Notes Notes

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

Capital Costs Capital Costs

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

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 45,500 19,000 32,250

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 91,000 38,000 64,500

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

construct final prototypes, safety test check. 

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

construct final prototypes, safety test check. 

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

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

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

 Tooling Tooling

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

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

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

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

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

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

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

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

Fixed Costs per model Fixed Costs per model

 Certification Certification

EPA testing, Confirmation safety testing or full 

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

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

EPA testing, Confirmation safety testing or full 

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

HBPA costs for personal at lab 

and travel expenses not 

accepted as independent third 

party testing costs

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

 Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS

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

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

Annualized capital cost per model 37,492 20,057 28,774

annualized over 6 years at 3% 

interest (note: NERA annualized 

over 10 years) Annualized capital cost per model 59,643 32,240 45,942

annualized over 6 years at 37% 

interest (note: NERA annualized 

over 10 years)

Annual cost for development of 4 models 149,967 80,226 115,097 Annual cost for development of 4 models 238,574 128,960 183,767

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 180,000 115,000 147,500

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

Modify prototype 16,000 9,000 12,500

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

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

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

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

 Manuracturing/Manufacturing Engineering

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

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

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

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

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

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

 Other Capital Cost components

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

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

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

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

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

Fixed Costs per model

 Certification

Hydronic Heaters & Forced-Air 

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

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

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

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

 Roll-out 0 0 0

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

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

Annualized capital cost per model 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 costs106,000

 Other Capital Cost components

Purchased parts sourcing 41,000

Test first production heaters 200,000

HPBA costs for equipment and 

integration not included because these 

are considered duplicative of R&D 

costs, above Equipment and facilities 75,000

 Other Capital Cost components total costs 316,000

Total Capital Cost per model 2,336,000

Fixed Costs per model

 Certification

Forced air furnaces, First 2 ye

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

travel expenses not accepted as 

independent third party testing costs

EPA testing, Confirmation safety testing or full safety 

testing, shipping of prototype 72,500

Owner's manual, labeling 6,500

 Certification Total Costs 79,000

roll-out considered normal business 

operation and not due to NSPS Roll-out 0

Total Fixed Capital Cost per model 79,000

Total Costs per Model 2,415,000

annualized over 6 years at 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

230,000 295,000

5,000 7,000

18,000 25,000

820,000 1,025,000

177,000 222,000

12,000 14,000

1,262,000 1,588,000

App. A (NERA) concludes 

erroneously $887,000 for high 

cost and $581,000 for low cost.

13,000 17,500

28,000 36,500

5,000 7,500

15,000 20,000

2,000 3,000

63,000 84,500

23,500 32,250

150,000 175,000

25,000 50,000

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

198,500 257,250

1,523,500 1,929,750

Forced air furnaces, First 2 years 

(doubled R&D / Engineering 

costs)
36,000 54,250

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

3,500 5,000

39,500 59,250

0 0

roll-out considered normal 

business operation and not due 

to NSPS

39,500 59,250

1,563,000 1,989,000

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)334 125 $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.)7,830 120 $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: 

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

Annual Cost of the Rule

6

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

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

5

Based on conversations with industry (e.g., 2/8/13), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2014 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters (respectively) this 

analysis assumes that these efforts will intensify in 2015 and 2016. Therefore estimated R&D costs are doubled in 2015 and 2016 to reflect model development to meet the more stringent 2020 Step 2 standard. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis 

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

4

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

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

3

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

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

2

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

7

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

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

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

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

are estimated beginning in 2015.
SCC

Appliance 

Population

Total Tons 

Burned Emission Inventory Category Pollutant

Baseline 

Emission 

factor 

(lb/ton)

Baseline 

Emissions 

(tons)

Baseline 

Tons/appl

2015 Step 

1 

Emission 

Factor

2104008220 1,303,142 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Carbon Monoxide 140.8 86,323 0.0662 140.8

2104008230 427,224 416,187 Woodstove: fireplace inserts; EPA certified; catalytic Carbon Monoxide 104.4 21,725 0.0509 104.4

2104008320 873,357 1,540,026 Woodstove: freestanding, EPA certified, non-catalytic Carbon Monoxide 140.8 108,418 0.1241 140.8

2104008330 374,154 775,602 Woodstove: freestanding, EPA certified, catalytic Carbon Monoxide 104.4 40,486 0.1082 104.4

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Carbon Monoxide 15.9 9,344 0.0110 15.9

2,206,470 4,668,250 Single Burn Rate Stoves Carbon Monoxide 230.8 538,716 0.2442 140.8

2104008610 364,560 3,654,153 Hydronic heater: outdoor Carbon Monoxide 360 657,748 1.8042 36

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Carbon Monoxide 360 472,341 1.3456 90

0.0863 Baseline 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

2015 4$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

2020 4$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 

Nationwide cumulative cost over 20-year emitting lifespan 5 

 Cost Effectiveness (CE) based on annual and cumulative CO 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 ). 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). 
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

2015 4$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

2020 4$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

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).

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

2015 4$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

2020 4$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

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 

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

2015 4$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

2020 4$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 

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.conference-board.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. 

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
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)

2015 4$18,399,692 $5,563,663 37,366 37,366 0 N/A 37,366 37,366 0

2016 4$18,399,692 $5,563,663 38,113 30,967 7,146 $779 75,479 68,333 7,146

2017 4$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

2020 4$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). 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.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.

Year 3

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

2015 4$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

2020 4$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

2047 3

53,744 1,679 52,064

2048 3

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). 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.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 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

2015 4$40,292,072 $14,699,957 57,933 39,423 18,511 $794 57,933 39,423 18,511

2016 4$40,292,072 $14,699,957 59,092 33,065 26,027 $565 117,025 72,488 44,537

2017 4$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

2020 4$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

2047 3

151,385 4,731 146,654

2048 3

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)

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.conference-board.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 

Year lifespan (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 
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

2015 4$45,222,674 $16,909,531 70,312 49,222 21,090 $802 70,312 49,222 21,090

2016 4$45,222,674 $16,909,531 71,718 43,060 28,658 $590 142,030 92,282 49,748

2017 4$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

2020 4$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

2047 3 185,155 18,098 167,057

2048 393,494 9,139 84,356

$253,642,960 13,842,572 $18

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.conference-board.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).

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 

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