry heater units installed yearly through its network of installing distributors. The same 

manufacturer said that the second largest producer is a Canadian firm, Temp-Cast. The 

remainder of the industry is “dozens” of small producers, with probably fewer than 100 (or at 

least fewer than 200) generating any masonry revenue at all. Some commercial operations sell 

core units and/or design kits based on their own design, and other sell units they license from 

 

5 Comments: Residential Solid Fuel Burning Appliance SBREFA Process. Product Category: Masonry Heaters. 

July 13, 2010. Timothy Seaton, Timely Construction, Inc. p. 5.
4

other U.S. or foreign companies. Finally, some units are custom built. Based on this 

information, we assumed that 50 percent of masonry heaters sold per year in the U.S. are 

Tulikivi models and 35 percent are sold by other large manufacturers. The remaining 15 percent 

of units are sold by independent small volume contractors. 

There are three major cost components to consider in evaluating the potential cost 

impacts of the proposed NSPS: research and development (R&D), certification testing, and 

licensing fees for use of a computer software package approved for use in certifying a model 

design. According to information provided by one manufacturer6, R&D costs for a masonry

heater may be estimated at $250,000 (compared to the $340,000 for other wood heater appliance 

models noted in Table 1). For our cost analysis, we assumed R&D costs were the same as for 

other wood heater appliances – that is, $63,850 annually for a 6-year R&D amortization period. 

For facilities conducting R&D, these costs include the costs for certification testing. We 

estimate that the cost of testing a heater design in an EPA accredited lab to be approximately

$10,000.7 

This cost analysis also makes use of a unique software package based on a European 

masonry heater design standard. This standard has been verified in the laboratory and under 

field conditions to produce masonry heaters that would meet the proposed NSPS emission limits. 

The software produces for printout a certification for a given design application and the design 

definition documents as well as operating instructions customized to the given design, so that the 

software verification and certification record is created for and attached to the design. The 

resulting documents can be submitted as part of the certification application. The cost of this 

software to the user is approximately 1,000 Euros (approximately $1,500) for the package with a 

300 Euro (approximately $450) annual fee that commences in the second year following 

purchase.8 

II. Estimated Manufacturer Cost Impacts

A. NSPS Options

We developed two primary options to evaluate the cost impacts of implementing new or 

revised NSPS standards for the residential wood heating appliance industry – namely, the 

proposed approach (“Proposal”) and an alternative approach (“Alternative”). As described in the 

unit cost memorandum9, the cost analyses assume specified phase-in schedules which vary

between the Proposal and Alternative.

The Proposal represents a scenario where all types of appliances (except masonry 

heaters) would be required to meet a specified Step 1 emission limit upon promulgation in 2014 

and then a stricter Step 2 emission limit five years later in 2019. Under this Proposal, large 

manufacturers of masonry heaters would also be required to meet a specified Step 1 emission 

limit upon promulgation in 2014, while small custom manufacturers would not be required to 

meet this Step 1 emission limit until 2019. There is no Step 2 emission limit for masonry heaters 

being proposed. The Alternative approach represents a scenario where all types of appliances 

 

6 Comments: Residential Solid Fuel Burning Appliance SBREFA Process. Product Category: Masonry Heaters. 

July 13, 2010. Timothy Seaton, Timely Construction, Inc. p. 14.

7 Letter to Lucinda Power, EPA, from Brian Klipfel, Fire Works Masonry. September 10, 2010.

8 E-mail from Timothy Seaton, Timely Construction Company, to Gil Wood, USEPA. April 21, 2011.

9 Memo to Gil Wood, USEPA, from Jill Mozier, EC/R, Inc. Unit Cost Estimates of Residential Wood Heating 

Appliances. February 21, 2013.
5

(except masonry heaters) would be required to meet a specified Step 1 emission limit upon 

promulgation in 2014 and then an interim Alternative Step 2 emission limit three years after 

promulgation in 2017, followed by a stricter Alternative Step 3 emission limit eight years after 

promulgation in 2022. Masonry heaters would be regulated the same way under this Alternative 

approach as under the Proposal, as explained above. Note that the Proposal Step 2 emission limit 

is the same as the Alternative Step 3 emission limit, but the compliance dates differ for this 

stricter limit (i.e., 2019 versus 2022). These implementation periods represent a tentative 

schedule and are subject to change. 

Following is a summary of the NSPS implementation assumptions for each appliance 

type, grouped according to NSPS Subparts. This summary describes the specific emission limits 

under the Proposal and the Alternative approach. 

Subpart AAA (“room heaters”): 

1. Adjustable burn rate, single burn rate, and pellet stoves: Proposal: Step 1 limit of 4.5 

g/hr upon promulgation in 2014; and Step 2 limit of 1.3 g/hr five years after 

promulgation in 2019. Alternative: Step 1 limit of 4.5 g/hr upon promulgation in 

2014; Step 2 limit of 2.5 g/hr three years after promulgation in 2017; and Step 3 limit 

of 1.3 g/hr eight years after promulgation in 2022. 

Notes on appliances already meeting these limits: The Step 1 limit is the 1995 

Washington State standard for non-catalytic stoves; the Alternative Step 2 limit is the 

1995 Washington State standard for catalytic stoves; and the proposed Step 2 

(Alternative Step 3) limit is already met by the top performing catalytic, non-catalytic 

and pellet stove models, according to industry data.10 Although previously

unregulated and a less developed technology than adjustable burn rate stoves, single 

burn rate stove designs have been undergoing R&D in anticipation of the proposed 

NSPS and cleaner designs are nearly market-ready.

11

Under both the Proposal and the Alternative, adjustable burn rate wood stoves (both 

catalytic and non-catalytic), pellet stoves, and single burn rate stoves would face a 

Step 1 standard that is based on the current Washington state standards of 4.5 g/hr 

emissions for non-catalytic stoves. Industry data10 from 2010 indicate that 90% (130 

out of 145 catalytic, non-catalytic and pellet stoves combined) already meet this limit, 

as shown in Table A-1 of Attachment A. The tables in Attachment A show the 

emissions performance of wood stoves that are currently certified for which we have 

reproducible emissions data. This list was initially prepared by the Hearth, Patio and 

Barbecue Association (HPBA), and includes the results of an effort to delete models 

that are no longer manufactured and remove duplicate certifications.10

Communication from HPBA confirmed that there were 110 non-catalytic wood 

stoves and 15 catalytic wood stoves being manufactured in 2010 by 34 manufacturers 

or importers of EPA certified wood heaters.12 We believe that manufacturers will 

 

10 Letter to Gil Wood, EPA, from Robert Ferguson, Ferguson, Andors, & Company. April 30, 2010. EC/R made 

minor changes to the data set used in this analysis. See Memo from Jeff Harris, EC/R to Project File. May 3, 2010. 

Changes to “Final HPBA Heater Database” from 2/25/10 Version.

11 2/8/13 telephone discussion between Gil Wood, USEPA, and a manufacturer of single burn rate stoves.

12Letter to Lucinda Power, EPA, from John Crouch, HPBA. September 12, 2010.
6

focus on existing models that meet the Washington State limits in order to comply

with the Step 1 standard.

Furthermore, the HPBA data10 indicates that 35% (52 out of 145 catalytic, noncatalytic and pellet stoves combined) already meet the interim Alternative Step 2 limit 

of 2.5 g/hr. Finally, this same dataset indicates that 10% (14 out of 145 catalytic, noncatalytic and pellet stoves combined) already meet the strictest proposed Step 2 

standard (which is also the Alternative Step 3 standard). Stoves meeting these limits 

are shown in Table A-1 of Attachment A, in which green rows indicate compliance 

with proposed Step 2/Alternative Step 3, green and blue rows indicate compliance 

with interim Alternative Step 2, and green, blue, and orange rows indicate compliance 

with Step 1. Attachment A also includes tables showing this same color-coded 

compliance for the individual catalytic (Table A-2) and pellet stove (Table A-3) 

datasets. 

Based on this emission data for adjustable burn rate and pellet stoves, for our cost 

analysis we assumed that while major R&D efforts are not needed to meet Step 1, 

R&D efforts would be required to meet the strictest standard.

Single burn rate stoves would also be subject to these stepped standards under 

Subpart AAA. Given the relative lack of previous regulation of these appliance types 

in the United States, we believe that manufacturers will have to redesign all such 

models to meet the proposed emission limits, and reflected that major re-design effort 

in our cost estimates.

Our specific cost and implementation assumptions under both the Proposal and 

Alternative scenarios are noted below in Sections B & D.

Subpart QQQQ (“central heaters”):

2. Hydronic heaters (both outdoor and indoor): Proposal: Step 1 limit of 0.32 lb/mm 

BTU heat output upon promulgation in 2014; and Step 2 limit of 0.06 lb/mm BTU 

heat output five years after promulgation in 2019. Alternative: Step 1 limit of 0.32 

lb/mm BTU heat output upon promulgation in 2014; Step 2 limit of 0.15 lb/mm BTU 

heat output three years after promulgation in 2017; and Step 3 limit of 0.06 lb/mm 

BTU heat output eight years after promulgation in 2022.

Notes on appliances already meeting these limits: The Step 1 limit is the EPA 

“Phase 2 ” voluntary program limit already met by 36 hydronic heater models (27 

cord wood and 9 pellet models) built by 17 U.S. manufacturers; the Alternative Step 2 

limit is already met by 11 hydronic heater models (6 cord wood and 5 pellet models) 

built by 6 U.S. manufacturers; and the proposed Step 2 (Alternative Step 3) limit is 

already met by 4 hydronic heater models (2 cord wood and 2 pellet models) built by 2 

U.S. manufacturers13, as well as over 100 European manufacturers per test method 

EN 303-05.14

 

13 See list of cleaner hydronic heaters participating in EPA’s voluntary program at 

http://www.epa.gov/burnwise/owhhlist.html.

14 European Wood-Heating Technology Survey: An Overview of Combustion Principles and the Energy and 

Emissions Performance Characteristics of Commercially Available Systems in Austria, Germany, Denmark, 
7

Based on the EPA’s experience with the hydronic heater market through the 

voluntary program, we understand that it is dominated by a few manufacturers in 

terms of the bulk of sales, and these manufacturers have qualifying units at some or 

all of the stepped emission limits, as noted above. Therefore, on a sales-weighted 

basis, only a percentage of the hydronic heater models currently sold would be 

required to undertake R&D to meet Step 1, with higher percentages needing R&D to 

meet the interim Alternative Step 2 and the proposed Step 2/Alternative Step 3 limits. 

However, for our cost analysis, we assumed that all hydronic heater models would 

begin R&D in 2013 to meet the stricter phased-in standards. Our specific cost and 

implementation assumptions under both the Proposal and Alternative scenarios are 

noted below in Sections B & D.

3. Forced Air Furnaces: Proposal: Step 1 limit of 0.93 lb/mm BTU heat output upon 

promulgation in 2014; and Step 2 limit of 0.06 lb/mm BTU heat output five years 

after promulgation in 2019. Alternative: Step 1 limit of 0.93 lb/mm BTU heat output 

upon promulgation in 2014; Step 2 limit of 0.15 lb/mm BTU heat output three years 

after promulgation in 2017; and Step 3 limit of 0.06 lb/mm BTU heat output eight 

years after promulgation in 2022.

4. Notes on appliances already meeting these limits: The Step 1 limit is based on test 

data from development of Canadian standard B415.1-1015 and conversation with 

industry regarding cleaner forced air furnace models currently being tested in R&D16. 

Forced air furnace designs able to meet the Alternative Step 2 and proposed Step 2 

(Alternative Step 3) limits may be based on technology transferred from hydronic 

heater designs. Given the relative lack of previous regulation of these appliance types 

in the United States, we assume in our cost analysis that manufacturers will have to 

redesign all such models to meet the proposed emission limits, and reflect that major 

re-design effort in our cost estimates. Our specific cost and implementation 

assumptions under both the Proposal and Alternative scenarios are noted below in 

Sections B & D.

Subpart RRRR (masonry heaters):

5. Masonry Heaters: Proposal / Alternative (same): Step 1 limit of 0.32 lb/mm BTU 

heat output upon promulgation in 2014 for large manufacturers (defined as 

manufacturers constructing ≥ 15 masonry heaters per year), with a 5-year (2019) 

small volume manufacturer compliance extension (for companies constructing < 15 

units/year). No other phased-in limits are being proposed.

Notes on appliances already meeting these limits: Based on data submitted by the 

Masonry Heater Association17, over 10 models already meet this limit. The masonry

heater market is dominated by a few large manufacturers and many small custom 

 

Norway, and Sweden; Final Report; Prepared for the New York State Energy Research and Development Authority; 

NYSERDA Report 10–01; April 2010.

15 CSA B415.1-10, Performance Testing of Solid-Fuel-Burning Heating Appliances. Appendix D. March 2010.

16 2/8/13 telephone discussion between Gil Wood, USEPA, and a manufacturer of forced air furnaces.

17 Attachment to 3/25/2011 e-mail from Timothy Seaton of Timely Construction to Gil Wood and Mike Toney of 

USEPA
8

manufacturers, and these segments of the market will take different approaches to 

come into compliance based on their models (i.e., a couple models will undergo 

R&D, while others who already meet the standards will certify through a 

conventional test or through a software product). Our cost analysis segmented the 

market accordingly and based our cost estimates on specific assumptions relevant to 

each segment of the market. These specific cost and implementation assumptions 

(which do not differ for the Proposal and Alternative) are explained below in Sections 

C & D. 

B. Estimated Manufacturer Costs – General Approach

Manufacturers have told us that is takes several years to develop new models. We have 

spread the annualized R&D costs (shown in Table 2) over 6 years to represent the time and funds 

needed to develop the complying models. For the purposes of our cost estimate, we have 

assumed that when the NSPS revisions are proposed, all manufacturers will begin serious efforts 

to develop complying models, although for many manufacturers we also know that they have 

been involved in intensive R&D efforts in anticipation of the proposed rule. 

We estimated both the average annual cost to manufacturers of each appliance type and 

then extended those costs to nationwide total annual costs. The basic components to each 

manufacturer’s estimated annual cost are:

1. Annualized R&D cost;

2. Ongoing annual Certification cost; and

3. Ongoing annual Reporting and Record Keeping cost.

The Annualized R&D costs (shown in Table 2, and based on the Table 1 costs) are by far the 

largest cost component and we have applied these costs to most models in our cost analysis –

especially to models in previously unregulated appliance categories – in order to present our best 

cost estimate of what might happen. For example, as noted above, instead of estimating the 

number of hydronic heater models that already meet a specific limit and will therefore merely 

need to certify their emissions rather than undergo R&D, we instead assumed that 100% of 

hydronic heater models will undergo R&D beginning in 2013. We made similar assumptions for 

single burn rate stoves and forced air furnaces.

Under the Proposal scenario, one round of R&D is assumed – beginning in 2013 and 

ending in 2018 – in order to meet the proposed Step 2 limit. Under the Alternative scenario, two 

rounds of R&D are assumed for all appliances except masonry heaters (for which there is only 

one standard with no additional phased-in standards to meet). Under the Alternative scenario, 

the first R&D round begins in 2013 and the second round begins in 2017 (which causes 

overlapping R&D costs in years 2017 and 2018 in this analysis) – in order to meet the interim 

Alternative Step 2 limit in 2017 and the Alternative Step 3 limit in 2022. We also assumed that 

of the models undergoing the first round of R&D costs, 80% of these models undergo and 

assume the second round of R&D costs in the Alternative scenario (i.e., we assumed that only

20% of models achieve the strictest limit in the first round of R&D).

Furthermore, for appliances like single burn rate stoves and forced air furnaces, which 

were previously unregulated (and also were not pushed technologically by a voluntary program, 

as hydronic heaters were), we have doubled R&D costs during years 2013 and 2014. This 

doubling of R&D cost estimates is to represent an intensification of the R&D efforts to meet the 
9

Step 1 limit and begin development of models to meet the stricter stepped limits – R&D efforts 

which industry has indicated are already ongoing.18

Note that all manufacturers, except for wood stoves that are subject to the current 1988 

NSPS, will face ongoing certification costs above baseline conditions. However, in the 2013 to 

2018 timeframe under the Proposal scenario and in the 2013 to 2022 timeframe under the 

Alternative scenario, we have incorporated these costs as part of the overall R&D expenditures. 

After 2018 under the Proposal scenario and after 2022 under the Alternative scenario, the 

ongoing certification costs will be the only NSPS related costs faced by manufacturers besides 

ongoing reporting and recordkeeping costs. 

Regarding certification costs, we have assumed a cost of $10,000 per model for pellet 

stoves, single burn rate stoves and masonry heaters; and we have assumed a cost of $20,000 per 

model for hydronic heaters and forced air furnaces.19 We have spread these costs out over the 5 

year certification life, assuming annual certification costs for one-fifth of the models.

For example, pellet stoves will incur certification costs in advance of complying with 

more stringent limits. As explained in Section A and shown in Table A-3 of Attachment A, 

approximately 30 percent of existing pellet stove models are expected to comply with the 

proposed Step 2 and Alternative Step 3 standard. However, in order to be sold, these stove 

models would now be required to demonstrate compliance with an emissions limit, incurring an 

upfront cost of $10,000 per model to become certified. We have assumed that one fifth of the 

pellet stove models will certify in any given year. 

We based reporting and recordkeeping (R&R) costs on the annual average costs derived 

from development of the Information Collection Request (ICR) supporting statements20. These 

are annual estimates of the ongoing R&R burden to manufacturers associated with the Proposal 

and Alternative scenarios. (We do not expect the R&R burden to differ substantially between the 

two scenarios.) 

The certification and reporting and recordkeeping costs were estimated to be incurred by 

manufacturers for the full 20-year model design lifespan.21 Under the Proposal, we estimated 

costs from 2013 through 2038 – that is, 20 years after the 2019 compliance year marking the 

beginning of the model lifespan designed to meet the Proposal Step 2 limit. Under the 

Alternative, we estimated costs from 2013 through 2041 – that is, 20 years after the 2022 

compliance year marking the beginning of the model lifespan designed to meet the Alternative 

Step 3 limit.

C. Estimated Manufacturer Costs – Masonry Heaters

As noted above, we addressed masonry heaters in a way which segmented the costs in 

keeping with the masonry heater market. There are three scenarios for potential cost impacts for 

large masonry heater manufacturers. In the case of Tulikivi and some U.S. firms, e.g., Timely

 

18 2/8/13 telephone discussion between Gil Wood, USEPA, and a manufacturer of forced air furnaces and single 

burn rate stoves.

19 Conversation with Dennis Brazier, Central Boiler. August 9, 2010.

20 ICR Supporting Statements for the Proposed NSPS Subparts have not been finalized as of the date of this memo.

21 Memo to Gil Wood, USEPA, from Jill Mozier, EC/R, Inc. Unit Cost Estimates of Residential Wood Heating 

Appliances. February 21, 2013.
10

Construction, these companies have already invested in R&D in order to gain access to U.S. 

markets which restrict sales (e.g., Colorado) of uncertified units. These companies will face 

testing costs only, with an assumed total of nine tests conducted prior to the proposed 

compliance date (i.e., to certify a total of nine model lines). For purposes of our cost analysis, 

we assumed that two additional companies will conduct R&D to develop two new models each 

to meet the proposed NSPS. Finally, we have been told that Tulikivi will use the software 

certification approach to certify up to eight additional models. We also project that the 

remaining 15 percent of custom built units will use the software certification approach to certify

compliance with the proposed NSPS starting in 2013 (estimated date of the proposed standards) 

and that they will continue to renew their license in the following years. 

As explained in the unit cost memo21, we used data in the Frost & Sullivan Market (F&S) 

report22 on 2008 masonry heater shipments by product category and F&S revenue forecasts 

which incorporated the weak economy in years 2009 and 2010, to calculate the reduced number 

of shipments in years 2009 and 2010. For years 2011 through 2038 (for the Proposal) and 2011 

through 2041 (for the Alternative) estimated shipments are based on a forecasted revenue growth 

rate of 2.0%, in keeping with the average annual growth in real GDP predicted by the US Bureau 

of Economic Analysis.23 For masonry heaters, our estimate of the number of custom built 

models is based on the average number of models sold per year in the 15 percent model category

(i.e., 85 per year). We assumed each custom manufacturer would sell 2 models per year, for a 

total of 42 manufacturers participating in the software certification option.

Under both the Proposal and Alternative scenarios, most sales-weighted masonry heater 

units face a 2014 Step 1 compliance date with no other phased-in limits. However, under both 

the Proposal and Alternative scenarios, companies that sell fewer than 15 units per year have 

until 2019 to come into compliance. We have assumed that the large manufacturers will comply

by 2014 for the units that only require testing and/or software certification, with those 

expenditures incurred annually starting in 2013. We also assumed that the 15 percent of custom 

built units will comply by 2019, but will begin certifying their units using the software 

certification approach as early as 2013, as noted above, as a selling point for their services. For 

those companies that start R&D when the NSPS is proposed in 2013, we have assumed that they

will spread these costs over the 6-year period from 2013 through 2018 for the four models 

affected, under both the Proposal and Alternative scenarios.

D. Estimated Manufacturer Costs – Specific Assumptions & Resulting Costs

Table 3a shows the estimated annual cost per manufacturer under the Proposal for all 

appliances. Table 3b shows the nationwide annual costs under the Proposal. The footnotes 

associated with the tables (not included in the tables shown on the following pages) help better 

explain the details we assumed for the cost analysis and are listed below. For the Proposal, the 

footnoted assumptions underlying Tables 3a and 3b are:

 

22 Market Research and Report on North American Residential Wood Heaters, Fireplaces, and Hearth Heating 

Products Market. Prepared by Frost & Sullivan. April 26, 2010. P. 31 -32.

23 2013 Global Outlook projections prepared by the Conference Board in November 2012; http://www.conferenceboard.org/data/globaloutlook.cfm
11

1. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2013 

through 2018). Ongoing certification costs are incurred through 2038 (based on a 

model brought to market in 2019 with a lifespan of 20 years), except for woodstoves 

which already incur certification costs under the existing NSPS.

2. Since certification is required every 5 years (except for the software certification 

option for masonry heaters), it is assumed that certification costs will be spread out so 

that 1/5 of the models certify each year.

3. This analysis considers additional costs resulting from the proposed NSPS. For wood 

stoves, the analysis assumes that 5% meet Step 2 already so that 95% of the models 

will undergo re-design to meet the Step 2 level. The costs modeled for years 2020 

through 2038 exclude the ongoing certification costs and ongoing reporting and 

recordkeeping costs incurred by wood stove manufacturers who already had to certify

and report under the existing NSPS.

4. For pellet stoves, the analysis assumes that 30% meet Step 2 already so that 70% of 

models undergo R&D re-design to meet Step 2. The R&D budget includes 

certification costs. The analysis also assumes that the 30% of the pellet stove models 

which already meet Step 2 will certify in an ongoing basis starting in 2013. The 

analysis reflects the certification costs beginning in 2013 for the 30% of models 

meeting Step 2, and beginning in 2019 for the remaining 70% of models which 

underwent R&D re-design.

5. Based on conversations with industry (2/2013), single burn rate stoves and forced air 

furnaces have been undergoing R&D prior to 2013 to develop cleaner models. 

Because these devices were previously unregulated and may need to transfer 

technology from adjustable burn rate stoves and hydronic heaters respectively, this 

analysis assumes that these efforts will intensify in 2013 and 2014. Therefore 

estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 

standard while also beginning R&D to develop models to meet the more stringent 

2019 Step 2 standard.

6. For single burn rate stoves, forced air furnaces, and hydronic heating systems, 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 2019.

7. For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 

lb/mmBTU standard (no additional stepped standards, although large manufacturers 

will be required to meet the limit in 2014, while small volume manufacturers will be 

given a 5 year extension until 2019 to meet the limit). For masonry heater 

manufacturers using software certification, the analysis assumes the purchased 

software will be used for certifying all models developed by that manufacturer.

8. Reporting and recordkeeping costs (R&R) [for all appliances but masonry heaters] 

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 proposed NSPS. The 

annual average nationwide R&R burden estimated to manufacturers for Subpart AAA 

is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the 

R&R burden to laboratories; the annual average nationwide R&R burden incurred by

laboratories subject to requirements under Subpart AAA is estimated to be $75,745, 

and incurred by laboratories subject to requirements under Subpart QQQQ is 

estimated to be $50,496.
12

9. [Masonry Heater] 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 proposed NSPS. The annual average nationwide 

R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for 

small/custom masonry heater manufacturers and $25,929 for large masonry heater 

manufacturers. These R&R costs do not include the R&R burden to laboratories; the 

annual average nationwide R&R burden incurred by laboratories subject to 

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

Table 4a shows the estimated annual cost per manufacturer under the Alternative 

approach for all appliances. Table 4b shows the nationwide annual costs under the Alternative. 

For the Alternative approach, the footnoted assumptions underlying Tables 4a and 4b (where 

different from the footnotes listed above) are:

1. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round 

one from 2013 through 2018 and round two from 2017 through 2022). Ongoing 

certification costs are incurred through 2041 (based on a model brought to market in 

2022 with a lifespan of 20 years), except for woodstoves which already incur 

certification costs under the existing NSPS.

2. (Same as above)

3. This analysis considers additional costs resulting from the proposed NSPS. For wood 

stoves, the analysis assumes that 5% meet Step 3 already so that 95% of the models 

will undergo re-design in round one, and 80% of those 95% will require another 

round of R&D to meet the Step 3 level. The costs exclude the ongoing certification 

costs and ongoing reporting and recordkeeping costs incurred by wood stove 

manufacturers who already had to certify and report under the existing NSPS.

4. For pellet stoves, the analysis assumes that 30% meet Step 3 already so that 70% of 

models undergo re-design in round one, and 80% of those 70% require another round 

of R&D to meet Step 3. The R&D budget includes certification costs. The analysis 

also assumes that the 30% of the pellet stove models which already meet Step 3 will 

certify in an ongoing basis starting in 2013.

5. Based on conversations with industry (2/2013), single burn rate stoves and forced air 

furnaces have been undergoing R&D prior to 2013 to develop cleaner models. 

Because these devices were previously unregulated and may need to transfer 

technology from adjustable burn rate stoves and hydronic heaters respectively, this 

analysis assumes that these efforts will intensify in 2013 and 2014. Therefore 

estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 

standard while also beginning R&D to develop models to meet the more stringent 

2017 Step 2 and 2022 Step 3 standards.

6. For single burn rate stoves, forced air furnaces, and hydronic heating systems, the 

analysis assumes that only a small percentage meet Step 3 so that approximately

100% of the models undergo re-design in round one, and 80% require another round 

of R&D to meet Step 3. The R&D budget includes certification costs.

7. (Same as above)

8. (Same as above)

9. (Same as above)
13

Table 3a. Average Annual Cost per Manufacturer under the Proposal

2013

(Step 1

compliance) 

2014 2015 2016 2017 2018

(Step 2

compliance) 

2019

2020 

through 

20382

Wood Stoves (R&D)334 125 $223,004 $223,004 $223,004 $223,004 $223,004 $223,004 $0 $0

Pellet Stoves (R&D, R&R)4,829 125 $199,681 $199,681 $199,681 $199,681 $199,681 $199,681 $7,031 $7,031

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

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $862,204 $862,204 $436,539 $436,539 $436,539 $436,539 $24,208 $24,208

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $917,148 $917,148 $461,079 $461,079 $461,079 $461,079 $33,582 $33,582

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $258,204 $258,204 $258,204 $258,204 $258,204 $258,204 $18,806 $18,806

MH - large companies (R&D, R&R, cert.)92 4 $130,169 $130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469

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

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

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

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

with ongoing certification costs (through 2038)

# 

Manufacturers# 

Models

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart Appliance Type
14

Table 3b. Nationwide Annual Costs under the Proposal

2013

(Step 1 

compliance)

2014 2015 2016 2017 2018

(Step 2

compliance) 

2019

2020 

through 

20382

Wood Stoves (R&D)334 125 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $0 $0

Pellet Stoves (R&D, R&R)4,829 125 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $203,909 $203,909

Pellet Stoves (certification)429 125 $75,000 $75,000 $75,000 $75,000 $75,000 $75,000 $250,000 $250,000

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $2,586,611 $2,586,611 $1,309,618 $1,309,618 $1,309,618 $1,309,618 $72,625 $72,625

$16,034,510 $16,034,510 $14,757,517 $14,757,517 $14,757,517 $14,757,517 $526,534 $526,534

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $6,420,038 $6,420,038 $3,227,556 $3,227,556 $3,227,556 $3,227,556 $235,073 $235,073

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $564,176 $564,176

$14,166,171 $14,166,171 $10,973,689 $10,973,689 $10,973,689 $10,973,689 $799,249 $799,249

MH - large companies (R&D, R&R, cert.)92 4 $260,337 $260,337 $260,337 $260,337 $260,337 $260,337 $12,939 $12,939

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

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

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

$462,616 $417,466 $417,466 $417,466 $417,466 $417,466 $170,067 $170,067

$30,663,297 $30,618,147 $26,148,672 $26,148,672 $26,148,672 $26,148,672 $1,495,850 $1,495,850

# 

Manufacturers# 

Models

Nationwide Annual Costs1

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart Appliance Type

Annual Cost of the Rule
15

Table 4a. Average Annual Cost per Manufacturer under the Alternative Approach

2013

(Step 1 

compliance) 

2014 2015 2016

(Step 2 

compliance) 

2017 2018 2019 2020 2021

(Step 3 

compliance) 

2022

2023 

through 

2041 2

Wood Stoves (R&D)334 125 $223,004 $223,004 $223,004 $223,004 $394,080 $394,080 $171,076 $171,076 $171,076 $171,076 $0

Pellet Stoves (R&D, R&R)4, 8 29 125 $199,681 $199,681 $199,681 $199,681 $347,471 $347,471 $154,821 $154,821 $154,821 $154,821 $7,031

Pellet Stoves (certification)429 125 $2,586 $2,586 $2,586 $2,586 $2,586 $2,586 $3,793 $3,793 $3,793 $3,793 $8,621

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $862,204 $862,204 $436,539 $436,539 $763,085 $763,085 $340,087 $340,087 $340,087 $340,087 $24,208

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $917,148 $917,148 $461,079 $461,079 $810,949 $810,949 $360,594 $360,594 $360,594 $360,594 $33,582

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $258,204 $258,204 $258,204 $258,204 $454,131 $454,131 $201,933 $201,933 $201,933 $201,933 $18,806

MH - large companies (R&D, R&R, cert.)92 4 $130,169 $130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469 $6,469 $6,469 $6,469

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

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

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

Appliance Type

# 

Manufacturers# 

Models

Average Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level 

with ongoing certification costs (through 2041)

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart
16

Table 4b. Nationwide Annual Costs under the Alternative Approach

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

2023 

through 

2041 2 

Wood Stoves (R&D)334 125 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $13,398,730 $13,398,730 $5,816,584 $5,816,584 $5,816,584 $5,816,584 $0

Pellet Stoves (R&D, R&R)4, 8 29 125 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $10,076,657 $10,076,657 $4,489,813 $4,489,813 $4,489,813 $4,489,813 $203,909

Pellet Stoves (certification)429 125 $75,000 $75,000 $75,000 $75,000 $75,000 $75,000 $110,000 $110,000 $110,000 $110,000 $250,000

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $2,586,611 $2,586,611 $1,309,618 $1,309,618 $2,289,254 $2,289,254 $1,020,261 $1,020,261 $1,020,261 $1,020,261 $72,625

$16,034,510 $16,034,510 $14,757,517 $14,757,517 $25,839,640 $25,839,640 $11,436,657 $11,436,657 $11,436,657 $11,436,657 $526,534

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $6,420,038 $6,420,038 $3,227,556 $3,227,556 $5,676,644 $5,676,644 $2,524,161 $2,524,161 $2,524,161 $2,524,161 $235,073

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $13,623,945 $13,623,945 $6,057,987 $6,057,987 $6,057,987 $6,057,987 $564,176

$14,166,171 $14,166,171 $10,973,689 $10,973,689 $19,300,588 $19,300,588 $8,582,148 $8,582,148 $8,582,148 $8,582,148 $799,249

MH - large companies (R&D, R&R, cert.)92 4 $260,337 $260,337 $260,337 $260,337 $260,337 $260,337 $12,939 $12,939 $12,939 $12,939 $12,939

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

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

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

$462,616 $417,466 $417,466 $417,466 $417,466 $417,466 $170,067 $170,067 $170,067 $170,067 $170,067

$30,663,297 $30,618,147 $26,148,672 $26,148,672 $45,557,694 $45,557,694 $20,188,873 $20,188,873 $20,188,873 $20,188,873 $1,495,850

Appliance Type

Annual Cost of the Rule

# 

Manufacturers# 

Models

Nationwide Annual Costs1

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart
17

It should be noted that Tables 3a, 3b, 4a, and 4b are based on a 7% interest rate and are in 

2010 dollars($). We also prepared these cost estimates based on a 3% interest rate. Note also 

that costs vary by appliance type based on the average number of models per manufacturer. The 

estimate of the number of model types are described in the unit cost memo.24 For numbers of 

manufacturers, we started with HPBA data, modified based on internet searches of 

manufacturers of the major appliance types.25

The total nationwide cost of the rule from years 2013 through 2023 for the Proposal and 

the Alternative differ based on the underlying cost and implementation assumptions described in 

this memo, and are summarized below in Table 5.

Table 5. Nationwide Annual Cost of the Rule under the Proposal and Alternative 

Approach

Year Cost under Proposal 

(2010$)

Cost under Alternative 

Approach (2010$)

2013 30,663,297 30,663,297

2014 30,618,147 30,618,147

2015 26,148,672 26,148,672

2016 26,148,672 26,148,672

2017 26,148,672 45,557,694

2018 26,148,672 45,557,694

2019 1,495,850 20,188,873

2020 1,495,850 20,188,873

2021 1,495,850 20,188,873

2022 1,495,850 20,188,873

2023 1,495,850 1,495,850

 

24 Memo to Gil Wood, USEPA, from Jill Mozier, EC/R, Inc. Unit Cost Estimates of Residential Wood Heating 

Appliances. February 21, 2013.

25 HPBA Solid Fuel Product List. Attachment to E-mail from John Crouch, HBPS, to Gil Wood, EPA. September 

24, 2010.
18

Attachment A (supplements Page 5 of text in memo)

Table A-1. Non-Catalytic, Catalytic, and Pellet Stove Emissions (HPBA Data)

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

1 Non-Cat 0.70

2 Non-Cat 0.80

3 Cat. 0.80

4 Pellet 1.00

5 Cat. 1.10

6 Pellet 1.10

7 Pellet 1.10

8 Non-Cat 1.10

9 Pellet 1.15

10 Pellet 1.20

11 Pellet 1.20

12 Pellet 1.30

13 Non-Cat 1.30

14 Cat. 1.30

15 Cat. 1.35

16 Non-Cat 1.40

17 Cat. 1.40

18 Pellet 1.40

19 Pellet 1.40

20 Non-Cat 1.50

21 Pellet 1.50

22 Non-Cat 1.60

23 Pellet 1.60

24 Pellet 1.60

25 Pellet 1.60

26 Cat. 1.60

27 Pellet 1.67

28 Pellet 1.70

29 Pellet 1.80

30 Non-Cat 1.89

31 Non-Cat 1.90

32 Cat. 1.90

33 Non-Cat 2.00

34 Non-Cat 2.00

35 Pellet 2.00

36 Cat. 2.00

37 Non-Cat 2.00
19

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

38 Cat. 2.10

39 Non-Cat 2.10

40 Cat. 2.10

41 Non-Cat 2.10

42 Pellet 2.20

43 Non-Cat 2.30

44 Pellet 2.30

45 Cat. 2.40

46 Cat. 2.40

47 Non-Cat 2.40

48 Non-Cat 2.40

49 Non-Cat 2.40

50 Non-Cat 2.43

51 Non-Cat 2.50

52 Cat. 2.50

53 Non-Cat 2.60

54 Non-Cat 2.60

55 Non-Cat 2.60

56 Pellet 2.60

57 Non-Cat 2.70

58 Non-Cat 2.70

59 Non-Cat 2.70

60 Non-Cat 2.70

61 Non-Cat 2.88

62 Non-Cat 2.90

63 Non-Cat 2.90

64 Non-Cat 2.90

65 Non-Cat 2.90

66 Non-Cat 3.00

67 Non-Cat 3.00

68 Non-Cat 3.00

69 Non-Cat 3.00

70 Non-Cat 3.01

71 Non-Cat 3.06

72 Non-Cat 3.10

73 Pellet 3.10

74 Non-Cat 3.10

75 Pellet 3.10

76 Non-Cat 3.10

77 Non-Cat 3.10
20

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

78 Non-Cat 3.10

79 Non-Cat 3.20

80 Non-Cat 3.30

81 Non-Cat 3.35

82 Non-Cat 3.40

83 Non-Cat 3.40

84 Non-Cat 3.40

85 Non-Cat 3.40

86 Non-Cat 3.47

87 Non-Cat 3.50

88 Non-Cat 3.50

89 Non-Cat 3.50

90 Non-Cat 3.50

91 Non-Cat 3.60

92 Non-Cat 3.60

93 Non-Cat 3.60

94 Non-Cat 3.60

95 Non-Cat 3.60

96 Non-Cat 3.60

97 Non-Cat 3.60

98 Non-Cat 3.70

99 Cat. 3.70

100 Non-Cat 3.71

101 Non-Cat 3.72

102 Non-Cat 3.80

103 Non-Cat 3.80

104 Non-Cat 3.80

105 Non-Cat 3.90

106 Non-Cat 3.90

107 Non-Cat 4.00

108 Non-Cat 4.00

109 Non-Cat 4.00

110 Pellet 4.00

111 Non-Cat 4.10

112 Cat. 4.10

113 Non-Cat 4.10

114 Non-Cat 4.10

115 Non-Cat 4.18

116 Non-Cat 4.19

117 Non-Cat 4.20
21

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

118 Non-Cat 4.20

119 Non-Cat 4.20

120 Non-Cat 4.30

121 Non-Cat 4.30

122 Non-Cat 4.31

123 Non-Cat 4.40

124 Non-Cat 4.40

125 Non-Cat 4.40

126 Non-Cat 4.40

127 Non-Cat 4.40

128 Non-Cat 4.50

129 Non-Cat 4.50

130 Non-Cat 4.50

131 Non-Cat 4.70

132 Non-Cat 4.80

133 Non-Cat 4.80

134 Non-Cat 5.10

135 Non-Cat 5.20

136 Non-Cat 5.30

137 Non-Cat 5.50

138 Pellet 5.50

139 Non-Cat 5.90

140 Non-Cat 6.00

141 Non-Cat 6.00

142 Non-Cat 6.10

143 Non-Cat 6.90

144 Non-Cat 7.30

145 Non-Cat 7.50
22

Table A-2. Catalytic Stove Emissions (HPBA Data)

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

1 Cat. 0.80

2 Cat. 1.10

3 Cat. 1.30

4 Cat. 1.35

5 Cat. 1.40

6 Cat. 1.60

7 Cat. 1.90

8 Cat. 2.00

9 Cat. 2.10

10 Cat. 2.10

11 Cat. 2.40

12 Cat. 2.40

13 Cat. 2.50

14 Cat. 3.70

15 Cat. 4.10
23

Table A-3. Pellet Stove Emissions (HPBA Data)

Rank

Type

EPA M28 

Weighted

Cat. / Non. Cat Avg. Emissions

or Pellet g/hour

1 Pellet 1.00

2 Pellet 1.10

3 Pellet 1.10

4 Pellet 1.15

5 Pellet 1.20

6 Pellet 1.20

7 Pellet 1.30

8 Pellet 1.40

9 Pellet 1.40

10 Pellet 1.50

11 Pellet 1.60

12 Pellet 1.60

13 Pellet 1.60

14 Pellet 1.67

15 Pellet 1.70

16 Pellet 1.80

17 Pellet 2.00

18 Pellet 2.20

19 Pellet 2.30

20 Pellet 2.60

21 Pellet 3.10

22 Pellet 3.10

23 Pellet 4.00

24 Pellet 5.50