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: January 30, 2015

SUBJECT: Residential Wood Heater Cost Effectiveness Analysis

FROM: Jill Mozier, EC/R Inc.

TO: David Cole, EPA/OAQPS

Gil Wood, EPA/OAQPS

Amanda Aldridge, EPA/OAQPS

The purpose of this memorandum is to present our cost effectiveness (CE) analyses for 

the PM emission reductions estimated to occur under the final New Source Performance 

Standards (NSPS) for Residential Wood Heaters. The final stepped standards and their 

underlying emission and cost assumptions have already been summarized in the projected 

emissions1, manufacturer cost impacts2and unit cost3 memos. This memo will explain how we 

applied the derived cost and PM emission estimates (based on our already-documented 

assumptions) in our CE analyses.

I. Application of Cost Estimates to Cost Effectiveness Analysis

A. NSPS-Related R&D, Certification, and Reporting & Recordkeeping Costs

As noted in our manufacturer cost impacts memo, one round of R&D is assumed –

beginning in 2015, the rule’s effective date, and ending in 2020, the year of the final Step 2 PM 

standard. We made assumptions regarding the number of model lines that would undergo R&D 

and assume the related costs. In cases where we assumed less than 100% of the models would 

require R&D (e.g., wood stoves, pellet stoves and hydronic heaters), this was based on the 

percentage of models estimated to already meet the 2020 Step 2 PM limit, as explained in both 

the manufacturer cost impacts memo and the projected emissions memo. It is important to note 

that manufacturers will likely consolidate their model lines, focusing on models able to achieve 

the limit, rather than incur R&D costs for every currently non-compliant model line. Therefore 

fewer models than we assumed in our cost estimates will likely undergo R&D, which will 

decrease cost impacts, potentially significantly. But since we do not have data to suggest the 

degree of consolidation which may occur, we assumed all non-compliant models would remain 

in existence and incur R&D costs, in order to avoid underestimating costs. Thus, in our CE 

analyses we assumed the following percentages and models would incur NSPS-related R&D 

costs beginning in 2015:

 

1 Memorandum to USEPA from EC/R, Inc. Estimated Emissions from Wood Heaters. January 2015.

2 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts. January 2015.

3 Memorandum to USEPA from EC/R, Inc. Unit Cost Estimates of Residential Wood Heating Appliances. January 

2015.
2

 74% of wood stove manufacturers (with an estimated 125 models representing catalytic, 

noncatalytic and hybrid designs);

 30% of pellet stove manufacturers (with an estimated 125 models);

 100% of single burn rate stove manufacturers (with an estimated 20 models) would face a 

doubling of the R&D engineering cost portion of total model development costs in 2015 and 

2016 to represent intensification of R&D efforts for this previously unregulated appliance type;

 100% of forced air furnace manufacturers (with an estimated 50 models) would face a doubling 

of the R&D engineering cost portion of total model development costs in 2015 and 2016 to 

represent intensification of R&D efforts for this previously unregulated appliance type; and

 82% of hydronic heater manufacturers (with an estimated 120 models).

As noted in the manufacturer cost impacts memo, all manufacturers, except for wood stove

manufacturers who are subject to the current 1988 NSPS (and therefore already incur certification 

costs), will face ongoing certification costs (every 5 years per model line) above baseline conditions. 

However, in the 2015 to 2020 timeframe, we have incorporated these costs as part of the overall R&D 

expenditures. 

After 2020, our CE analysis tracks the ongoing annual certification and annual reporting and 

recordkeeping costs faced by manufacturers. We based reporting and recordkeeping (R&R) costs on 

the annual average costs derived from development of the Information Collection Request (ICR) 

supporting statements.

4,5

These are annual estimates of the ongoing R&R burden to manufacturers 

associated with final rule compliance.

B. Model Design Lifespan

For proposal, we assumed a 20-year model design lifespan. We made this assumption to best 

characterize the actual model design lifespan given that many models developed for the 1988 NSPS 

are still being sold (after 25 years), and many “new” models still have the same internal working parts 

with merely exterior cosmetic changes. Respectful of comments on the proposed rule6, however, in 

which some industry representatives commented that a shorter model lifespan is more accurate, we 

reduced our assumed model design lifespan to 10 years for this analysis. Therefore our CE analysis 

tracks shipments through year 2029 (assuming a 10-year design life for a model meeting the Step 2 

limit in year 2020).

 

4

See http://www.reginfo.gov for the ICR Supporting Statements for the New Residential Wood Heaters New Source 

Performance Standards (OMB Control Number 2060-0161), Hydronic Heaters and Forced-Air Furnaces New Source 

Performance Standards (OMB Control Number 2060-0693)(40 CFR Part 60, Subparts AAA and QQQQ). 

5

See also Memorandum to Docket ID Number EPA-HQ-OAR-2009-0734 from EC/R, Inc. 40 CFR Part 60, Subparts AAA 

and QQQQ Estimated Three-Year and Annual Respondent Burden Cost of Reporting and Recordkeeping Requirements 

(Years 2018 to 2020). January 2015.

6 Comments on the proposed NSPS are available electronically through http://www.regulations.gov by searching Docket 

IDs EPA-HQ-OAR-2009-0734. See also the Response to Comment (RTC) document in the docket for this rulemaking.
3

II. Application of Emission Estimates to Cost Effectiveness Analysis

A. Baseline and NSPS emission estimates

As noted in our emissions memo, we multiplied our tons/appliance PM emission estimate by

the estimated number of shipments in each year to calculate total PM emissions from each appliance 

category per year. We made this calculation under baseline conditions (i.e., in the absence of this final

NSPS) and under the final NSPS. Furthermore, in order to not overstate emission reductions under the 

NSPS, baseline emissions were discounted by the estimated percentage of appliances already meeting 

the Step 2 PM limit (i.e., 26% of wood stoves, 70% of pellet stoves, and 18% of hydronic heaters are 

estimated to already meet Step 2, as noted in Section I.A).

 The emission estimates assume that the total number of shipped units meet the PM standard in 

the year the standard is implemented. Because our PM emission estimates assume that models do not 

come into compliance until the year they are required to, we do not claim PM emission reductions until 

each compliance year. This simplifying assumption means that we underestimated how soon PM 

emission reductions will happen under the final NSPS. In reality, some models will meet the NSPS 

Step 2 PM limit prior to the 2020 compliance year and will therefore be emitting less than baseline 

levels prior to that year.

Further, based on available data for wood stoves and pellet stoves, we assumed that baseline 

PM emissions for both of these appliance types are already at the Step 1 PM level. We therefore 

claimed no PM emission reductions for wood stoves and pellet stoves until the 2020 Step 2 compliance 

year. It should furthermore be noted that the assumption that at baseline all wood stoves already meet 

the Step 1 (Washington State) PM standard may slightly underestimate baseline emissions, as not 

100% of wood stoves currently sold do meet the Washington state PM standard. Finally, in our CE

analyses PM emission reductions for forced-air furnaces are not estimated to begin until the Step 1 PM 

limit is required in 2016, even though the work practice/operational standard required in 2015 will 

result in some (un-estimated) PM emissions reduction. We made these simplifying assumptions in 

order to avoid any potential for overstating PM baseline emissions and PM emissions reduction under 

the final NSPS.

B. Appliance Emitting Lifespan

As noted above, we used a 10-year model design lifespan for estimating costs. We also 

assumed a 20-year appliance emitting lifespan. This assumption was made to best characterize the 

actual use lifespan given that most stoves in consumer homes emit for at least 20 years and often much 

longer. Our CE analysis therefore tracks emission reductions out through 2048 (assuming a 20-year 

emitting life for an appliance shipped in year 2029). 

Our CE analysis incorporates “trailing emissions” as part of our 20 year lifespan assumptions. 

For example, our analysis assumes that a stove shipped in 2015 will emit in homes for 20 years – or 

until 2034 (inclusive of both 2015 and 2034). We therefore drop emissions from this stove in our 

analysis in year 2035. Likewise, we drop emissions for a stove shipped in 2016 in year 2036, and so 

on.
4

III. Resulting Cost Effectiveness Tables

Tables 1 through 8 show the results of our CE analyses based on PM2.5 reductions under the 

final NSPS for each appliance, for appliances grouped by subparts AAA (“room heaters”) and QQQQ 

(“central heaters”), and for Subparts AAA and QQQQ combined. Each table shown is based on 2013 

dollars (2010 dollars were used at proposal) and a 7% interest rate applied to the amortized costs 

during the 6-year R&D period. 

We also prepared estimates based on a 3% interest rate and these are presented in Tables 9 

through 16. 

In addition, we prepared both sets of tables based on volatile organic compound (VOC)

emission reductions and based on carbon monoxide (CO) emission reductions, although these 

pollutants do not have emission limits under the final NSPS. The VOC7and CO8cost effectiveness 

estimates are available in the docket. 

Finally, we prepared a sensitivity analysis in which we varied the GDP-based forecasted

growth rate, used as a proxy for growth in shipments, from 2.0% to 2.1%, 2.5% and 3.0%, which 

caused emission estimates and resulting cost effectiveness to vary. The CE tables associated with this 

sensitivity analysis are provided in Appendix A of this memo.

 

7

See January 2015 cost effectiveness (CE) spreadsheets for VOC entitled Revised Final Wood Heater NSPS VOC CE 7% 

and Revised Final Wood Heater NSPS VOC CE 3%, available in the public docket for this rulemaking.

8

See January 2015 cost effectiveness (CE) spreadsheets for CO entitled Revised Final Wood Heater NSPS CO CE 7% and

Revised Final Wood Heater NSPS CO CE 3% available in the public docket for this rulemaking
5

PM2.5 Cost Effectiveness Tables 1 through 8

These estimates are based on a 7% interest rate for amortized costs

and a 2% forecasted growth in shipments
6

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$5,566,638 $2,454,615 1,315 689 626 $3,922 1,315 689 626

2016 $5,566,638 $2,454,615 1,341 702 638 $3,845 2,655 1,391 1,264

2017 $5,566,638 $2,454,615 1,368 716 651 $3,769 4,023 2,108 1,916

2018 $5,269,325 $2,454,615 1,435 771 664 $3,695 5,458 2,879 2,580

2019 $5,269,325 $2,454,615 1,464 787 678 $3,623 6,922 3,665 3,257

2020 4$5,269,325 $2,454,615 1,493 410 1,084 $2,265 8,416 4,075 4,341

2021 $479,037 $2,454,615 1,523 418 1,105 $2,221 9,939 4,493 5,446

2022 $479,037 $2,454,615 1,554 426 1,127 $2,177 11,493 4,919 6,573

2023 $479,037 $2,454,615 1,585 435 1,150 $2,135 13,077 5,354 7,723

2024 $479,037 $2,454,615 1,616 444 1,173 $2,093 14,694 5,798 8,896

2025 $479,037 $2,454,615 1,649 452 1,196 $2,052 16,343 6,250 10,092

2026 $479,037 $2,454,615 1,682 462 1,220 $2,012 18,024 6,712 11,312

2027 $479,037 $2,454,615 1,715 471 1,245 $1,972 19,740 7,183 12,557

2028 $479,037 $2,454,615 1,750 480 1,270 $1,934 21,489 7,663 13,827

2029 $479,037 $2,454,615 1,785 490 1,295 $1,896 23,274 8,153 15,122

2030 23,274 8,153 15,122

2031 23,274 8,153 15,122

2032 23,274 8,153 15,122

2033 23,274 8,153 15,122

2034 23,274 8,153 15,122

2035 21,960 7,464 14,496

2036 20,619 6,761 13,857

2037 19,251 6,045 13,206

2038 17,816 5,274 12,542

2039 16,352 4,487 11,864

2040 14,858 4,078 10,781

2041 13,335 3,660 9,676

2042 11,781 3,233 8,548

2043 10,197 2,798 7,398

2044 8,580 2,355 6,226

2045 6,931 1,902 5,029

2046 5,250 1,441 3,809

2047 3,534 970 2,564

2048 1,785 490 1,295

$36,819,222 212,020 $174

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year

Table 1. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative 

cost5 

5

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

reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029.

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

4

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

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

models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 

2020.
7

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$3,024,928 $1,209,971 381 381 0 N/A 381 381 0

2016 $3,024,928 $1,209,971 389 389 0 N/A 770 770 0

2017 $3,024,928 $1,209,971 397 397 0 N/A 1,167 1,167 0

2018 $3,024,928 $1,209,971 445 445 0 N/A 1,612 1,612 0

2019 $3,024,928 $1,209,971 454 454 0 N/A 2,066 2,066 0

2020 4$3,024,928 $1,209,971 463 259 204 $5,932 2,529 2,325 204

2021 $0 $1,209,971 472 264 208 $5,816 3,001 2,589 412

2022 $0 $1,209,971 482 269 212 $5,702 3,483 2,859 624

2023 $0 $1,209,971 491 275 216 $5,590 3,974 3,134 841

2024 $0 $1,209,971 501 280 221 $5,480 4,475 3,414 1,061

2025 $0 $1,209,971 511 286 225 $5,373 4,987 3,700 1,287

2026 $0 $1,209,971 521 292 230 $5,267 5,508 3,992 1,516

2027 $0 $1,209,971 532 298 234 $5,164 6,040 4,289 1,751

2028 $0 $1,209,971 542 303 239 $5,063 6,582 4,593 1,990

2029 $0 $1,209,971 553 310 244 $4,964 7,136 4,902 2,233

2030 7,136 4,902 2,233

2031 7,136 4,902 2,233

2032 7,136 4,902 2,233

2033 7,136 4,902 2,233

2034 7,136 4,902 2,233

2035 6,754 4,521 2,233

2036 6,365 4,132 2,233

2037 5,969 3,735 2,233

2038 5,524 3,290 2,233

2039 5,070 2,836 2,233

2040 4,607 2,577 2,029

2041 4,134 2,313 1,821

2042 3,653 2,043 1,609

2043 3,161 1,769 1,393

2044 2,660 1,488 1,172

2045 2,149 1,202 947

2046 1,628 911 717

2047 1,096 613 483

2048 553 310 244

$18,149,566 34,983 $519

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

stoves already meet the Step 2 limit).

 Table 2. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total 

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

1

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

2048 are past the 10-year model design lifespan used in this analysis.

2

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

for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update

of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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 
8

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$1,484,192 $857,473 56 56 0 N/A 56 56 0

2016 $1,484,192 $857,473 57 57 0 N/A 114 114 0

2017 $1,484,192 $857,473 59 59 0 N/A 172 172 0

2018 $1,564,285 $857,473 60 60 0 N/A 232 232 0

2019 $1,564,285 $857,473 61 61 0 N/A 293 293 0

2020 4$1,564,285 $857,473 62 28 35 $24,853 355 320 35

2021 $412,963 $857,473 63 28 35 $24,366 418 348 70

2022 $412,963 $857,473 65 29 36 $23,888 483 377 106

2023 $412,963 $857,473 66 29 37 $23,419 549 406 142

2024 $412,963 $857,473 67 30 37 $22,960 616 436 180

2025 $412,963 $857,473 69 30 38 $22,510 684 467 218

2026 $412,963 $857,473 70 31 39 $22,069 754 498 256

2027 $412,963 $857,473 71 32 40 $21,636 826 530 296

2028 $412,963 $857,473 73 32 40 $21,212 899 562 337

2029 $412,963 $857,473 74 33 41 $20,796 973 595 378

2030 973 595 378

2031 973 595 378

2032 973 595 378

2033 973 595 378

2034 973 595 378

2035 916 539 378

2036 859 481 378

2037 801 423 378

2038 741 363 378

2039 680 302 378

2040 618 275 343

2041 555 246 308

2042 490 218 272

2043 424 188 236

2044 357 159 198

2045 288 128 160

2046 218 97 121

2047 147 65 82

2048 74 33 41

$12,862,099 5,917 $2,174

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).

Table 3. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are

estimated until Step 2 in 2020.

5

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

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

CE based on total 

cost & cumulative 

emission reduction 

over 20-year

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year stove 

lifespan 
9

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

2015 4$1,057,518 $387,171 877 251 626 $619 877 251 626

2016 $1,057,518 $387,171 895 256 638 $606 1,771 507 1,264

2017 $1,057,518 $387,171 912 261 651 $595 2,684 768 1,916

2018 $680,112 $387,171 931 266 664 $583 3,614 1,035 2,580

2019 $680,112 $387,171 949 272 678 $571 4,564 1,306 3,257

2020 4$680,112 $387,171 968 123 845 $458 5,532 1,430 4,102

2021 $66,074 $387,171 988 126 862 $449 6,520 1,555 4,964

2022 $66,074 $387,171 1,007 128 879 $440 7,527 1,683 5,843

2023 $66,074 $387,171 1,027 131 897 $432 8,554 1,814 6,740

2024 $66,074 $387,171 1,048 133 915 $423 9,602 1,948 7,655

2025 $66,074 $387,171 1,069 136 933 $415 10,671 2,084 8,588

2026 $66,074 $387,171 1,090 139 952 $407 11,762 2,222 9,540

2027 $66,074 $387,171 1,112 142 971 $399 12,874 2,364 10,510

2028 $66,074 $387,171 1,134 144 990 $391 14,009 2,508 11,500

2029 $66,074 $387,171 1,157 147 1,010 $383 15,166 2,655 12,510

2030 15,166 2,655 12,510

2031 15,166 2,655 12,510

2032 15,166 2,655 12,510

2033 15,166 2,655 12,510

2034 15,166 2,655 12,510

2035 14,289 2,404 11,884

2036 13,394 2,148 11,246

2037 12,482 1,887 10,595

2038 11,551 1,621 9,931

2039 10,602 1,349 9,253

2040 9,634 1,226 8,408

2041 8,646 1,100 7,546

2042 7,639 972 6,667

2043 6,611 841 5,770

2044 5,563 708 4,855

2045 4,494 572 3,922

2046 3,404 433 2,971

2047 2,292 292 2,000

2048 1,157 147 1,010

$5,807,558 171,119 $34

Table 4. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

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

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

this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
10

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average 

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$45,761,061 $16,620,786 10,299 7,008 3,291 $5,051 10,299 7,008 3,291

2016 4$45,761,061 $16,620,786 10,505 5,878 4,627 $3,592 20,804 12,887 7,918

2017 4$37,432,168 $16,620,786 10,715 2,108 8,607 $1,931 31,520 14,995 16,525

2018 $37,488,168 $16,620,786 10,930 2,150 8,779 $1,893 42,449 17,145 25,304

2019 $37,488,168 $16,620,786 11,148 2,193 8,955 $1,856 53,598 19,339 34,259

2020 4$37,488,168 $16,620,786 11,371 355 11,016 $1,509 64,969 19,694 45,275

2021 $877,000 $16,620,786 11,599 362 11,236 $1,479 76,567 20,056 56,511

2022 $877,000 $16,620,786 11,831 370 11,461 $1,450 88,398 20,426 67,972

2023 $877,000 $16,620,786 12,067 377 11,690 $1,422 100,465 20,803 79,662

2024 $877,000 $16,620,786 12,309 385 11,924 $1,394 112,774 21,188 91,586

2025 $877,000 $16,620,786 12,555 392 12,162 $1,367 125,329 21,580 103,748

2026 $877,000 $16,620,786 12,806 400 12,406 $1,340 138,134 21,980 116,154

2027 $877,000 $16,620,786 13,062 408 12,654 $1,314 151,196 22,389 128,808

2028 $877,000 $16,620,786 13,323 416 12,907 $1,288 164,519 22,805 141,714

2029 $877,000 $16,620,786 13,590 425 13,165 $1,263 178,109 23,230 154,879

2030 178,109 23,230 154,879

2031 178,109 23,230 154,879

2032 178,109 23,230 154,879

2033 178,109 23,230 154,879

2034 178,109 23,230 154,879

2035 167,810 16,221 151,589

2036 157,305 10,343 146,962

2037 146,589 8,235 138,355

2038 135,660 6,084 129,575

2039 124,511 3,891 120,620

2040 113,140 3,536 109,605

2041 101,542 3,173 98,368

2042 89,711 2,803 86,908

2043 77,644 2,426 75,217

2044 65,335 2,042 63,294

2045 52,781 1,649 51,131

2046 39,975 1,249 38,726

2047 326,913 841 26,072

2048 313,590 425 13,165

$249,311,792 2,178,862 $114

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

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

Year (per ton) 3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

hydronic heaters are estimated to already meet the Step 2 limit).

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
11

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average 

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2015 4$20,905,663 $6,299,286 6,643 6,643 0 N/A 6,643 6,643 0

2016 4$20,905,663 $6,299,286 6,776 5,505 1,270 $4,958 13,419 12,148 1,270

2017 4$12,576,770 $6,299,286 6,911 1,728 5,183 $1,215 20,330 13,876 6,454

2018 $12,593,240 $6,299,286 7,049 1,762 5,287 $1,191 27,379 15,638 11,741

2019 $12,593,240 $6,299,286 7,190 1,798 5,393 $1,168 34,570 17,436 17,134

2020 4$12,593,240 $6,299,286 7,334 229 7,105 $887 41,904 17,665 24,239

2021 $257,941 $6,299,286 7,481 234 7,247 $869 49,385 17,899 31,486

2022 $257,941 $6,299,286 7,631 238 7,392 $852 57,015 18,137 38,878

2023 $257,941 $6,299,286 7,783 243 7,540 $835 64,798 18,381 46,418

2024 $257,941 $6,299,286 7,939 248 7,691 $819 72,737 18,629 54,109

2025 $257,941 $6,299,286 8,098 253 7,845 $803 80,835 18,882 61,953

2026 $257,941 $6,299,286 8,260 258 8,001 $787 89,094 19,140 69,955

2027 $257,941 $6,299,286 8,425 263 8,161 $772 97,519 19,403 78,116

2028 $257,941 $6,299,286 8,593 269 8,325 $757 106,112 19,672 86,441

2029 $257,941 $6,299,286 8,765 274 8,491 $742 114,877 19,945 94,932

2030 114,877 19,945 94,932

2031 114,877 19,945 94,932

2032 114,877 19,945 94,932

2033 114,877 19,945 94,932

2034 114,877 19,945 94,932

2035 108,235 13,303 94,932

2036 101,459 7,797 93,662

2037 94,548 6,070 88,478

2038 87,498 4,307 83,191

2039 80,308 2,510 77,798

2040 72,974 2,280 70,693

2041 65,493 2,047 63,446

2042 57,862 1,808 56,054

2043 50,079 1,565 48,514

2044 42,140 1,317 40,823

2045 34,043 1,064 32,979

2046 25,783 806 24,977

2047 17,358 542 16,816

2048 8,765 274 8,491

$94,489,287 1,370,447 $69

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 

Table 6. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
12

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$24,855,398 $10,321,500.34 3,656 366 3,291 $3,137 3,656 366 3,291

2016 $24,855,398 $10,321,500.34 3,730 373 3,357 $3,075 7,386 739 6,647

2017 $24,855,398 $10,321,500.34 3,804 380 3,424 $3,015 11,190 1,119 10,071

2018 $24,894,927 $10,321,500.34 3,880 388 3,492 $2,956 15,070 1,507 13,563

2019 $24,894,927 $10,321,500.34 3,958 396 3,562 $2,898 19,028 1,903 17,125

2020 4$24,894,927 $10,321,500.34 4,037 126 3,911 $2,639 23,065 2,029 21,036

2021 $619,059 $10,321,500.34 4,118 129 3,989 $2,587 27,183 2,158 25,025

2022 $619,059 $10,321,500.34 4,200 131 4,069 $2,537 31,383 2,289 29,094

2023 $619,059 $10,321,500.34 4,284 134 4,150 $2,487 35,667 2,423 33,244

2024 $619,059 $10,321,500.34 4,370 137 4,233 $2,438 40,037 2,559 37,477

2025 $619,059 $10,321,500.34 4,457 139 4,318 $2,390 44,494 2,699 41,795

2026 $619,059 $10,321,500.34 4,546 142 4,404 $2,344 49,040 2,841 46,199

2027 $619,059 $10,321,500.34 4,637 145 4,492 $2,298 53,677 2,986 50,692

2028 $619,059 $10,321,500.34 4,730 148 4,582 $2,253 58,407 3,133 55,274

2029 $619,059 $10,321,500.34 4,825 151 4,674 $2,208 63,232 3,284 59,947

2030 63,232 3,284 59,947

2031 63,232 3,284 59,947

2032 63,232 3,284 59,947

2033 63,232 3,284 59,947

2034 63,232 3,284 59,947

2035 59,575 2,919 56,657

2036 55,846 2,546 53,300

2037 52,042 2,165 49,876

2038 48,161 1,777 46,384

2039 44,204 1,381 42,822

2040 40,167 1,255 38,911

2041 36,049 1,127 34,922

2042 31,849 995 30,854

2043 27,565 861 26,703

2044 23,195 725 22,470

2045 18,738 586 18,152

2046 14,192 443 13,748

2047 39,554 299 9,256

2048 34,825 151 4,674

$154,822,505 808,415 $192

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).

Table 7. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
13

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average 

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$51,327,699 $19,075,401 11,614 7,697 3,917 $4,870 11,614 7,697 3,917

2016 4$51,327,699 $19,075,401 11,846 6,581 5,265 $3,623 23,460 14,278 9,182

2017 4$42,998,805 $19,075,401 12,083 2,825 9,258 $2,060 35,543 17,102 18,440

2018 $42,757,493 $19,075,401 12,365 2,922 9,443 $2,020 47,908 20,024 27,884

2019 $42,757,493 $19,075,401 12,612 2,980 9,632 $1,980 60,520 23,004 37,516

2020 4$42,757,493 $19,075,401 12,865 765 12,099 $1,577 73,385 23,769 49,616

2021 $1,356,037 $19,075,401 13,122 780 12,341 $1,546 86,507 24,550 61,957

2022 $1,356,037 $19,075,401 13,384 796 12,588 $1,515 99,891 25,346 74,545

2023 $1,356,037 $19,075,401 13,652 812 12,840 $1,486 113,543 26,158 87,385

2024 $1,356,037 $19,075,401 13,925 828 13,097 $1,456 127,468 26,986 100,482

2025 $1,356,037 $19,075,401 14,203 845 13,359 $1,428 141,671 27,831 113,841

2026 $1,356,037 $19,075,401 14,488 862 13,626 $1,400 156,159 28,692 127,466

2027 $1,356,037 $19,075,401 14,777 879 13,898 $1,372 170,936 29,571 141,365

2028 $1,356,037 $19,075,401 15,073 897 14,176 $1,346 186,009 30,468 155,541

2029 $1,356,037 $19,075,401 15,374 914 14,460 $1,319 201,383 31,382 170,001

2030 201,383 31,382 170,001

2031 201,383 31,382 170,001

2032 201,383 31,382 170,001

2033 201,383 31,382 170,001

2034 201,383 31,382 170,001

2035 189,769 23,685 166,084

2036 177,923 17,104 160,819

2037 165,840 14,280 151,561

2038 153,475 11,358 142,117

2039 140,863 8,378 132,485

2040 127,998 7,613 120,385

2041 114,877 6,833 108,044

2042 101,492 6,037 95,456

2043 87,840 5,225 82,616

2044 73,915 4,396 69,519

2045 59,712 3,552 56,160

2046 45,224 2,690 42,535

2047 3 30,447 1,811 28,636

2048 315,374 914 14,460

$286,131,014 2,390,882 $120

Nationwide 

Average

Annual Cost 

Annual Snapshots

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit

(i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Table 8. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room 

Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Emission Reduction, cumulative per year

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

Year 

3

Nationwide 

Annual Cost1 
14

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15

PM2.5 Cost Effectiveness Tables 9 through 16

These estimates are based on a 3% interest rate for amortized costs

and a 2% forecasted growth in shipments
16

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$4,930,601 $2,209,574 1,315 689 626 $3,530 1,315 689 626

2016 $4,930,601 $2,209,574 1,341 702 638 $3,461 2,655 1,391 1,264

2017 $4,930,601 $2,209,574 1,368 716 651 $3,393 4,023 2,108 1,916

2018 $4,680,157 $2,209,574 1,435 771 664 $3,327 5,458 2,879 2,580

2019 $4,680,157 $2,209,574 1,464 787 678 $3,261 6,922 3,665 3,257

2020 4$4,680,157 $2,209,574 1,493 410 1,084 $2,039 8,416 4,075 4,341

2021 $479,037 $2,209,574 1,523 418 1,105 $1,999 9,939 4,493 5,446

2022 $479,037 $2,209,574 1,554 426 1,127 $1,960 11,493 4,919 6,573

2023 $479,037 $2,209,574 1,585 435 1,150 $1,922 13,077 5,354 7,723

2024 $479,037 $2,209,574 1,616 444 1,173 $1,884 14,694 5,798 8,896

2025 $479,037 $2,209,574 1,649 452 1,196 $1,847 16,343 6,250 10,092

2026 $479,037 $2,209,574 1,682 462 1,220 $1,811 18,024 6,712 11,312

2027 $479,037 $2,209,574 1,715 471 1,245 $1,775 19,740 7,183 12,557

2028 $479,037 $2,209,574 1,750 480 1,270 $1,740 21,489 7,663 13,827

2029 $479,037 $2,209,574 1,785 490 1,295 $1,706 23,274 8,153 15,122

2030 23,274 8,153 15,122

2031 23,274 8,153 15,122

2032 23,274 8,153 15,122

2033 23,274 8,153 15,122

2034 23,274 8,153 15,122

2035 21,960 7,464 14,496

2036 20,619 6,761 13,857

2037 19,251 6,045 13,206

2038 17,816 5,274 12,542

2039 16,352 4,487 11,864

2040 14,858 4,078 10,781

2041 13,335 3,660 9,676

2042 11,781 3,233 8,548

2043 10,197 2,798 7,398

2044 8,580 2,355 6,226

2045 6,931 1,902 5,029

2046 5,250 1,441 3,809

2047 3,534 970 2,564

2048 1,785 490 1,295

$33,143,609 212,020 $156

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year

Table 9. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative

cost5 

5

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

reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029.

Year 

3

Nationwide

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

4

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

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

models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 

2020.
17

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$2,661,608 $1,064,643 381 381 0 N/A 381 381 0

2016 $2,661,608 $1,064,643 389 389 0 N/A 770 770 0

2017 $2,661,608 $1,064,643 397 397 0 N/A 1,167 1,167 0

2018 $2,661,608 $1,064,643 445 445 0 N/A 1,612 1,612 0

2019 $2,661,608 $1,064,643 454 454 0 N/A 2,066 2,066 0

2020 4$2,661,608 $1,064,643 463 259 204 $5,219 2,529 2,325 204

2021 $0 $1,064,643 472 264 208 $5,117 3,001 2,589 412

2022 $0 $1,064,643 482 269 212 $5,017 3,483 2,859 624

2023 $0 $1,064,643 491 275 216 $4,918 3,974 3,134 841

2024 $0 $1,064,643 501 280 221 $4,822 4,475 3,414 1,061

2025 $0 $1,064,643 511 286 225 $4,727 4,987 3,700 1,287

2026 $0 $1,064,643 521 292 230 $4,635 5,508 3,992 1,516

2027 $0 $1,064,643 532 298 234 $4,544 6,040 4,289 1,751

2028 $0 $1,064,643 542 303 239 $4,455 6,582 4,593 1,990

2029 $0 $1,064,643 553 310 244 $4,367 7,136 4,902 2,233

2030 7,136 4,902 2,233

2031 7,136 4,902 2,233

2032 7,136 4,902 2,233

2033 7,136 4,902 2,233

2034 7,136 4,902 2,233

2035 6,754 4,521 2,233

2036 6,365 4,132 2,233

2037 5,969 3,735 2,233

2038 5,524 3,290 2,233

2039 5,070 2,836 2,233

2040 4,607 2,577 2,029

2041 4,134 2,313 1,821

2042 3,653 2,043 1,609

2043 3,161 1,769 1,393

2044 2,660 1,488 1,172

2045 2,149 1,202 947

2046 1,628 911 717

2047 1,096 613 483

2048 553 310 244

$15,969,645 34,983 $456

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

stoves already meet the Step 2 limit).

 Table 10. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% 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 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update

of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

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 
18

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$1,336,900 $798,556 56 56 0 N/A 56 56 0

2016 $1,336,900 $798,556 57 57 0 N/A 114 114 0

2017 $1,336,900 $798,556 59 59 0 N/A 172 172 0

2018 $1,416,993 $798,556 60 60 0 N/A 232 232 0

2019 $1,416,993 $798,556 61 61 0 N/A 293 293 0

2020 4$1,416,993 $798,556 62 28 35 $23,145 355 320 35

2021 $412,963 $798,556 63 28 35 $22,691 418 348 70

2022 $412,963 $798,556 65 29 36 $22,247 483 377 106

2023 $412,963 $798,556 66 29 37 $21,810 549 406 142

2024 $412,963 $798,556 67 30 37 $21,383 616 436 180

2025 $412,963 $798,556 69 30 38 $20,963 684 467 218

2026 $412,963 $798,556 70 31 39 $20,552 754 498 256

2027 $412,963 $798,556 71 32 40 $20,149 826 530 296

2028 $412,963 $798,556 73 32 40 $19,754 899 562 337

2029 $412,963 $798,556 74 33 41 $19,367 973 595 378

2030 973 595 378

2031 973 595 378

2032 973 595 378

2033 973 595 378

2034 973 595 378

2035 916 539 378

2036 859 481 378

2037 801 423 378

2038 741 363 378

2039 680 302 378

2040 618 275 343

2041 555 246 308

2042 490 218 272

2043 424 188 236

2044 357 159 198

2045 288 128 160

2046 218 97 121

2047 147 65 82

2048 74 33 41

$11,978,347 5,917 $2,024

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).

Table 11. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are

estimated until Step 2 in 2020.

5

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 
19

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

2015 4$932,093 $346,374 877 251 626 $553 877 251 626

2016 $932,093 $346,374 895 256 638 $543 1,771 507 1,264

2017 $932,093 $346,374 912 261 651 $532 2,684 768 1,916

2018 $601,557 $346,374 931 266 664 $521 3,614 1,035 2,580

2019 $601,557 $346,374 949 272 678 $511 4,564 1,306 3,257

2020 4$601,557 $346,374 968 123 845 $410 5,532 1,430 4,102

2021 $66,074 $346,374 988 126 862 $402 6,520 1,555 4,964

2022 $66,074 $346,374 1,007 128 879 $394 7,527 1,683 5,843

2023 $66,074 $346,374 1,027 131 897 $386 8,554 1,814 6,740

2024 $66,074 $346,374 1,048 133 915 $379 9,602 1,948 7,655

2025 $66,074 $346,374 1,069 136 933 $371 10,671 2,084 8,588

2026 $66,074 $346,374 1,090 139 952 $364 11,762 2,222 9,540

2027 $66,074 $346,374 1,112 142 971 $357 12,874 2,364 10,510

2028 $66,074 $346,374 1,134 144 990 $350 14,009 2,508 11,500

2029 $66,074 $346,374 1,157 147 1,010 $343 15,166 2,655 12,510

2030 15,166 2,655 12,510

2031 15,166 2,655 12,510

2032 15,166 2,655 12,510

2033 15,166 2,655 12,510

2034 15,166 2,655 12,510

2035 14,289 2,404 11,884

2036 13,394 2,148 11,246

2037 12,482 1,887 10,595

2038 11,551 1,621 9,931

2039 10,602 1,349 9,253

2040 9,634 1,226 8,408

2041 8,646 1,100 7,546

2042 7,639 972 6,667

2043 6,611 841 5,770

2044 5,563 708 4,855

2045 4,494 572 3,922

2046 3,404 433 2,971

2047 2,292 292 2,000

2048 1,157 147 1,010

$5,195,617 171,119 $30

Table 12. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% 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 2.0% from 2015 through 2029, in keeping with the average 

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year

emitting lifespan 
20

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$40,292,072 $14,699,957 10,299 7,008 3,291 $4,467 10,299 7,008 3,291

2016 4$40,292,072 $14,699,957 10,505 5,878 4,627 $3,177 20,804 12,887 7,918

2017 4$32,963,552 $14,699,957 10,715 2,108 8,607 $1,708 31,520 14,995 16,525

2018 $33,019,552 $14,699,957 10,930 2,150 8,779 $1,674 42,449 17,145 25,304

2019 $33,019,552 $14,699,957 11,148 2,193 8,955 $1,642 53,598 19,339 34,259

2020 4$33,019,552 $14,699,957 11,371 355 11,016 $1,334 64,969 19,694 45,275

2021 $877,000 $14,699,957 11,599 362 11,236 $1,308 76,567 20,056 56,511

2022 $877,000 $14,699,957 11,831 370 11,461 $1,283 88,398 20,426 67,972

2023 $877,000 $14,699,957 12,067 377 11,690 $1,257 100,465 20,803 79,662

2024 $877,000 $14,699,957 12,309 385 11,924 $1,233 112,774 21,188 91,586

2025 $877,000 $14,699,957 12,555 392 12,162 $1,209 125,329 21,580 103,748

2026 $877,000 $14,699,957 12,806 400 12,406 $1,185 138,134 21,980 116,154

2027 $877,000 $14,699,957 13,062 408 12,654 $1,162 151,196 22,389 128,808

2028 $877,000 $14,699,957 13,323 416 12,907 $1,139 164,519 22,805 141,714

2029 $877,000 $14,699,957 13,590 425 13,165 $1,117 178,109 23,230 154,879

2030 178,109 23,230 154,879

2031 178,109 23,230 154,879

2032 178,109 23,230 154,879

2033 178,109 23,230 154,879

2034 178,109 23,230 154,879

2035 167,810 16,221 151,589

2036 157,305 10,343 146,962

2037 146,589 8,235 138,355

2038 135,660 6,084 129,575

2039 124,511 3,891 120,620

2040 113,140 3,536 109,605

2041 101,542 3,173 98,368

2042 89,711 2,803 86,908

2043 77,644 2,426 75,217

2044 65,335 2,042 63,294

2045 52,781 1,649 51,131

2046 39,975 1,249 38,726

2047 326,913 841 26,072

2048 313,590 425 13,165

$220,499,351 2,178,862 $101

Table 13. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

Year (per ton) 3

Nationwide 

Annual Cost1 

Nationwide

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

hydronic heaters are estimated to already meet the Step 2 limit).

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
21

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2015 4$18,399,692 $5,563,663 6,643 6,643 0 N/A 6,643 6,643 0

2016 4$18,399,692 $5,563,663 6,776 5,505 1,270 $4,379 13,419 12,148 1,270

2017 4$11,071,171 $5,563,663 6,911 1,728 5,183 $1,073 20,330 13,876 6,454

2018 $11,087,642 $5,563,663 7,049 1,762 5,287 $1,052 27,379 15,638 11,741

2019 $11,087,642 $5,563,663 7,190 1,798 5,393 $1,032 34,570 17,436 17,134

2020 4$11,087,642 $5,563,663 7,334 229 7,105 $783 41,904 17,665 24,239

2021 $257,941 $5,563,663 7,481 234 7,247 $768 49,385 17,899 31,486

2022 $257,941 $5,563,663 7,631 238 7,392 $753 57,015 18,137 38,878

2023 $257,941 $5,563,663 7,783 243 7,540 $738 64,798 18,381 46,418

2024 $257,941 $5,563,663 7,939 248 7,691 $723 72,737 18,629 54,109

2025 $257,941 $5,563,663 8,098 253 7,845 $709 80,835 18,882 61,953

2026 $257,941 $5,563,663 8,260 258 8,001 $695 89,094 19,140 69,955

2027 $257,941 $5,563,663 8,425 263 8,161 $682 97,519 19,403 78,116

2028 $257,941 $5,563,663 8,593 269 8,325 $668 106,112 19,672 86,441

2029 $257,941 $5,563,663 8,765 274 8,491 $655 114,877 19,945 94,932

2030 114,877 19,945 94,932

2031 114,877 19,945 94,932

2032 114,877 19,945 94,932

2033 114,877 19,945 94,932

2034 114,877 19,945 94,932

2035 108,235 13,303 94,932

2036 101,459 7,797 93,662

2037 94,548 6,070 88,478

2038 87,498 4,307 83,191

2039 80,308 2,510 77,798

2040 72,974 2,280 70,693

2041 65,493 2,047 63,446

2042 57,862 1,808 56,054

2043 50,079 1,565 48,514

2044 42,140 1,317 40,823

2045 34,043 1,064 32,979

2046 25,783 806 24,977

2047 17,358 542 16,816

2048 8,765 274 8,491

$83,454,951 1,370,447 $61

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 

Table 14. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
22

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$21,892,380 $9,136,293.29 3,656 366 3,291 $2,776 3,656 366 3,291

2016 $21,892,380 $9,136,293.29 3,730 373 3,357 $2,722 7,386 739 6,647

2017 $21,892,380 $9,136,293.29 3,804 380 3,424 $2,669 11,190 1,119 10,071

2018 $21,931,910 $9,136,293.29 3,880 388 3,492 $2,616 15,070 1,507 13,563

2019 $21,931,910 $9,136,293.29 3,958 396 3,562 $2,565 19,028 1,903 17,125

2020 4$21,931,910 $9,136,293.29 4,037 126 3,911 $2,336 23,065 2,029 21,036

2021 $619,059 $9,136,293.29 4,118 129 3,989 $2,290 27,183 2,158 25,025

2022 $619,059 $9,136,293.29 4,200 131 4,069 $2,245 31,383 2,289 29,094

2023 $619,059 $9,136,293.29 4,284 134 4,150 $2,201 35,667 2,423 33,244

2024 $619,059 $9,136,293.29 4,370 137 4,233 $2,158 40,037 2,559 37,477

2025 $619,059 $9,136,293.29 4,457 139 4,318 $2,116 44,494 2,699 41,795

2026 $619,059 $9,136,293.29 4,546 142 4,404 $2,074 49,040 2,841 46,199

2027 $619,059 $9,136,293.29 4,637 145 4,492 $2,034 53,677 2,986 50,692

2028 $619,059 $9,136,293.29 4,730 148 4,582 $1,994 58,407 3,133 55,274

2029 $619,059 $9,136,293.29 4,825 151 4,674 $1,955 63,232 3,284 59,947

2030 63,232 3,284 59,947

2031 63,232 3,284 59,947

2032 63,232 3,284 59,947

2033 63,232 3,284 59,947

2034 63,232 3,284 59,947

2035 59,575 2,919 56,657

2036 55,846 2,546 53,300

2037 52,042 2,165 49,876

2038 48,161 1,777 46,384

2039 44,204 1,381 42,822

2040 40,167 1,255 38,911

2041 36,049 1,127 34,922

2042 31,849 995 30,854

2043 27,565 861 26,703

2044 23,195 725 22,470

2045 18,738 586 18,152

2046 14,192 443 13,748

2047 39,554 299 9,256

2048 34,825 151 4,674

$137,044,399 808,415 $170

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).

Table 15. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% 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 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

Year

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
23

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$45,222,674 $16,909,531 11,614 7,697 3,917 $4,317 11,614 7,697 3,917

2016 4$45,222,674 $16,909,531 11,846 6,581 5,265 $3,211 23,460 14,278 9,182

2017 4$37,894,153 $16,909,531 12,083 2,825 9,258 $1,826 35,543 17,102 18,440

2018 $37,699,709 $16,909,531 12,365 2,922 9,443 $1,791 47,908 20,024 27,884

2019 $37,699,709 $16,909,531 12,612 2,980 9,632 $1,755 60,520 23,004 37,516

2020 4$37,699,709 $16,909,531 12,865 765 12,099 $1,398 73,385 23,769 49,616

2021 $1,356,037 $16,909,531 13,122 780 12,341 $1,370 86,507 24,550 61,957

2022 $1,356,037 $16,909,531 13,384 796 12,588 $1,343 99,891 25,346 74,545

2023 $1,356,037 $16,909,531 13,652 812 12,840 $1,317 113,543 26,158 87,385

2024 $1,356,037 $16,909,531 13,925 828 13,097 $1,291 127,468 26,986 100,482

2025 $1,356,037 $16,909,531 14,203 845 13,359 $1,266 141,671 27,831 113,841

2026 $1,356,037 $16,909,531 14,488 862 13,626 $1,241 156,159 28,692 127,466

2027 $1,356,037 $16,909,531 14,777 879 13,898 $1,217 170,936 29,571 141,365

2028 $1,356,037 $16,909,531 15,073 897 14,176 $1,193 186,009 30,468 155,541

2029 $1,356,037 $16,909,531 15,374 914 14,460 $1,169 201,383 31,382 170,001

2030 201,383 31,382 170,001

2031 201,383 31,382 170,001

2032 201,383 31,382 170,001

2033 201,383 31,382 170,001

2034 201,383 31,382 170,001

2035 189,769 23,685 166,084

2036 177,923 17,104 160,819

2037 165,840 14,280 151,561

2038 153,475 11,358 142,117

2039 140,863 8,378 132,485

2040 127,998 7,613 120,385

2041 114,877 6,833 108,044

2042 101,492 6,037 95,456

2043 87,840 5,225 82,616

2044 73,915 4,396 69,519

2045 59,712 3,552 56,160

2046 45,224 2,690 42,535

2047 3 30,447 1,811 28,636

2048 315,374 914 14,460

$253,642,960 2,390,882 $106

Nationwide

Average

Annual Cost 

Annual Snapshots

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average

annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit

(i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Table 16. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room 

Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Emission Reduction, cumulative per year

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

Year 

3

Nationwide 

Annual Cost1 
24

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A-0

Appendix A

Sensitivity Analysis: Growth in shipments 

The following cost effectiveness (CE) tables are based on varying the forecasted growth in shipments

and therefore emissions. The sensitivity analysis uses growth rates of 2.1%, 2.5% and 3.0%. A growth rate of 

2.0% is used for our final emission and CE estimates described in the body of this memo. All sensitivity

analysis estimates are based on a 7% interest rate for amortized costs.

 Tables A-1 through A-8 are based on a forecasted growth in shipments and emissions of 2.1%

 Tables A-9 through A-16 are based on a forecasted growth in shipments and emissions of 2.5%

 Tables A-17 through A-24 are based on a forecasted growth in shipments and emissions of 3.0%
A-1

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$5,566,638 $2,454,615 1,321 692 629 $3,903 1,321 692 629

2016 $5,566,638 $2,454,615 1,349 707 642 $3,822 2,670 1,399 1,271

2017 $5,566,638 $2,454,615 1,377 721 656 $3,744 4,047 2,120 1,927

2018 $5,269,325 $2,454,615 1,443 774 669 $3,667 5,490 2,894 2,596

2019 $5,269,325 $2,454,615 1,473 790 684 $3,591 6,963 3,684 3,280

2020 4$5,269,325 $2,454,615 1,504 412 1,093 $2,247 8,468 4,095 4,372

2021 $479,037 $2,454,615 1,536 420 1,116 $2,200 10,004 4,516 5,488

2022 $479,037 $2,454,615 1,568 429 1,139 $2,155 11,572 4,945 6,627

2023 $479,037 $2,454,615 1,601 438 1,163 $2,111 13,173 5,383 7,790

2024 $479,037 $2,454,615 1,635 448 1,187 $2,067 14,808 5,831 8,977

2025 $479,037 $2,454,615 1,669 457 1,212 $2,025 16,477 6,288 10,189

2026 $479,037 $2,454,615 1,704 466 1,238 $1,983 18,181 6,754 11,427

2027 $479,037 $2,454,615 1,740 476 1,264 $1,942 19,921 7,231 12,691

2028 $479,037 $2,454,615 1,777 486 1,290 $1,902 21,698 7,717 13,981

2029 $479,037 $2,454,615 1,814 497 1,317 $1,863 23,512 8,213 15,298

2030 23,512 8,213 15,298

2031 23,512 8,213 15,298

2032 23,512 8,213 15,298

2033 23,512 8,213 15,298

2034 23,512 8,213 15,298

2035 22,191 7,521 14,669

2036 20,842 6,815 14,027

2037 19,465 6,093 13,371

2038 18,022 5,320 12,702

2039 16,548 4,530 12,018

2040 15,044 4,118 10,926

2041 13,508 3,698 9,810

2042 11,940 3,268 8,671

2043 10,338 2,830 7,508

2044 8,704 2,382 6,321

2045 7,034 1,926 5,109

2046 5,330 1,459 3,871

2047 3,590 983 2,608

2048 1,814 497 1,317

$36,819,222 214,718 $171

Table A-1. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative

cost5 

5

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

reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029.

Year 

3

Nationwide

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis. 

4

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

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

models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 

2020.

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year
A-2

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$3,024,928 $1,209,971 383 383 0 N/A 383 383 0

2016 $3,024,928 $1,209,971 391 391 0 N/A 775 775 0

2017 $3,024,928 $1,209,971 399 399 0 N/A 1,174 1,174 0

2018 $3,024,928 $1,209,971 445 445 0 N/A 1,619 1,619 0

2019 $3,024,928 $1,209,971 454 454 0 N/A 2,073 2,073 0

2020 4$3,024,928 $1,209,971 464 260 204 $5,920 2,537 2,333 204

2021 $0 $1,209,971 474 265 209 $5,799 3,011 2,598 413

2022 $0 $1,209,971 484 271 213 $5,679 3,495 2,868 626

2023 $0 $1,209,971 494 276 218 $5,563 3,988 3,145 844

2024 $0 $1,209,971 504 282 222 $5,448 4,492 3,427 1,066

2025 $0 $1,209,971 515 288 227 $5,336 5,007 3,715 1,292

2026 $0 $1,209,971 526 294 232 $5,226 5,533 4,009 1,524

2027 $0 $1,209,971 537 300 236 $5,119 6,069 4,309 1,760

2028 $0 $1,209,971 548 306 241 $5,014 6,617 4,615 2,002

2029 $0 $1,209,971 559 313 246 $4,910 7,176 4,928 2,248

2030 7,176 4,928 2,248

2031 7,176 4,928 2,248

2032 7,176 4,928 2,248

2033 7,176 4,928 2,248

2034 7,176 4,928 2,248

2035 6,793 4,545 2,248

2036 6,402 4,154 2,248

2037 6,002 3,754 2,248

2038 5,557 3,309 2,248

2039 5,103 2,855 2,248

2040 4,639 2,595 2,044

2041 4,165 2,330 1,835

2042 3,682 2,060 1,622

2043 3,188 1,784 1,404

2044 2,684 1,501 1,182

2045 2,169 1,214 956

2046 1,644 920 724

2047 1,107 619 488

2048 559 313 246

$18,149,566 35,231 $515

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 

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

stoves already meet the Step 2 limit).

 Table A-2. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020 ). 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis. 
A-3

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$1,484,192 $857,473 57 57 0 N/A 57 57 0

2016 $1,484,192 $857,473 58 58 0 N/A 114 114 0

2017 $1,484,192 $857,473 59 59 0 N/A 173 173 0

2018 $1,564,285 $857,473 60 60 0 N/A 233 233 0

2019 $1,564,285 $857,473 61 61 0 N/A 295 295 0

2020 4$1,564,285 $857,473 63 28 35 $24,611 357 323 35

2021 $412,963 $857,473 64 28 36 $24,104 421 351 70

2022 $412,963 $857,473 65 29 36 $23,609 487 380 107

2023 $412,963 $857,473 67 30 37 $23,123 554 410 144

2024 $412,963 $857,473 68 30 38 $22,647 622 440 182

2025 $412,963 $857,473 70 31 39 $22,182 691 471 220

2026 $412,963 $857,473 71 32 39 $21,725 762 503 260

2027 $412,963 $857,473 73 32 40 $21,279 835 535 300

2028 $412,963 $857,473 74 33 41 $20,841 909 568 341

2029 $412,963 $857,473 76 34 42 $20,412 985 601 383

2030 985 601 383

2031 985 601 383

2032 985 601 383

2033 985 601 383

2034 985 601 383

2035 928 545 383

2036 870 487 383

2037 811 428 383

2038 751 368 383

2039 690 307 383

2040 627 279 348

2041 563 250 313

2042 498 221 277

2043 431 192 239

2044 363 161 202

2045 293 130 163

2046 222 99 123

2047 150 67 83

2048 76 34 42

$12,862,099 6,006 $2,142

4

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

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are

estimated until Step 2 in 2020.

5

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 

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).

Table A-3. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.1% from 2015 through 2029, for the purposes of a sensitivity 

analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-4

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

2015 4$1,057,518 $387,171 881 252 629 $616 881 252 629

2016 $1,057,518 $387,171 900 258 642 $603 1,781 510 1,271

2017 $1,057,518 $387,171 919 263 656 $590 2,700 773 1,927

2018 $680,112 $387,171 938 269 669 $578 3,638 1,041 2,596

2019 $680,112 $387,171 958 274 684 $566 4,595 1,316 3,280

2020 4$680,112 $387,171 978 124 853 $454 5,573 1,440 4,133

2021 $66,074 $387,171 998 127 871 $444 6,571 1,567 5,004

2022 $66,074 $387,171 1,019 130 890 $435 7,591 1,697 5,894

2023 $66,074 $387,171 1,041 132 908 $426 8,631 1,829 6,802

2024 $66,074 $387,171 1,063 135 927 $418 9,694 1,964 7,730

2025 $66,074 $387,171 1,085 138 947 $409 10,779 2,102 8,676

2026 $66,074 $387,171 1,108 141 967 $401 11,886 2,243 9,643

2027 $66,074 $387,171 1,131 144 987 $392 13,017 2,387 10,630

2028 $66,074 $387,171 1,155 147 1,008 $384 14,172 2,534 11,638

2029 $66,074 $387,171 1,179 150 1,029 $376 15,351 2,684 12,667

2030 15,351 2,684 12,667

2031 15,351 2,684 12,667

2032 15,351 2,684 12,667

2033 15,351 2,684 12,667

2034 15,351 2,684 12,667

2035 14,469 2,432 12,038

2036 13,570 2,174 11,396

2037 12,651 1,911 10,740

2038 11,713 1,643 10,070

2039 10,755 1,368 9,387

2040 9,778 1,244 8,534

2041 8,779 1,117 7,662

2042 7,760 987 6,773

2043 6,719 855 5,864

2044 5,657 720 4,937

2045 4,572 582 3,990

2046 3,464 441 3,024

2047 2,334 297 2,037

2048 1,179 150 1,029

$5,807,558 173,481 $33

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year

emitting lifespan 

Table A-4. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

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

and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.1% from 2015 through 2029, for the purposes of a sensitivity 

analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-5

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$45,761,061 $16,620,786 10,343 7,042 3,300 $5,036 10,343 7,042 3,300

2016 4$45,761,061 $16,620,786 10,560 5,912 4,648 $3,576 20,902 12,954 7,948

2017 4$37,432,168 $16,620,786 10,782 2,122 8,660 $1,919 31,684 15,076 16,608

2018 $37,488,168 $16,620,786 11,008 2,167 8,841 $1,880 42,692 17,243 25,449

2019 $37,488,168 $16,620,786 11,239 2,212 9,027 $1,841 53,931 19,455 34,476

2020 4$37,488,168 $16,620,786 11,475 359 11,117 $1,495 65,406 19,813 45,593

2021 $877,000 $16,620,786 11,716 366 11,350 $1,464 77,123 20,180 56,943

2022 $877,000 $16,620,786 11,962 374 11,588 $1,434 89,085 20,553 68,531

2023 $877,000 $16,620,786 12,213 382 11,832 $1,405 101,298 20,935 80,363

2024 $877,000 $16,620,786 12,470 390 12,080 $1,376 113,768 21,325 92,443

2025 $877,000 $16,620,786 12,732 398 12,334 $1,348 126,500 21,723 104,777

2026 $877,000 $16,620,786 12,999 406 12,593 $1,320 139,499 22,129 117,370

2027 $877,000 $16,620,786 13,272 415 12,857 $1,293 152,771 22,544 130,227

2028 $877,000 $16,620,786 13,551 423 13,127 $1,266 166,322 22,967 143,355

2029 $877,000 $16,620,786 13,835 432 13,403 $1,240 180,157 23,399 156,758

2030 180,157 23,399 156,758

2031 180,157 23,399 156,758

2032 180,157 23,399 156,758

2033 180,157 23,399 156,758

2034 180,157 23,399 156,758

2035 169,815 16,357 153,457

2036 159,255 10,445 148,810

2037 148,473 8,323 140,150

2038 137,465 6,157 131,309

2039 126,226 3,945 122,282

2040 114,751 3,586 111,165

2041 103,035 3,220 99,815

2042 91,073 2,846 88,227

2043 78,859 2,464 76,395

2044 66,389 2,075 64,315

2045 53,657 1,677 51,981

2046 40,658 1,271 39,388

2047 327,386 856 26,530

2048 313,835 432 13,403

$249,311,792 2,207,772 $113

Nationwide

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

hydronic heaters are estimated to already meet the Step 2 limit).

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

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

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

Year (per ton) 3

Nationwide 

Annual Cost1 
A-6

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2015 4$20,905,663 $6,299,286 6,675 6,675 0 N/A 6,675 6,675 0

2016 4$20,905,663 $6,299,286 6,816 5,538 1,278 $4,929 13,491 12,213 1,278

2017 4$12,576,770 $6,299,286 6,959 1,740 5,219 $1,207 20,450 13,953 6,497

2018 $12,593,240 $6,299,286 7,105 1,776 5,329 $1,182 27,555 15,729 11,826

2019 $12,593,240 $6,299,286 7,254 1,814 5,441 $1,158 34,809 17,543 17,266

2020 4$12,593,240 $6,299,286 7,406 231 7,175 $878 42,215 17,774 24,441

2021 $257,941 $6,299,286 7,562 236 7,326 $860 49,777 18,010 31,767

2022 $257,941 $6,299,286 7,721 241 7,480 $842 57,498 18,252 39,247

2023 $257,941 $6,299,286 7,883 246 7,637 $825 65,381 18,498 46,883

2024 $257,941 $6,299,286 8,048 252 7,797 $808 73,430 18,750 54,680

2025 $257,941 $6,299,286 8,217 257 7,961 $791 81,647 19,006 62,641

2026 $257,941 $6,299,286 8,390 262 8,128 $775 90,037 19,269 70,769

2027 $257,941 $6,299,286 8,566 268 8,299 $759 98,603 19,536 79,067

2028 $257,941 $6,299,286 8,746 273 8,473 $743 107,350 19,810 87,540

2029 $257,941 $6,299,286 8,930 279 8,651 $728 116,279 20,089 96,191

2030 116,279 20,089 96,191

2031 116,279 20,089 96,191

2032 116,279 20,089 96,191

2033 116,279 20,089 96,191

2034 116,279 20,089 96,191

2035 109,604 13,413 96,191

2036 102,788 7,875 94,913

2037 95,829 6,136 89,694

2038 88,725 4,359 84,365

2039 81,470 2,546 78,924

2040 74,064 2,314 71,749

2041 66,502 2,078 64,424

2042 58,781 1,837 56,944

2043 50,898 1,591 49,308

2044 42,850 1,339 41,511

2045 34,632 1,082 33,550

2046 26,242 820 25,422

2047 17,676 552 17,124

2048 8,930 279 8,651

$94,489,287 1,389,914 $68

Table A-6. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a 

sensitivity analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
A-7

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$24,855,398 $10,321,500.34 3,667 367 3,300 $3,127 3,667 367 3,300

2016 $24,855,398 $10,321,500.34 3,744 374 3,370 $3,063 7,411 741 6,670

2017 $24,855,398 $10,321,500.34 3,823 382 3,441 $3,000 11,234 1,123 10,111

2018 $24,894,927 $10,321,500.34 3,903 390 3,513 $2,938 15,137 1,514 13,623

2019 $24,894,927 $10,321,500.34 3,985 399 3,587 $2,878 19,122 1,912 17,210

2020 4$24,894,927 $10,321,500.34 4,069 127 3,942 $2,619 23,191 2,039 21,152

2021 $619,059 $10,321,500.34 4,154 130 4,024 $2,565 27,345 2,169 25,176

2022 $619,059 $10,321,500.34 4,241 133 4,109 $2,512 31,587 2,302 29,285

2023 $619,059 $10,321,500.34 4,330 135 4,195 $2,460 35,917 2,437 33,480

2024 $619,059 $10,321,500.34 4,421 138 4,283 $2,410 40,338 2,575 37,763

2025 $619,059 $10,321,500.34 4,514 141 4,373 $2,360 44,853 2,716 42,136

2026 $619,059 $10,321,500.34 4,609 144 4,465 $2,312 49,462 2,860 46,601

2027 $619,059 $10,321,500.34 4,706 147 4,559 $2,264 54,168 3,007 51,160

2028 $619,059 $10,321,500.34 4,805 150 4,655 $2,218 58,972 3,158 55,815

2029 $619,059 $10,321,500.34 4,906 153 4,752 $2,172 63,878 3,311 60,567

2030 63,878 3,311 60,567

2031 63,878 3,311 60,567

2032 63,878 3,311 60,567

2033 63,878 3,311 60,567

2034 63,878 3,311 60,567

2035 60,211 2,944 57,267

2036 56,467 2,570 53,897

2037 52,644 2,187 50,456

2038 48,741 1,797 46,944

2039 44,756 1,399 43,357

2040 40,687 1,271 39,415

2041 36,533 1,142 35,391

2042 32,291 1,009 31,282

2043 27,961 874 27,087

2044 23,539 736 22,804

2045 19,025 595 18,431

2046 14,416 451 13,966

2047 39,710 303 9,407

2048 34,906 153 4,752

$154,822,505 817,858 $189

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

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).

Table A-7. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 2.1% 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
A-8

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$51,327,699 $19,075,401 11,664 7,734 3,929 $4,854 11,664 7,734 3,929

2016 4$51,327,699 $19,075,401 11,909 6,619 5,290 $3,606 23,572 14,353 9,219

2017 4$42,998,805 $19,075,401 12,159 2,843 9,315 $2,048 35,731 17,196 18,535

2018 $42,757,493 $19,075,401 12,451 2,940 9,511 $2,006 48,182 20,137 28,046

2019 $42,757,493 $19,075,401 12,713 3,002 9,711 $1,964 60,895 23,139 37,756

2020 4$42,757,493 $19,075,401 12,980 770 12,209 $1,562 73,874 23,909 49,965

2021 $1,356,037 $19,075,401 13,252 787 12,466 $1,530 87,126 24,696 62,431

2022 $1,356,037 $19,075,401 13,530 803 12,727 $1,499 100,657 25,499 75,158

2023 $1,356,037 $19,075,401 13,815 820 12,995 $1,468 114,471 26,319 88,153

2024 $1,356,037 $19,075,401 14,105 837 13,268 $1,438 128,576 27,156 101,420

2025 $1,356,037 $19,075,401 14,401 855 13,546 $1,408 142,977 28,011 114,966

2026 $1,356,037 $19,075,401 14,703 873 13,831 $1,379 157,680 28,883 128,797

2027 $1,356,037 $19,075,401 15,012 891 14,121 $1,351 172,692 29,774 142,918

2028 $1,356,037 $19,075,401 15,327 910 14,418 $1,323 188,020 30,684 157,336

2029 $1,356,037 $19,075,401 15,649 929 14,720 $1,296 203,669 31,613 172,056

2030 203,669 31,613 172,056

2031 203,669 31,613 172,056

2032 203,669 31,613 172,056

2033 203,669 31,613 172,056

2034 203,669 31,613 172,056

2035 192,005 23,879 168,127

2036 180,097 17,260 162,837

2037 167,938 14,417 153,521

2038 155,487 11,476 144,010

2039 142,774 8,474 134,300

2040 129,795 7,704 122,091

2041 116,543 6,917 109,625

2042 103,012 6,114 96,898

2043 89,197 5,294 83,903

2044 75,093 4,457 70,636

2045 60,692 3,602 57,090

2046 45,989 2,730 43,259

2047 3 30,977 1,839 29,138

2048 315,649 929 14,720

$286,131,014 2,422,490 $118

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit

(i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Table A-8. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room 

Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Emission Reduction, cumulative per year

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

Year 

3

Nationwide 

Annual Cost1 

Nationwide

Average

Annual Cost 

Annual Snapshots

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.
A-9

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 24,490 8,463 16,027

2031 24,490 8,463 16,027

2032 24,490 8,463 16,027

2033 24,490 8,463 16,027

2034 24,490 8,463 16,027

2035 23,143 7,757 15,385

2036 21,762 7,034 14,728

2037 20,346 6,292 14,054

2038 18,872 5,508 13,363

2039 17,360 4,704 12,655

2040 15,810 4,285 11,526

2041 14,222 3,854 10,368

2042 12,594 3,413 9,181

2043 10,925 2,961 7,965

2044 9,215 2,497 6,718

2045 7,462 2,022 5,440

2046 5,665 1,535 4,130

2047 3,823 1,036 2,787

2048 1,935 524 1,411

$36,819,222 225,872 $163

Table A-9. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative

cost5 

5

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

reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029.

Year 

3

Nationwide

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

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

4

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

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

models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 

2020.

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year
A-10

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 7,341 5,033 2,308

2031 7,341 5,033 2,308

2032 7,341 5,033 2,308

2033 7,341 5,033 2,308

2034 7,341 5,033 2,308

2035 6,950 4,643 2,308

2036 6,550 4,242 2,308

2037 6,139 3,832 2,308

2038 5,694 3,387 2,308

2039 5,238 2,930 2,308

2040 4,771 2,669 2,102

2041 4,291 2,401 1,891

2042 3,800 2,126 1,674

2043 3,297 1,844 1,452

2044 2,781 1,556 1,225

2045 2,252 1,260 992

2046 1,709 956 753

2047 1,154 645 508

2048 584 327 257

$18,149,566 36,238 $501

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 

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

stoves already meet the Step 2 limit).

 Table A-10. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020 ). 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. 
A-11

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 1,034 628 406

2031 1,034 628 406

2032 1,034 628 406

2033 1,034 628 406

2034 1,034 628 406

2035 976 570 406

2036 917 511 406

2037 856 450 406

2038 794 388 406

2039 731 325 406

2040 665 296 370

2041 599 266 333

2042 530 236 294

2043 460 204 255

2044 388 172 215

2045 314 140 174

2046 238 106 132

2047 161 72 89

2048 81 36 45

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

4

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

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are

estimated until Step 2 in 2020.

5

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 

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).

Table A-11. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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.

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-12

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 16,115 2,802 13,313

2031 16,115 2,802 13,313

2032 16,115 2,802 13,313

2033 16,115 2,802 13,313

2034 16,115 2,802 13,313

2035 15,216 2,544 12,672

2036 14,295 2,281 12,014

2037 13,351 2,010 11,341

2038 12,383 1,733 10,650

2039 11,391 1,449 9,942

2040 10,374 1,320 9,054

2041 9,332 1,187 8,145

2042 8,264 1,051 7,213

2043 7,169 912 6,257

2044 6,047 769 5,277

2045 4,896 623 4,273

2046 3,717 473 3,244

2047 2,509 319 2,189

2048 1,270 162 1,108

$5,807,558 183,259 $32

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year

emitting lifespan 

Table A-12. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

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

and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 single burn rate stoves shipped in 2029 will be emitting through 2048.

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-13

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 188,603 24,092 164,510

2031 188,603 24,092 164,510

2032 188,603 24,092 164,510

2033 188,603 24,092 164,510

2034 188,603 24,092 164,510

2035 178,085 16,914 161,171

2036 167,304 10,864 156,440

2037 156,254 8,686 147,568

2038 144,928 6,454 138,473

2039 133,318 4,166 129,152

2040 121,418 3,794 117,624

2041 109,221 3,413 105,808

2042 96,719 3,022 93,696

2043 83,904 2,622 81,282

2044 70,769 2,212 68,557

2045 57,305 1,791 55,514

2046 43,505 1,360 42,146

2047 329,360 917 28,442

2048 314,861 464 14,397

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

Nationwide

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

hydronic heaters are estimated to already meet the Step 2 limit).

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Table A-13. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

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

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

Year (per ton) 3

Nationwide 

Annual Cost1 
A-14

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 122,067 20,672 101,395

2031 122,067 20,672 101,395

2032 122,067 20,672 101,395

2033 122,067 20,672 101,395

2034 122,067 20,672 101,395

2035 115,260 13,865 101,395

2036 108,283 8,196 100,087

2037 101,131 6,408 94,723

2038 93,800 4,575 89,225

2039 86,286 2,696 83,590

2040 78,584 2,456 76,129

2041 70,690 2,209 68,481

2042 62,598 1,956 60,642

2043 54,304 1,697 52,607

2044 45,803 1,431 44,372

2045 37,089 1,159 35,930

2046 28,157 880 27,277

2047 19,002 594 18,409

2048 9,618 301 9,318

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

Table A-14. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

sensitivity analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
A-15

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 66,535 3,420 63,115

2031 66,535 3,420 63,115

2032 66,535 3,420 63,115

2033 66,535 3,420 63,115

2034 66,535 3,420 63,115

2035 62,825 3,049 59,776

2036 59,022 2,669 56,353

2037 55,123 2,279 52,844

2038 51,128 1,879 49,248

2039 47,032 1,470 45,562

2040 42,834 1,339 41,495

2041 38,531 1,204 37,327

2042 34,120 1,066 33,054

2043 29,600 925 28,675

2044 24,966 780 24,186

2045 20,216 632 19,584

2046 15,348 480 14,868

2047 310,358 324 10,034

2048 35,243 164 5,079

$154,822,505 856,776 $181

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

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).

Table A-15. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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
A-16

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2030 213,092 32,555 180,537

2031 213,092 32,555 180,537

2032 213,092 32,555 180,537

2033 213,092 32,555 180,537

2034 213,092 32,555 180,537

2035 201,227 24,671 176,556

2036 189,066 17,898 171,168

2037 176,600 14,979 161,622

2038 163,799 11,962 151,837

2039 150,678 8,871 141,807

2040 137,229 8,079 129,150

2041 123,443 7,267 116,176

2042 109,313 6,435 102,877

2043 94,829 5,583 89,247

2044 79,984 4,709 75,275

2045 64,767 3,813 60,954

2046 49,170 2,895 46,275

2047 3 33,183 1,954 31,230

2048 316,796 989 15,808

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

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit

(i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Table A-16. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room 

Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Emission Reduction, cumulative per year

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

Year 

3

Nationwide 

Annual Cost1 

Nationwide

Average

Annual Cost 

Annual Snapshots

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

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

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.
A-17

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$5,566,638 $2,454,615 1,380 723 657 $3,735 1,380 723 657

2016 $5,566,638 $2,454,615 1,422 745 677 $3,626 2,802 1,468 1,334

2017 $5,566,638 $2,454,615 1,464 767 697 $3,521 4,266 2,235 2,031

2018 $5,269,325 $2,454,615 1,516 798 718 $3,418 5,782 3,033 2,749

2019 $5,269,325 $2,454,615 1,561 822 740 $3,318 7,343 3,854 3,489

2020 4$5,269,325 $2,454,615 1,608 430 1,178 $2,084 8,951 4,284 4,667

2021 $479,037 $2,454,615 1,656 443 1,213 $2,024 10,608 4,728 5,880

2022 $479,037 $2,454,615 1,706 457 1,249 $1,965 12,314 5,184 7,129

2023 $479,037 $2,454,615 1,757 470 1,287 $1,907 14,071 5,655 8,416

2024 $479,037 $2,454,615 1,810 484 1,325 $1,852 15,881 6,139 9,742

2025 $479,037 $2,454,615 1,864 499 1,365 $1,798 17,745 6,638 11,107

2026 $479,037 $2,454,615 1,920 514 1,406 $1,746 19,665 7,152 12,513

2027 $479,037 $2,454,615 1,978 529 1,448 $1,695 21,643 7,681 13,961

2028 $479,037 $2,454,615 2,037 545 1,492 $1,645 23,680 8,226 15,453

2029 $479,037 $2,454,615 2,098 562 1,537 $1,597 25,778 8,788 16,990

2030 25,778 8,788 16,990

2031 25,778 8,788 16,990

2032 25,778 8,788 16,990

2033 25,778 8,788 16,990

2034 25,778 8,788 16,990

2035 24,397 8,065 16,333

2036 22,976 7,320 15,656

2037 21,511 6,553 14,959

2038 19,996 5,755 14,240

2039 18,434 4,934 13,501

2040 16,826 4,503 12,323

2041 15,170 4,060 11,110

2042 13,464 3,603 9,861

2043 11,707 3,133 8,574

2044 9,897 2,649 7,248

2045 8,033 2,150 5,883

2046 6,113 1,636 4,477

2047 4,135 1,107 3,028

2048 2,098 562 1,537

$36,819,222 240,668 $153

Table A-17. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative

cost5 

5

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

reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029.

Year 

3

Nationwide

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis. 

4

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

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

models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 

2020.

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year
A-18

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$3,024,928 $1,209,971 400 400 0 N/A 400 400 0

2016 $3,024,928 $1,209,971 412 412 0 N/A 813 813 0

2017 $3,024,928 $1,209,971 425 425 0 N/A 1,238 1,238 0

2018 $3,024,928 $1,209,971 445 445 0 N/A 1,683 1,683 0

2019 $3,024,928 $1,209,971 458 458 0 N/A 2,141 2,141 0

2020 4$3,024,928 $1,209,971 472 264 208 $5,817 2,613 2,405 208

2021 $0 $1,209,971 486 272 214 $5,648 3,099 2,677 422

2022 $0 $1,209,971 501 280 221 $5,483 3,600 2,957 643

2023 $0 $1,209,971 516 289 227 $5,324 4,116 3,246 870

2024 $0 $1,209,971 531 297 234 $5,169 4,648 3,543 1,104

2025 $0 $1,209,971 547 306 241 $5,018 5,195 3,849 1,345

2026 $0 $1,209,971 564 315 248 $4,872 5,759 4,165 1,594

2027 $0 $1,209,971 581 325 256 $4,730 6,339 4,490 1,850

2028 $0 $1,209,971 598 335 263 $4,592 6,937 4,824 2,113

2029 $0 $1,209,971 616 345 271 $4,459 7,553 5,169 2,384

2030 7,553 5,169 2,384

2031 7,553 5,169 2,384

2032 7,553 5,169 2,384

2033 7,553 5,169 2,384

2034 7,553 5,169 2,384

2035 7,153 4,768 2,384

2036 6,740 4,356 2,384

2037 6,316 3,931 2,384

2038 5,871 3,486 2,384

2039 5,412 3,028 2,384

2040 4,940 2,764 2,176

2041 4,454 2,492 1,962

2042 3,953 2,211 1,742

2043 3,437 1,923 1,514

2044 2,906 1,626 1,280

2045 2,358 1,319 1,039

2046 1,795 1,004 791

2047 1,214 679 535

2048 616 345 271

$18,149,566 37,539 $483

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 

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

stoves already meet the Step 2 limit).

 Table A-18. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Wood Stoves

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020 ). 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 3% from 2015 through 2029, for the purposes of a sensitivity analysis. 
A-19

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$1,484,192 $857,473 59 59 0 N/A 59 59 0

2016 $1,484,192 $857,473 61 61 0 N/A 120 120 0

2017 $1,484,192 $857,473 63 63 0 N/A 183 183 0

2018 $1,564,285 $857,473 65 65 0 N/A 247 247 0

2019 $1,564,285 $857,473 66 66 0 N/A 314 314 0

2020 4$1,564,285 $857,473 68 30 38 $22,543 382 344 38

2021 $412,963 $857,473 71 31 39 $21,886 453 375 77

2022 $412,963 $857,473 73 32 40 $21,249 525 408 118

2023 $412,963 $857,473 75 33 42 $20,630 600 441 159

2024 $412,963 $857,473 77 34 43 $20,029 677 475 202

2025 $412,963 $857,473 79 35 44 $19,446 756 510 246

2026 $412,963 $857,473 82 36 45 $18,879 838 547 291

2027 $412,963 $857,473 84 37 47 $18,329 922 584 338

2028 $412,963 $857,473 87 39 48 $17,795 1,009 623 386

2029 $412,963 $857,473 89 40 50 $17,277 1,098 662 436

2030 1,098 662 436

2031 1,098 662 436

2032 1,098 662 436

2033 1,098 662 436

2034 1,098 662 436

2035 1,039 603 436

2036 979 543 436

2037 916 480 436

2038 851 415 436

2039 785 349 436

2040 716 318 398

2041 646 287 359

2042 573 255 318

2043 498 222 277

2044 421 187 234

2045 342 152 190

2046 260 116 145

2047 176 78 98

2048 89 40 50

$12,862,099 6,865 $1,874

4

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

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are

estimated until Step 2 in 2020.

5

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

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

CE based on total

cost & cumulative

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 

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).

Table A-19. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Pellet Stoves

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 3% from 2015 through 2029, for the purposes of a sensitivity 

analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-20

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

2015 4$1,057,518 $387,171 921 264 657 $589 921 264 657

2016 $1,057,518 $387,171 948 272 677 $572 1,869 535 1,334

2017 $1,057,518 $387,171 977 280 697 $555 2,846 815 2,031

2018 $680,112 $387,171 1,006 288 718 $539 3,852 1,103 2,749

2019 $680,112 $387,171 1,036 297 740 $523 4,889 1,399 3,489

2020 4$680,112 $387,171 1,067 136 932 $416 5,956 1,535 4,421

2021 $66,074 $387,171 1,099 140 960 $403 7,056 1,675 5,380

2022 $66,074 $387,171 1,132 144 988 $392 8,188 1,819 6,369

2023 $66,074 $387,171 1,166 148 1,018 $380 9,355 1,968 7,387

2024 $66,074 $387,171 1,201 153 1,049 $369 10,556 2,121 8,435

2025 $66,074 $387,171 1,237 157 1,080 $358 11,793 2,278 9,515

2026 $66,074 $387,171 1,275 162 1,112 $348 13,068 2,440 10,628

2027 $66,074 $387,171 1,313 167 1,146 $338 14,381 2,607 11,774

2028 $66,074 $387,171 1,352 172 1,180 $328 15,733 2,779 12,954

2029 $66,074 $387,171 1,393 177 1,216 $319 17,126 2,956 14,169

2030 17,126 2,956 14,169

2031 17,126 2,956 14,169

2032 17,126 2,956 14,169

2033 17,126 2,956 14,169

2034 17,126 2,956 14,169

2035 16,205 2,693 13,512

2036 15,257 2,421 12,835

2037 14,280 2,142 12,138

2038 13,274 1,854 11,420

2039 12,237 1,557 10,680

2040 11,170 1,421 9,749

2041 10,070 1,281 8,789

2042 8,938 1,137 7,801

2043 7,771 989 6,783

2044 6,570 836 5,734

2045 5,332 678 4,654

2046 4,058 516 3,542

2047 2,745 349 2,396

2048 1,393 177 1,216

$5,807,558 196,264 $30

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year

emitting lifespan 

Table A-20. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Single Burn Rate Stoves

1

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

and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 3% from 2015 through 2029, for the purposes of a sensitivity 

analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
A-21

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$45,761,061 $16,620,786 10,740 7,351 3,388 $4,905 10,740 7,351 3,388

2016 4$45,761,061 $16,620,786 11,062 6,225 4,837 $3,436 21,802 13,576 8,226

2017 4$37,432,168 $16,620,786 11,394 2,249 9,145 $1,818 33,196 15,826 17,370

2018 $37,488,168 $16,620,786 11,736 2,317 9,419 $1,765 44,932 18,143 26,789

2019 $37,488,168 $16,620,786 12,088 2,386 9,702 $1,713 57,020 20,529 36,491

2020 4$37,488,168 $16,620,786 12,451 389 12,061 $1,378 69,470 20,918 48,552

2021 $877,000 $16,620,786 12,824 401 12,423 $1,338 82,294 21,319 60,976

2022 $877,000 $16,620,786 13,209 413 12,796 $1,299 95,503 21,731 73,771

2023 $877,000 $16,620,786 13,605 425 13,180 $1,261 109,108 22,157 86,951

2024 $877,000 $16,620,786 14,013 438 13,575 $1,224 123,121 22,595 100,527

2025 $877,000 $16,620,786 14,434 451 13,983 $1,189 137,555 23,046 114,509

2026 $877,000 $16,620,786 14,867 465 14,402 $1,154 152,421 23,510 128,911

2027 $877,000 $16,620,786 15,313 479 14,834 $1,120 167,734 23,989 143,745

2028 $877,000 $16,620,786 15,772 493 15,279 $1,088 183,506 24,482 159,024

2029 $877,000 $16,620,786 16,245 508 15,737 $1,056 199,751 24,989 174,762

2030 199,751 24,989 174,762

2031 199,751 24,989 174,762

2032 199,751 24,989 174,762

2033 199,751 24,989 174,762

2034 199,751 24,989 174,762

2035 189,011 17,638 171,373

2036 177,949 11,413 166,536

2037 166,555 9,164 157,391

2038 154,819 6,847 147,972

2039 142,731 4,460 138,271

2040 130,281 4,071 126,209

2041 117,457 3,671 113,786

2042 104,248 3,258 100,990

2043 90,643 2,833 87,810

2044 76,630 2,395 74,235

2045 62,196 1,944 60,253

2046 47,330 1,479 45,851

2047 332,017 1,001 31,016

2048 316,245 508 15,737

$249,311,792 2,486,001 $100

Nationwide

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

hydronic heaters are estimated to already meet the Step 2 limit).

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

Table A-21. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

Year (per ton) 3

Nationwide 

Annual Cost1 
A-22

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2015 4$20,905,663 $6,299,286 6,975 6,975 0 N/A 6,975 6,975 0

2016 4$20,905,663 $6,299,286 7,184 5,837 1,347 $4,676 14,159 12,812 1,347

2017 4$12,576,770 $6,299,286 7,400 1,850 5,550 $1,135 21,559 14,662 6,897

2018 $12,593,240 $6,299,286 7,622 1,905 5,716 $1,102 29,180 16,567 12,613

2019 $12,593,240 $6,299,286 7,850 1,963 5,888 $1,070 37,031 18,530 18,501

2020 4$12,593,240 $6,299,286 8,086 253 7,833 $804 45,117 18,783 26,334

2021 $257,941 $6,299,286 8,328 260 8,068 $781 53,445 19,043 34,402

2022 $257,941 $6,299,286 8,578 268 8,310 $758 62,023 19,311 42,712

2023 $257,941 $6,299,286 8,836 276 8,560 $736 70,859 19,587 51,272

2024 $257,941 $6,299,286 9,101 284 8,816 $715 79,960 19,872 60,088

2025 $257,941 $6,299,286 9,374 293 9,081 $694 89,333 20,164 69,169

2026 $257,941 $6,299,286 9,655 302 9,353 $673 98,988 20,466 78,522

2027 $257,941 $6,299,286 9,945 311 9,634 $654 108,933 20,777 88,156

2028 $257,941 $6,299,286 10,243 320 9,923 $635 119,176 21,097 98,079

2029 $257,941 $6,299,286 10,550 330 10,221 $616 129,726 21,427 108,299

2030 129,726 21,427 108,299

2031 129,726 21,427 108,299

2032 129,726 21,427 108,299

2033 129,726 21,427 108,299

2034 129,726 21,427 108,299

2035 122,751 14,452 108,299

2036 115,567 8,615 106,952

2037 108,167 6,765 101,402

2038 100,546 4,859 95,686

2039 92,695 2,897 89,798

2040 84,609 2,644 81,965

2041 76,281 2,384 73,897

2042 67,703 2,116 65,587

2043 58,867 1,840 57,027

2044 49,766 1,555 48,211

2045 40,393 1,262 39,130

2046 30,738 961 29,777

2047 20,793 650 20,143

2048 10,550 330 10,221

$94,489,287 1,577,893 $60

Table A-22. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Forced Air Furnaces

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity 

analysis. 

3

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

Year 

3

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 
A-23

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$24,855,398 $10,321,500.34 3,765 376 3,388 $3,046 3,765 376 3,388

2016 $24,855,398 $10,321,500.34 3,878 388 3,490 $2,957 7,643 764 6,879

2017 $24,855,398 $10,321,500.34 3,994 399 3,595 $2,871 11,637 1,164 10,474

2018 $24,894,927 $10,321,500.34 4,114 411 3,703 $2,788 15,751 1,575 14,176

2019 $24,894,927 $10,321,500.34 4,238 424 3,814 $2,706 19,989 1,999 17,990

2020 4$24,894,927 $10,321,500.34 4,365 136 4,228 $2,441 24,354 2,135 22,218

2021 $619,059 $10,321,500.34 4,496 140 4,355 $2,370 28,849 2,276 26,573

2022 $619,059 $10,321,500.34 4,630 145 4,486 $2,301 33,480 2,420 31,059

2023 $619,059 $10,321,500.34 4,769 149 4,620 $2,234 38,249 2,570 35,679

2024 $619,059 $10,321,500.34 4,912 154 4,759 $2,169 43,161 2,723 40,438

2025 $619,059 $10,321,500.34 5,060 158 4,902 $2,106 48,221 2,881 45,340

2026 $619,059 $10,321,500.34 5,212 163 5,049 $2,044 53,433 3,044 50,389

2027 $619,059 $10,321,500.34 5,368 168 5,200 $1,985 58,801 3,212 55,589

2028 $619,059 $10,321,500.34 5,529 173 5,356 $1,927 64,330 3,385 60,945

2029 $619,059 $10,321,500.34 5,695 178 5,517 $1,871 70,025 3,563 66,462

2030 70,025 3,563 66,462

2031 70,025 3,563 66,462

2032 70,025 3,563 66,462

2033 70,025 3,563 66,462

2034 70,025 3,563 66,462

2035 66,260 3,186 63,074

2036 62,382 2,798 59,584

2037 58,388 2,399 55,989

2038 54,273 1,987 52,286

2039 50,036 1,564 48,472

2040 45,671 1,427 44,244

2041 41,176 1,287 39,889

2042 36,545 1,142 35,403

2043 31,776 993 30,783

2044 26,863 839 26,024

2045 21,804 681 21,122

2046 16,592 518 16,073

2047 311,224 351 10,873

2048 35,695 178 5,517

$154,822,505 908,107 $170

4

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

5

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

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

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).

Table A-23. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Hydronic Heating Systems

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). 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 3% 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
A-24

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)6

CE based on 

nationwide

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)6

2015 4$51,327,699 $19,075,401 12,120 8,075 4,046 $4,715 12,120 8,075 4,046

2016 4$51,327,699 $19,075,401 12,484 6,970 5,514 $3,459 24,604 15,044 9,560

2017 4$42,998,805 $19,075,401 12,858 3,016 9,842 $1,938 37,462 18,061 19,402

2018 $42,757,493 $19,075,401 13,252 3,114 10,137 $1,882 50,714 21,175 29,539

2019 $42,757,493 $19,075,401 13,649 3,208 10,441 $1,827 64,363 24,383 39,980

2020 4$42,757,493 $19,075,401 14,059 819 13,239 $1,441 78,421 25,202 53,219

2021 $1,356,037 $19,075,401 14,480 844 13,636 $1,399 92,902 26,046 66,855

2022 $1,356,037 $19,075,401 14,915 869 14,045 $1,358 107,817 26,916 80,901

2023 $1,356,037 $19,075,401 15,362 895 14,467 $1,319 123,179 27,811 95,367

2024 $1,356,037 $19,075,401 15,823 922 14,901 $1,280 139,002 28,734 110,268

2025 $1,356,037 $19,075,401 16,298 950 15,348 $1,243 155,299 29,683 125,616

2026 $1,356,037 $19,075,401 16,787 978 15,808 $1,207 172,086 30,662 141,424

2027 $1,356,037 $19,075,401 17,290 1,008 16,282 $1,172 189,376 31,670 157,707

2028 $1,356,037 $19,075,401 17,809 1,038 16,771 $1,137 207,185 32,708 174,477

2029 $1,356,037 $19,075,401 18,343 1,069 17,274 $1,104 225,529 33,777 191,751

2030 225,529 33,777 191,751

2031 225,529 33,777 191,751

2032 225,529 33,777 191,751

2033 225,529 33,777 191,751

2034 225,529 33,777 191,751

2035 213,408 25,703 187,706

2036 200,925 18,733 182,192

2037 188,066 15,716 172,350

2038 174,815 12,602 162,213

2039 161,166 9,394 151,772

2040 147,107 8,575 138,532

2041 132,627 7,731 124,896

2042 117,712 6,861 110,851

2043 102,350 5,966 96,384

2044 86,527 5,043 81,483

2045 70,229 4,094 66,136

2046 53,442 3,115 50,327

2047 3 36,152 2,107 34,045

2048 318,343 1,069 17,274

$286,131,014 2,726,669 $105

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit

(i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Table A-24. Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room 

Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

CE based on total

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

Emission Reduction, cumulative per year

Nationwide cumulative 

cost5 

Cumulative Emission 

Reduction over 20-year 

emitting lifespan 

5

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

reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029.

Year 

3

Nationwide 

Annual Cost1 

Nationwide

Average

Annual Cost 

Annual Snapshots

1

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

certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design 

lifespan used in this analysis.

2

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

surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis. 

3

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

4

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

practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all 

furnaces in 2020.