Notes Notes



### Wood stove 7.5 to 4.5 High Low median 2013 dollars High Low median 2013 dollars **Capital Costs Capital Costs**  **R&D/Engineering costs R&D/Engineering costs**  Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 45,500 19,000 32,250 Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 91,000 38,000 64,500
adjust design/test until emission target is met 47,500 30,000 38,750 adjust design/test until emission target is met 95,000 60,000 77,500
construct final prototypes, safety test check. Eng. Drawings/specs, patent application 27,000 17,000 22,000 construct final prototypes, safety test check. Eng. Drawings/specs, patent application 54,000 34,000 44,000 confirm final prototype performance 0 0 0 confirm final prototype performance 0 0 0 **R&D/Engineering Total costs 120,000**  **66,000 93,000**  **R&D/Engineering Total costs 240,000** **132,000 186,000** 
**Tooling Tooling**  Steel Stove 31,200 9,700 20,450 Steel Stove 31,200 9,700 20,450 Cast Iron Stove 62,000 31,000 46,500 Cast Iron Stove 62,000 31,000 46,500 **Average tooling cost 46,600**  **20,350 33,475**  **Average tooling cost 46,600**  **20,350 33,475** 

**Other Capital Cost components 14,000**  **6,000 10,000** HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above **Other Capital Cost components 14,000**  **6,000 10,000** HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above
**Total Capital Cost per model 180,600**  **92,350 136,475**  **Total Capital Cost per model 300,600** **158,350 229,475** 
**Fixed Costs per model Fixed Costs per model**  **Certification Certification** 

EPA testing, Confirmation safety testing or full safety testing, shipping of prototype 19,000 14,500 16,750HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs EPA testing, Confirmation safety testing or full safety testing, shipping of prototype 19,000 14,500 16,750HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs Owner's manual, labeling 3,500 1,800 2,650 Owner's manual, labeling 3,500 1,800 2,650

**Roll-out 0**  **0 0** roll-out considered normal business operation and not due to NSPS **Roll-out 0**  **0 0** roll-out considered normal business operation and not due to NSPS
**Total Fixed Capital Cost per model 22,500**  **16,300 19,400**  **Total Fixed Capital Cost per model 22,500**  **16,300 19,400** 
**Total Costs per Model 203,100** **108,650 155,875**  **Total Costs per Model 323,100** **174,650 248,875** 

**Annualized capital cost per model** 37,492 20,057 28,774annualized over 6 years at 3% interest (note: NERA annualized over 10 years) **Annualized capital cost per model** 59,643 32,240 45,942annualized over 6 years at 37% interest (note: NERA annualized over 10 years) **Annual cost for development of 4 models** 149,967 80,226115,097 **Annual cost for development of 4 models** 238,574128,960183,767 **Adjustable Burn Rate Stoves, Pellet Stoves & Single Burn Rate** 

**Stoves Single Burn Rate Stoves, first 2**  **years (doubled R&D / Engineering Costs)** 

# Hydronic Heater Uncontrolled to 0.32 High Low median

**Capital Costs R&D/Engineering costs** 
Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 180,000115,000147,500 Formulate design changes 4,500 2,500 3,500 Modify prototype 16,000 9,000 12,500 Test/Retest 615,000410,000512,500
Construct final prototype, confirm testing, safety testing 133,500 88,500111,000 Document final changes 8,000 6,000 7,000

**R&D/Engineering total costs 957,000** **631,000 794,000** 
**Manuracturing/Manufacturing Engineering** Programming and Tooling - Steel parts 22,000 13,000 17,500 Tooling - Refractory 45,000 28,000 36,500 Electronic Control System 10,000 5,000 7,500 Final Production samples/Confirm product. Fitup 25,000 15,000 20,000 Create QA/QC specs 4,000 2,000 3,000 **Manuracturing/Manufacturing Engineering total costs 106,000**  **63,000 84,500** 
**Other Capital Cost components** Purchased parts sourcing 41,000 23,500 32,250 Test first production heaters 200,000150,000175,000

Equipment and facilities 75,000 25,000 50,000 **Other Capital Cost components total costs 316,000** **198,500 257,250** 
**Total Capital Cost per model 1,379,000** **892,500 1,135,750** 
**Fixed Costs per model Certification**  **Hydronic Heaters & Forced-Air Furnaces** 

# EPA testing, Confirmation safety testing or full safety testing,

shipping of prototype 72,500 36,000 54,250 Owner's manual, labeling 6,500 3,500 5,000 **Certification Total Costs** 79,000 39,500 59,250

**Roll-out 0**  **0 0** 
**Total Fixed Capital Cost per model 79,000**  **39,500 59,250** 
**Total Costs per Model 1,458,000** **932,000 1,195,000** 

**Annualized capital cost per model 269,143** **172,045 220,594**  **Annual cost for development of 4 models 1,076,573** **688,179 882,376** 

# Notes

2013 dollars High **Capital Costs R&D/Engineering costs** 
Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 360,000 Formulate design changes 9,000 Modify prototype 32,000 Test/Retest 1,230,000 Construct final prototype, confirm testing, safety testing 267,000 Document final changes 16,000
App. A (NERA) concludes erroneously $887,000 for high cost and $581,000 for low cost. **R&D/Engineering total costs 1,914,000** 
**Manuracturing/Manufacturing Engineering** Programming and Tooling - Steel parts 22,000 Tooling - Refractory 45,000 Electronic Control System 10,000 Final Production samples/Confirm product. Fitup 25,000 Create QA/QC specs 4,000 **Manuracturing/Manufacturing Engineering total costs 106,000** 
**Other Capital Cost components** Purchased parts sourcing 41,000 Test first production heaters 200,000
HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above Equipment and facilities 75,000 **Other Capital Cost components total costs 316,000** 
**Total Capital Cost per model 2,336,000** 
**Fixed Costs per model Certification**  **Forced air furnaces, First 2 years (doubled R&D / Engineering** 

# HBPA costs for personal at lab and

travel expenses not accepted as independent third party testing costsEPA testing, Confirmation safety testing or full safety testing, shipping of prototype 72,500 Owner's manual, labeling 6,500 **Certification Total Costs** 79,000

roll-out considered normal business operation and not due to NSPS **Roll-out 0** 
**Total Fixed Capital Cost per model 79,000** 
**Total Costs per Model 2,415,000** 
annualized over 6 years at 3% interest (note: NERA annualized over 10 years)**Annualized capital cost per model 445,803**  **Annual cost for development of 4 models 1,783,212** 

# Notes

Low median 2013 dollars

230,000295,000 5,000 7,000 18,000 25,000 820,0001,025,000

177,000222,000 12,000 14,000

**1,262,000 1,588,000** App. A (NERA) concludes

erroneously $887,000 for high cost and $581,000 for low cost.

13,000 17,500 28,000 36,500 5,000 7,500 15,000 20,000 2,000 3,000 **63,000 84,500** 

23,500 32,250 150,000175,000

25,000 50,000HPBA costs for equipment and

integration not included because these are considered duplicative of R&D costs, above **198,500 257,250** 

**1,523,500 1,929,750**  **Forced air furnaces, First 2 years (doubled R&D / Engineering** 

**costs)**

# 36,000 54,250HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs 3,500 5,000 39,500 59,250

**0 0** roll-out considered normal

business operation and not due to NSPS

**39,500 59,250** 

**1,563,000 1,989,000** 

**288,526 367,164** annualized over 6 years at 3%

interest (note: NERA annualized over 10 years) **1,154,104 1,468,658** **Table 9. Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2015-2020) and through model lifespan (2020-2029)**

(Step 1 compliance) 2015 2016 2017 2018 2019 (Step 2 compliance) 2020 2021 through

20292 (Step 1

compliance) 2015 2016 2017 2018 2019 (Step 2 compliance) 2020 2021 through

20292 Wood Stoves (R&D)3 34 125 $78,283 $78,283 $78,283 $78,283 $78,283 $78,283 $0 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $0 Pellet Stoves (R&D, R&R, cert)4,7 29 125 $46,100 $46,100 $46,100 $48,862 $48,862 $48,862 $14,240 $1,336,900 $1,336,900 $1,336,900 $1,416,993 $1,416,993 $1,416,993 $412,963 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 7 3 20 $310,698 $310,698 $310,698 $200,519 $200,519 $200,519 $22,025 $932,093 $932,093 $932,093 $601,557 $601,557 $601,557 $66,074 $4,930,601 $4,930,601 $4,930,601 $4,680,157 $4,680,157 $4,680,157 $479,037 Forced Air Furnaces (R&D, R&R, cert.)5, 6, 7 7 50 $2,628,527 $2,628,527 $1,581,596 $1,583,949 $1,583,949 $1,583,949 $36,849 $18,399,692 $18,399,692 $11,071,171 $11,087,642 $11,087,642 $11,087,642 $257,941 Hydronic Heaters (R&D, R&R, cert.)7,8 30 120 $729,746 $729,746 $729,746 $731,064 $731,064 $731,064 $20,635 $21,892,380 $21,892,380 $21,892,380 $21,931,910 $21,931,910 $21,931,910 $619,059 $40,292,072 $40,292,072 $32,963,552 $33,019,552 $33,019,552 $33,019,552 $877,000

Period Nationwide Cost of the Rule
$45,222,674 $45,222,674 $37,894,153 $37,699,709 $37,699,709 $37,699,709 $1,356,037 R&D year average (2015- 2020) $40,239,771 Post R&D year average

(2021-2029) $1,356,037

Subpart: Years Annual $

AAA: 2015-2017 Laboratories $55,000 Third-Party Certifiers $16,000

AAA: 2018-2020 Laboratories $73,000 Third-Party Certifiers $9,000
QQQQ: 2015-2017 Laboratories $36,000 Third-Party Certifiers $15,000
QQQQ: 2018-2020 Laboratories $49,000 Third-Party Certifiers $5,000 Average Annual Cost per Manufacturer based on 6-year R&D round (2015-2020) to meet Step 1 and Step 2 limits with ongoing certification costs (through 2029)

# Manufacturers # Models Nationwide Annual Costs1

QQQQ: Central Heaters AAA: Room Heaters NSPS Subpart Appliance Type

* Reporting and Recordkeeping (R&R) costs for laboratories and certifying entities are not included in this cost analysis but are estimated as follows: 1Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2015 through 2020). Ongoing certification and reporting & recordkeeping costs are incurred through 2029 (based on a model brought to market in 2020 with a lifespan of 10 years). Annual Cost of the Rule

6For single burn rate stoves and forced air furnaces, the analysis assumes that only a small percentage meet Step 2 so that approximately 100% of the models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. 5Based on conversations with industry (e.g., 2/8/13), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2014 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters (respectively) this analysis assumes that these efforts will intensify in 2015 and 2016. Therefore estimated R&D costs are doubled in 2015 and 2016 to reflect model development to meet the more stringent 2020 Step 2 standard. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. 4For pellet stoves, the analysis assumes that 70% meet Step 2 already so that 30% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 70% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2015. The analysis reflects the certification costs beginning in 2015 for the 70% of models meeting Step 2, and beginning in 2020 for the remaining 30% of models which underwent R&D re-design. The analysis also reflects ongoing reporting & recordkeeping costs for 100% of the models beginning in 2015. 3This analysis considers additional costs resulting from the NSPS. For wood stoves, the analysis assumes that 26% meet Step 2 already so that 74% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2021 through 2029 exclude the ongoing certification and reporting & recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing 1988 NSPS. 2Since certification is required every 5 years , it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

7Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are estimates of the ongoing R&R burden to manufacturers associated with the NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is approximately$179,000for years 2015 through 2017 and$352,000for years 2018 through 2020. For Subpart QQQQ, the R&R burden to manufacturers is estimated to be $141,000 for years 2015 through 2017 and $197,00 for years 2018 through 2020. Although the 2018 through 2020 costs are carried forward to 2029 for this analysis, actual R&R costs from 2021 through 2029 may vary slightly. These R&R costs do not include the R&R burden to laboratories and certifying entities, which are calculated separately and provided below.*

8For hydronic heaters, the analysis assumes that 18% of models meet Step 2 already so that 82% must undergo R&D to meet Step 2 in 2020. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015.

# SCC **Appliance Population** **Total Tons**

**Burned Emission Inventory Category**  **Pollutant Baseline**  **Emission factor**  **(lb/ton) Baseline** 

**Emissions (tons)**  **Baseline**

**Tons/appl 2015 Step** 

**1 Emission**  **Factor** 2104008220 1,303,1421,226,184Woodstove: fireplace inserts; EPA certified; non-catalyticCarbon Monoxide 140.8 86,323 0.0662 140.8 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Carbon Monoxide 104.4 21,725 0.0509 104.4 2104008320 873,3571,540,026Woodstove: freestanding, EPA certified, non-catalytic Carbon Monoxide 140.8 108,418 0.1241 140.8 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Carbon Monoxide 104.4 40,486 0.1082 104.4 2104008400 846,9311,175,337Woodstove: pellet-fired, general Carbon Monoxide 15.9 9,344 0.0110 15.9

2,206,4704,668,250Single Burn Rate Stoves Carbon Monoxide 230.8 538,716 0.2442 140.8 2104008610 364,5603,654,153Hydronic heater: outdoor Carbon Monoxide 360 657,748 1.8042 36 2104008510 351,0232,624,115Furnace: indoor, cordwood Carbon Monoxide 360472,341 1.3456 90 0.0863Baseline woodstove weighted average (Tons/appl)

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

Wood Stoves 126,527 80,851 77,617 79,169 80,752 82,367 84,015 85,695 87,409 Single Burn Rate Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,091 27,633 Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,305 90,072 Furnace: indoor, cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,769 28,324 Hydronic Heating Systems 13,385 8,553 8,211 8,375 13,100 13,362 13,629 13,902 14,180

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 8,079 5,163 4,956 5,055 5,156 5,259 5,365 5,472 5,581 Single Burn Rate Stoves 9,766 6,241 5,991 6,111 6,233 6,358 6,485 6,614 6,747 Pellet Stoves 432 276 265 270 275 281 287 292 298 Furnace: indoor, cordwood 55,170 35,254 33,844 34,520 35,211 35,915 36,633 37,366 38,113 Hydronic Heating Systems 19,803 12,654 12,148 12,391 19,381 19,769 20,164 20,567 20,979 Total **93,249 59,586**  **57,203 58,347**  **66,256 67,582**  **68,933 70,312**  **71,718 Table 4. Estimated Annual Shipped Units** 

**Table 5. Estimated CO Emissions (Tons) -- Baseline***

### Baseline CO Emissions2 

### (tons) NSPS CO

Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $2,661,608 $1,064,643 5,472 5,472 0 N/A 5,472 5,472 0 2016 $2,661,608 $1,064,643 5,581 5,581 0 N/A 11,053 11,053 0 2017 $2,661,608 $1,064,643 5,693 5,693 0 N/A 16,746 16,746 0 2018 $2,661,608 $1,064,643 6,385 6,385 0 N/A 23,131 23,131 0 2019 $2,661,608 $1,064,643 6,513 6,513 0 N/A 29,644 29,644 0 20204 

### $2,661,608 $1,064,643 6,643 3,524 3,119 $341 36,287 33,169 3,119 2021 $0 $1,064,643 6,776 3,595 3,181 $335 43,064 36,764 6,300 2022 $0 $1,064,643 6,912 3,667 3,245 $328 49,975 40,430 9,545 2023 $0 $1,064,643 7,050 3,740 3,310 $322 57,025 44,171 12,854 2024 $0 $1,064,643 7,191 3,815 3,376 $315 64,216 47,985 16,230 2025 $0 $1,064,643 7,335 3,891 3,443 $309 71,550 51,877 19,674 2026 $0 $1,064,643 7,481 3,969 3,512 $303 79,032 55,846 23,186 2027 $0 $1,064,643 7,631 4,048 3,583 $297 86,663 59,894 26,769 2028 $0 $1,064,643 7,784 4,129 3,654 $291 94,446 64,024 30,423 2029 $0 $1,064,643 7,939 4,212 3,727 $286 102,386 68,236 34,150 2030 102,386 68,236 34,150 2031 102,386 68,236 34,150 2032 102,386 68,236 34,150 2033 102,386 68,236 34,150 2034 102,386 68,236 34,150 2035 96,914 62,764 34,150 2036 91,332 57,182 34,150 2037 85,640 51,490 34,150 2038 79,254 45,104 34,150 2039 72,741 38,591 34,150 2040 66,098 35,067 31,031 2041 59,322 31,472 27,850 2042 52,410 27,805 24,605 2043 45,361 24,065 21,295 2044 38,170 20,250 17,920 2045 30,835 16,359 14,476 2046 23,354 12,390 10,964 2047 15,723 8,341 7,381 2048 7,939 4,212 3,727

$15,969,645 534,900 $30

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 

### Cost Effectiveness (CE) based on annual and cumulative CO**emissions from Wood Stoves**

Year3 

### Nationwide

Annual Cost1 

### Nationwide

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

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 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).Baseline CO Emissions2 (tons) NSPS CO

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6
20154 $1,336,900 $798,556 292 292 0 N/A 292 292 0 2016 $1,336,900 $798,556 298 298 0 N/A 590 590 0 2017 $1,336,900 $798,556 304 304 0 N/A 894 894 0 2018 $1,416,993 $798,556 310 310 0 N/A 1,205 1,205 0 2019 $1,416,993 $798,556 316 316 0 N/A 1,521 1,521 0 20204 $1,416,993 $798,556 323 143 179 $4,454 1,844 1,664 179 2021 $412,963 $798,556 329 146 183 $4,367 2,173 1,811 362 2022 $412,963 $798,556 336 149 187 $4,281 2,509 1,960 549 2023 $412,963 $798,556 342 152 190 $4,197 2,851 2,112 739 2024 $412,963 $798,556 349 155 194 $4,115 3,200 2,267 933 2025 $412,963 $798,556 356 158 198 $4,034 3,557 2,426 1,131 2026 $412,963 $798,556 363 162 202 $3,955 3,920 2,587 1,333 2027 $412,963 $798,556 371 165 206 $3,878 4,291 2,752 1,539 2028 $412,963 $798,556 378 168 210 $3,802 4,669 2,920 1,749 2029 $412,963 $798,556 386 171 214 $3,727 5,054 3,091 1,963 2030 5,054 3,091 1,963 2031 5,054 3,091 1,963 2032 5,054 3,091 1,963 2033 5,054 3,091 1,963 2034 5,054 3,091 1,963 2035 4,762 2,799 1,963 2036 4,464 2,501 1,963 2037 4,160 2,197 1,963 2038 3,850 1,887 1,963 2039 3,533 1,570 1,963 2040 3,211 1,427 1,784 2041 2,882 1,281 1,601 2042 2,546 1,131 1,414 2043 2,203 979 1,224 2044 1,854 824 1,030 2045 1,498 666 832 2046 1,134 504 630 2047 764 339 424 2048 386 171 214

$11,978,347 30,747 $390

4Estimated 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.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

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

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount pellet stoves already meeting the Step 2 limit (i.e., 70% of pellet stoves already meet the Step 2 limit). **Cost Effectiveness (CE) based on annual and cumulative CO emissions from Pellet Stoves** 

1Estimated 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.

2Estimated 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).

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

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline CO Emissions2 (tons) NSPS CO

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons) 20154 $932,093 $346,374 6,614 4,035 2,579 $134 6,614 4,035 2,579 2016 $932,093 $346,374 6,747 4,116 2,631 $132 13,361 8,151 5,210 2017 $932,093 $346,374 6,882 4,198 2,684 $129 20,243 12,349 7,894 2018 $601,557 $346,374 7,019 4,282 2,737 $127 27,262 16,631 10,631 2019 $601,557 $346,374 7,160 4,368 2,792 $124 34,422 20,999 13,423 20204 $601,557 $346,374 7,303 1,980 5,323 $65 41,725 22,979 18,746 2021 $66,074 $346,374 7,449 2,020 5,429 $64 49,174 24,999 24,175 2022 $66,074 $346,374 7,598 2,060 5,538 $63 56,772 27,059 29,713 2023 $66,074 $346,374 7,750 2,101 5,649 $61 64,522 29,160 35,361 2024 $66,074 $346,374 7,905 2,143 5,762 $60 72,427 31,304 41,123 2025 $66,074 $346,374 8,063 2,186 5,877 $59 80,490 33,490 47,000 2026 $66,074 $346,374 8,224 2,230 5,994 $58 88,714 35,720 52,994 2027 $66,074 $346,374 8,389 2,274 6,114 $57 97,103 37,994 59,109 2028 $66,074 $346,374 8,557 2,320 6,237 $56 105,659 40,314 65,345 2029 $66,074 $346,374 8,728 2,366 6,361 $54 114,387 42,680 71,706 2030 114,387 42,680 71,706 2031 114,387 42,680 71,706 2032 114,387 42,680 71,706 2033 114,387 42,680 71,706 2034 114,387 42,680 71,706 2035 107,772 38,645 69,127 2036 101,026 34,529 66,496 2037 94,144 30,331 63,813 2038 87,124 26,049 61,076 2039 79,965 21,681 58,284 2040 72,662 19,701 52,961 2041 65,213 17,681 47,531 2042 57,615 15,621 41,994 2043 49,865 13,520 36,345 2044 41,960 11,377 30,583 2045 33,897 9,191 24,706 2046 25,673 6,961 18,712 2047 17,284 4,686 12,598 2048 8,728 2,366 6,361

$5,195,617 1,020,825 $5

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

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespan **Cost Effectiveness (CE) based on annual and cumulative CO emissions from Single Burn Rate Stoves** 

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 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.

2Estimated 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).

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

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline CO Emissions2 (tons) NSPS CO

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6
20154 $4,930,601 $2,209,574 12,379 9,799 2,579 $857 12,379 9,799 2,579 2016 $4,930,601 $2,209,574 12,626 9,995 2,631 $840 25,005 19,795 5,210 2017 $4,930,601 $2,209,574 12,879 10,195 2,684 $823 37,883 29,990 7,894 2018 $4,680,157 $2,209,574 13,715 10,978 2,737 $807 51,598 40,967 10,631 2019 $4,680,157 $2,209,574 13,989 11,197 2,792 $791 65,587 52,164 13,423 20204 $4,680,157 $2,209,574 14,269 5,648 8,621 $256 79,856 57,812 22,044 2021 $479,037 $2,209,574 14,554 5,761 8,793 $251 94,410 63,573 30,837 2022 $479,037 $2,209,574 14,845 5,876 8,969 $246 109,255 69,449 39,806 2023 $479,037 $2,209,574 15,142 5,994 9,149 $242 124,398 75,443 48,955 2024 $479,037 $2,209,574 15,445 6,113 9,332 $237 139,843 81,556 58,286 2025 $479,037 $2,209,574 15,754 6,236 9,518 $232 155,597 87,792 67,805 2026 $479,037 $2,209,574 16,069 6,360 9,709 $228 171,666 94,153 77,513 2027 $479,037 $2,209,574 16,390 6,488 9,903 $223 188,056 100,640 87,416 2028 $479,037 $2,209,574 16,718 6,617 10,101 $219 204,774 107,258 97,517 2029 $479,037 $2,209,574 17,053 6,750 10,303 $214 221,827 114,007 107,819 2030 221,827 114,007 107,819 2031 221,827 114,007 107,819 2032 221,827 114,007 107,819 2033 221,827 114,007 107,819 2034 221,827 114,007 107,819 2035 209,448 104,208 105,240 2036 196,822 94,213 102,609 2037 183,943 84,018 99,926 2038 170,229 73,040 97,188 2039 156,240 61,843 94,397 2040 141,971 56,195 85,776 2041 127,417 50,434 76,982 2042 112,571 44,558 68,013 2043 97,429 38,565 58,865 2044 81,984 32,451 49,533 2045 66,230 26,215 40,015 2046 50,161 19,855 30,306 2047 33,771 13,367 20,404 2048 17,053 6,750 10,303

$33,143,609 1,586,472 $21 **Cost Effectiveness (CE) based on annual and cumulative CO emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)** 

Nationwide cumulative cost5

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 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.

2Estimated 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).

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. In order to not overestimate emission reductions resulting from the rule, for woodstoves and pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2020.

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters already meeting the Step 2 limit (i.e., 26% of wood stoves and 70% of pellet stoves are estimated to already meet the Step 2 limit). CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

3These heaters have in-home emitting lifespans of at least 20 years; thus room heaters shipped in 2029 will be emitting through 2048. Cumulative Emission Reduction over 20-year emitting lifespan Emission Reduction, cumulative per year Annual Snapshots

### Baseline CO Emissions2

### (tons) NSPS CO

Emissions2 

### (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons) 20154 

### $18,399,692 $5,563,663 37,366 37,366 0 N/A 37,366 37,366 0 20164 

### $18,399,692 $5,563,663 38,113 30,967 7,146 $779 75,479 68,333 7,146 20174 

### $11,071,171 $5,563,663 38,876 9,719 29,157 $191 114,355 78,052 36,303 2018 $11,087,642 $5,563,663 39,653 9,913 29,740 $187 154,008 87,965 66,043 2019 $11,087,642 $5,563,663 40,446 10,112 30,335 $183 194,454 98,077 96,377 20204 

### $11,087,642 $5,563,663 41,255 1,289 39,966 $139 235,709 99,366 136,343 2021 $257,941 $5,563,663 42,080 1,315 40,765 $136 277,789 100,681 177,108 2022 $257,941 $5,563,663 42,922 1,341 41,580 $134 320,711 102,022 218,689 2023 $257,941 $5,563,663 43,780 1,368 42,412 $131 364,491 103,390 261,101 2024 $257,941 $5,563,663 44,656 1,395 43,260 $129 409,147 104,786 304,361 2025 $257,941 $5,563,663 45,549 1,423 44,126 $126 454,696 106,209 348,487 2026 $257,941 $5,563,663 46,460 1,452 45,008 $124 501,156 107,661 393,495 2027 $257,941 $5,563,663 47,389 1,481 45,908 $121 548,545 109,142 439,403 2028 $257,941 $5,563,663 48,337 1,511 46,826 $119 596,882 110,653 486,230 2029 $257,941 $5,563,663 49,304 1,541 47,763 $116 646,186 112,193 533,992 2030 646,186 112,193 533,992 2031 646,186 112,193 533,992 2032 646,186 112,193 533,992 2033 646,186 112,193 533,992 2034 646,186 112,193 533,992 2035 608,820 74,827 533,992 2036 570,707 43,860 526,846 2037 531,831 34,141 497,690 2038 492,178 24,228 467,950 2039 451,732 14,117 437,615 2040 410,477 12,827 397,649 2041 368,396 11,512 356,884 2042 325,475 10,171 315,304 2043 281,694 8,803 272,891 2044 237,039 7,407 229,631 2045 191,490 5,984 185,506 2046 145,030 4,532 140,498 2047 97,641 3,051 94,589 2048 49,304 1,541 47,763

$83,454,951 7,708,763 $11

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 **Cost Effectiveness (CE) based on annual and cumulative CO 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). 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.conference-board.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. Year3 

### Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline CO Emissions2

### (tons) NSPS CO

Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $21,892,380 $9,136,293.29 20,567 2,057 18,511 $494 20,567 2,057 18,511 2016 $21,892,380 $9,136,293.29 20,979 2,098 18,881 $484 41,546 4,155 37,391 2017 $21,892,380 $9,136,293.29 21,398 2,140 19,258 $474 62,944 6,294 56,650 2018 $21,931,910 $9,136,293.29 21,826 2,183 19,644 $465 84,770 8,477 76,293 2019 $21,931,910 $9,136,293.29 22,263 2,226 20,036 $456 107,033 10,703 96,329 20204 

### $21,931,910 $9,136,293.29 22,708 710 21,998 $415 129,741 11,413 118,328 2021 $619,059 $9,136,293.29 23,162 724 22,438 $407 152,903 12,137 140,766 2022 $619,059 $9,136,293.29 23,625 738 22,887 $399 176,528 12,875 163,653 2023 $619,059 $9,136,293.29 24,098 753 23,345 $391 200,626 13,628 186,998 2024 $619,059 $9,136,293.29 24,580 768 23,812 $384 225,205 14,396 210,809 2025 $619,059 $9,136,293.29 25,071 783 24,288 $376 250,277 15,180 235,097 2026 $619,059 $9,136,293.29 25,573 799 24,774 $369 275,850 15,979 259,871 2027 $619,059 $9,136,293.29 26,084 815 25,269 $362 301,934 16,794 285,140 2028 $619,059 $9,136,293.29 26,606 831 25,774 $354 328,540 17,625 310,914 2029 $619,059 $9,136,293.29 27,138 848 26,290 $348 355,678 18,473 337,204 2030 355,678 18,473 337,204 2031 355,678 18,473 337,204 2032 355,678 18,473 337,204 2033 355,678 18,473 337,204 2034 355,678 18,473 337,204 2035 335,111 16,417 318,694 2036 314,132 14,319 299,813 2037 292,734 12,179 280,555 2038 270,908 9,996 260,911 2039 248,645 7,770 240,875 2040 225,937 7,061 218,877 2041 202,775 6,337 196,438 2042 179,150 5,598 173,551 2043 155,052 4,845 150,207 2044 130,472 4,077 126,395 2045 105,401 3,294 102,107 2046 79,828 2,495 77,334 20473 

### 53,744 1,679 52,064 20483 

### 27,138 848 26,290

$137,044,399 4,547,337 $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 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).**Cost Effectiveness (CE) based on annual and cumulative CO 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.conference-board.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 yearBaseline CO Emissions2(tons) NSPS CO

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6
20154 $40,292,072 $14,699,957 57,933 39,423 18,511 $794 57,933 39,423 18,511 20164 $40,292,072 $14,699,957 59,092 33,065 26,027 $565 117,025 72,488 44,537 20174 $32,963,552 $14,699,957 60,274 11,859 48,415 $304 177,299 84,346 92,953 2018 $33,019,552 $14,699,957 61,479 12,096 49,383 $298 238,778 96,442 142,336 2019 $33,019,552 $14,699,957 62,709 12,338 50,371 $292 301,487 108,780 192,707 20204 $33,019,552 $14,699,957 63,963 1,999 61,964 $237 365,450 110,779 254,671 2021 $877,000 $14,699,957 65,242 2,039 63,203 $233 430,692 112,818 317,874 2022 $877,000 $14,699,957 66,547 2,080 64,467 $228 497,239 114,897 382,342 2023 $877,000 $14,699,957 67,878 2,121 65,757 $224 565,117 117,019 448,099 2024 $877,000 $14,699,957 69,236 2,164 67,072 $219 634,353 119,182 515,171 2025 $877,000 $14,699,957 70,620 2,207 68,413 $215 704,973 121,389 583,584 2026 $877,000 $14,699,957 72,033 2,251 69,782 $211 777,006 123,640 653,366 2027 $877,000 $14,699,957 73,473 2,296 71,177 $207 850,479 125,936 724,543 2028 $877,000 $14,699,957 74,943 2,342 72,601 $202 925,422 128,278 797,144 2029 $877,000 $14,699,957 76,442 2,389 74,053 $199 1,001,864 130,667 871,197 2030 1,001,864 130,667 871,197 2031 1,001,864 130,667 871,197 2032 1,001,864 130,667 871,197 2033 1,001,864 130,667 871,197 2034 1,001,864 130,667 871,197 2035 943,930 91,244 852,686 2036 884,839 58,179 826,659 2037 824,565 46,320 778,244 2038 763,086 34,225 728,861 2039 700,377 21,887 678,490 2040 636,414 19,888 616,526 2041 571,172 17,849 553,322 2042 504,624 15,770 488,855 2043 436,746 13,648 423,098 2044 367,511 11,485 356,026 2045 296,891 9,278 287,613 2046 224,858 7,027 217,831 20473 151,385 4,731 146,654 20483 76,442 2,389 74,053

$220,499,351 12,256,100 $18 **Cost Effectiveness (CE) based on annual and cumulative CO emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)** 

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. 1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 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.

2Estimated 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).

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

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton) Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount central heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are estimated to already meet the Step 2 limit). Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespanBaseline CO Emissions2 (tons) NSPS CO

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline CO

Emissions (tons) NSPS CO

Emissions (tons) Emission

Reduction (tons)6
20154 $45,222,674 $16,909,531 70,312 49,222 21,090 $802 70,312 49,222 21,090 20164 $45,222,674 $16,909,531 71,718 43,060 28,658 $590 142,030 92,282 49,748 20174 $37,894,153 $16,909,531 73,152 22,054 51,099 $331 215,182 114,336 100,846 2018 $37,699,709 $16,909,531 75,194 23,073 52,121 $324 290,376 137,410 152,967 2019 $37,699,709 $16,909,531 76,698 23,535 53,163 $318 367,074 160,945 206,130 20204 $37,699,709 $16,909,531 78,232 7,647 70,585 $240 445,306 168,591 276,715 2021 $1,356,037 $16,909,531 79,796 7,800 71,997 $235 525,102 176,391 348,711 2022 $1,356,037 $16,909,531 81,392 7,956 73,437 $230 606,495 184,347 422,148 2023 $1,356,037 $16,909,531 83,020 8,115 74,905 $226 689,515 192,461 497,053 2024 $1,356,037 $16,909,531 84,681 8,277 76,404 $221 774,195 200,738 573,457 2025 $1,356,037 $16,909,531 86,374 8,443 77,932 $217 860,570 209,181 651,389 2026 $1,356,037 $16,909,531 88,102 8,611 79,490 $213 948,671 217,793 730,879 2027 $1,356,037 $16,909,531 89,864 8,784 81,080 $209 1,038,535 226,576 811,959 2028 $1,356,037 $16,909,531 91,661 8,959 82,702 $204 1,130,196 235,536 894,660 2029 $1,356,037 $16,909,531 93,494 9,139 84,356 $200 1,223,690 244,674 979,016 2030 1,223,690 244,674 979,016 2031 1,223,690 244,674 979,016 2032 1,223,690 244,674 979,016 2033 1,223,690 244,674 979,016 2034 1,223,690 244,674 979,016 2035 1,153,379 195,452 957,926 2036 1,081,660 152,392 929,268 2037 1,008,508 130,338 878,170 2038 933,314 107,265 826,049 2039 856,616 83,730 772,887 2040 778,384 76,083 702,301 2041 698,588 68,283 630,305 2042 617,196 60,328 556,868 2043 534,176 52,213 481,963 2044 449,495 43,936 405,559 2045 363,121 35,493 327,628 2046 275,019 26,882 248,137 20473 185,155 18,098 167,057 20483 93,494 9,139 84,356

$253,642,960 13,842,572 $18 Nationwide Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 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.

2Estimated 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).

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

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit (i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit). **Cost Effectiveness (CE) based on annual and cumulative CO emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves,**  **Pellet Stoves, and Single Burn Rate Stoves)**
CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton) Emission Reduction, cumulative per year

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

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. Year3 Nationwide

Annual Cost1