# 12/2/2010, revised 12/3/2012 and 1/5/2013

**DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation**
**R&D Annual Cost Summary Development of 4 Model Fireboxes**  6-year R&D Period **Direct Annual Costs (DAC)**

Operator labor $141,667Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years.

Outside Consultants $26,667Annual outside consultant cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. **Total Direct Costs (DC)** $168,333
**Indirect Annual Costs (IAC)**

Laboratory Equipment1 

# $10,490The laboratory equipment cost of $50,000 was amortized over 6 years at an interest rate of 7%.
Re-tooling1 

# $25,175The re-tooling cost of $120,000 was amortized over 6 years at an interest rate of 7%.

Other Capital Costs1, 2 

# $51,400Other capital costs include costs for prototypes ($25,000), test fuel ($30,000+$15,000), testing services ($100,000+$50,000), and marketing ($25,000) and were amortized over 6 years at an interest rate of 7%.
**Total Indirect Costs (IAC)** $87,065

**Total Annual Cost** $255,399Annual cost for development of 4 model fireboxes. **Total Annual Cost** $63,850Average annual cost per firebox model.

1

# An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's estimate that approximately 6 years of R&D are required to bring a product to market .

2

# To conservatively estimate the additional cost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib only was increased by $15,000 and the testing services estimate of $100,000 based on crib only (which covered not only emissions testing but also efficiency and safety testing) was increased by $50,000.

# 0.34

Note: Fraction that Capital Cost is of Total Cost =**Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2013-2018) and through model lifespan (2019-2038)**

2013 (Step 1

compliance) 2014 2015 2016 2017 2018 (Step 2 compliance) 2019 2020 through

20382 2013 (Step 1 compliance) 2014 2015 2016 2017 2018 (Step 2 compliance) 2019 2020 through

20382 Wood Stoves (R&D)3 34 125 $223,004 $223,004 $223,004 $223,004 $223,004 $223,004 $0 $0 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $0 $0 Pellet Stoves (R&D, R&R)4,8 29 125 $199,681 $199,681 $199,681 $199,681 $199,681 $199,681 $7,031 $7,031 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $203,909 $203,909 Pellet Stoves (certification)4 29 125 $2,586 $2,586 $2,586 $2,586 $2,586 $2,586 $8,621 $8,621 $75,000 $75,000 $75,000 $75,000 $75,000 $75,000 $250,000 $250,000 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $862,204 $862,204 $436,539 $436,539 $436,539 $436,539 $24,208 $24,208 $2,586,611 $2,586,611 $1,309,618 $1,309,618 $1,309,618 $1,309,618 $72,625 $72,625 $16,034,510$16,034,510$14,757,517$14,757,517$14,757,517 $14,757,517 $526,534 $526,534 Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $917,148 $917,148 $461,079 $461,079 $461,079 $461,079 $33,582 $33,582 $6,420,038 $6,420,038 $3,227,556 $3,227,556 $3,227,556 $3,227,556 $235,073 $235,073 Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $258,204 $258,204 $258,204 $258,204 $258,204 $258,204 $18,806 $18,806 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $564,176 $564,176 $14,166,171$14,166,171$10,973,689$10,973,689$10,973,689 $10,973,689 $799,249 $799,249 MH - large companies (R&D, R&R, cert.)9 2 4 $130,169 $130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469 $260,337 $260,337 $260,337 $260,337 $260,337 $260,337 $12,939 $12,939 MH - large companies (R&R, cert.)9 3 9 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 MH - large companies (R&R, software cert.)7, 9 1 8 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 MH - small companies (R&R, software cert.)7, 9 42 85 $3,852 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $462,616 $417,466 $417,466 $417,466 $417,466 $417,466 $170,067 $170,067 Period Nationwide Cost of the Rule R&D year average (2013-

2018) $27,646,022 $30,663,297$30,618,147$26,148,672$26,148,672$26,148,672 $26,148,672$1,495,850$1,495,850 Year 2022 $1,495,850 Cumulative (2013 through 2038) $195,793,135 NSPS Subpart Appliance Type

7For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer. Annual Cost of the Rule

6For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 2 so that approximately 100% of the models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2019. 1Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2013 through 2018). Ongoing certification costs are incurred through 2038 (based on a model brought to market in 2019 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

2Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

3This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 2 already so that 95% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2020 through 2038 exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing NSPS.

4For pellet stoves, the analysis assumes that 30% meet Step 2 already so that 70% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2013. The analysis reflects the certification costs beginning in 2013 for the 30% of models meeting Step 2, and beginning in 2019 for the remaining 70% of models which underwent R&D re-design.

5Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more stringent 2019 Step 2 standard.

8Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496.
9Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872. Average Annual Cost per Manufacturer based on 6-year R&D round (2013-2018) to meet Step 1 and Step 2 limits with ongoing certification costs (through 2038)

# Manufacturers # Models Nationwide Annual Costs1

QQQQ: Central Heaters

RRRR: Masonry Heaters AAA: Room Heaters

## SCC **Appliance Population**  **Total Tons Burned Emission Inventory Category**  **Pollutant Baseline**  **Emission factor**  **(lb/ton) Baseline** 

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

**Tons/appl 2014** 

**Step 1 Emission**  **Factor** 2104008220 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Volatile Organic Compounds 15 3,121 0.0073 15 2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Volatile Organic Compounds 12 9,240 0.0106 12 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Volatile Organic Compounds 15 5,817 0.0155 15 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Volatile Organic Compounds 0.041 24 0.00000.041 2,206,470 4,668,250Single Burn Rate Stoves Volatile Organic Compounds 53 123,709 0.0561 12 2104008610 364,560 3,654,153Hydronic heater: outdoor Volatile Organic Compounds 11.7 21,377 0.0586 1.17 2104008510 351,023 2,624,115Furnace: indoor, cordwood Volatile Organic Compounds 11.7 15,351 0.04372.925 0.0086Baseline 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 82,36784,01585,69587,409 Single Burn Rate Stoves 40,000 25,560 24,538 25,028 25,529 26,03926,56027,09127,633 Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,87686,57488,30590,072 Furnace: indoor, cordwood 41,000 26,199 25,151 25,654 26,167 26,69027,22427,76928,324 Hydronic Heating Systems 13,385 8,553 8,211 8,375 8,543 8,713 8,888 9,065 9,247

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 1,085 693 666 679 692 706 720 735 750 Single Burn Rate Stoves 2,243 1,433 1,376 1,403 1,431 1,460 1,489 1,519 1,549 Pellet Stoves 4 2 2 2 2 2 2 3 3 Furnace: indoor, cordwood 1,793 1,146 1,100 1,122 1,144 1,167 1,191 1,214 1,239 Hydronic Heating Systems 785 502 481 491 501 511 521 532 542 Total **5,909 3,776**  **3,625 3,697**  **3,771 3,847**  **3,924 4,002**  **4,082 Table 4. Estimated Annual Shipped Units** 

**Table 5. Estimated VOC Emissions (Tons) -- Baseline**Baseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons) 20133 $5,466,157$16,034,510$3,908,837 20144 $5,466,157$16,034,510$3,908,837 2,212 1,060 1,152 $3,393 2,212 1,060 1,152 20154 $5,030,830$14,757,517$3,908,837 2,256 1,081 1,175 $3,327 4,468 2,141 2,327 20164 $5,030,830$14,757,517$3,908,837 2,301 1,103 1,199 $3,261 6,770 3,244 3,526 20174 $5,030,830$14,757,517$3,908,837 2,347 1,125 1,222 $3,197 9,117 4,369 4,748 20184 $5,030,830$14,757,517$3,908,837 2,394 1,147 1,247 $3,135 11,512 5,517 5,995 2019 $0 $526,534 $3,908,837 2,442 400 2,042 $1,914 13,954 5,917 8,037 2020 $0 $526,534 $3,908,837 2,491 408 2,083 $1,877 16,445 6,325 10,120 2021 $0 $526,534 $3,908,837 2,541 417 2,124 $1,840 18,986 6,742 12,244 2022 $0 $526,534 $3,908,837 2,592 425 2,167 $1,804 21,578 7,167 14,411 2023 $0 $526,534 $3,908,837 2,644 433 2,210 $1,769 24,221 7,600 16,621 2024 $0 $526,534 $3,908,837 2,696 442 2,254 $1,734 26,918 8,042 18,875 2025 $0 $526,534 $3,908,837 2,750 451 2,299 $1,700 29,668 8,493 21,175 2026 $0 $526,534 $3,908,837 2,805 460 2,345 $1,667 32,473 8,953 23,520 2027 $0 $526,534 $3,908,837 2,862 469 2,392 $1,634 35,335 9,422 25,913 2028 $0 $526,534 $3,908,837 2,919 478 2,440 $1,602 38,254 9,901 28,353 2029 $0 $526,534 $3,908,837 2,977 488 2,489 $1,570 41,231 10,389 30,842 2030 $0 $526,534 $3,908,837 3,037 498 2,539 $1,540 44,267 10,887 33,381 2031 $0 $526,534 $3,908,837 3,097 508 2,590 $1,509 47,365 11,394 35,971 2032 $0 $526,534 $3,908,837 3,159 518 2,641 $1,480 50,524 11,912 38,612 2033 $0 $526,534 $3,908,837 3,223 528 2,694 $1,451 53,747 12,441 41,306 2034 $0 $526,534 $3,908,837 3,287 539 2,748 $1,422 54,822 11,919 42,902 2035 $0 $526,534 $3,908,837 3,353 550 2,803 $1,394 55,918 11,388 44,530 2036 $0 $526,534 $3,908,837 3,420 561 2,859 $1,367 57,036 10,845 46,191 2037 $0 $526,534 $3,908,837 3,488 572 2,916 $1,340 58,177 10,292 47,885 2038 $0 $526,534 $3,908,837 3,558 583 2,975 $1,314 59,341 9,728 49,613 2039 56,898 9,328 47,571 2040 54,407 8,919 45,488 2041 51,866 8,503 43,364 2042 49,275 8,078 41,197 2043 46,631 7,645 38,986 2044 43,935 7,203 36,732 2045 41,184 6,752 34,433 2046 38,379 6,292 32,087 2047 35,517 5,823 29,695 2048 32,599 5,344 27,254 2049 29,621 4,856 24,765 2050 26,585 4,358 22,227 2051 23,487 3,850 19,637 2052 20,328 3,333 16,996 2053 17,106 2,804 14,301 2054 13,819 2,265 11,553 2055 10,466 1,716 8,750 2056 7,046 1,155 5,891 2057 3,558 583 2,975

$101,629,772 553,513 $184 **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC 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 proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves and pellet stoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 2014 through 2018. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2019. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Cumulative Emission Reduction over 20-year stove lifespan Emission Reduction, cumulative per year Annual SnapshotsBaseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons)Emission

Reduction (tons) 20133$2,584,750$7,582,146$1,749,726 20144$2,584,750$7,582,146$1,749,726 720 720 0 N/A 720 720 0 20154$2,584,750$7,582,146$1,749,726 735 735 0 N/A 1,455 1,455 0 20164$2,584,750$7,582,146$1,749,726 750 750 0 N/A 2,205 2,205 0 20174$2,584,750$7,582,146$1,749,726 765 765 0 N/A 2,969 2,969 0 20184$2,584,750$7,582,146$1,749,726 780 780 0 N/A 3,749 3,749 0 2019 $0 $0 $1,749,726 795 293 503 $3,480 4,545 4,042 503 2020 $0 $0 $1,749,726 811 298 513 $3,412 5,356 4,340 1,016 2021 $0 $0 $1,749,726 828 304 523 $3,345 6,183 4,645 1,539 2022 $0 $0 $1,749,726 844 311 534 $3,279 7,028 4,955 2,072 2023 $0 $0 $1,749,726 861 317 544 $3,215 7,889 5,272 2,616 2024 $0 $0 $1,749,726 878 323 555 $3,152 8,767 5,595 3,172 2025 $0 $0 $1,749,726 896 330 566 $3,090 9,663 5,925 3,738 2026 $0 $0 $1,749,726 914 336 578 $3,030 10,576 6,261 4,315 2027 $0 $0 $1,749,726 932 343 589 $2,970 11,508 6,604 4,904 2028 $0 $0 $1,749,726 951 350 601 $2,912 12,459 6,954 5,505 2029 $0 $0 $1,749,726 970 357 613 $2,855 13,428 7,310 6,118 2030 $0 $0 $1,749,726 989 364 625 $2,799 14,417 7,674 6,743 2031 $0 $0 $1,749,726 1,009 371 638 $2,744 15,426 8,045 7,381 2032 $0 $0 $1,749,726 1,029 379 650 $2,690 16,455 8,424 8,031 2033 $0 $0 $1,749,726 1,050 386 663 $2,637 17,505 8,810 8,695 2034 $0 $0 $1,749,726 1,071 394 677 $2,586 17,855 8,483 9,371 2035 $0 $0 $1,749,726 1,092 402 690 $2,535 18,212 8,150 10,062 2036 $0 $0 $1,749,726 1,114 410 704 $2,485 18,576 7,811 10,766 2037 $0 $0 $1,749,726 1,136 418 718 $2,437 18,948 7,464 11,484 2038 $0 $0 $1,749,726 1,159 426 732 $2,389 19,327 7,110 12,216 2039 18,531 6,818 11,713 2040 17,720 6,519 11,201 2041 16,892 6,215 10,678 2042 16,048 5,904 10,144 2043 15,187 5,588 9,600 2044 14,309 5,264 9,045 2045 13,413 4,935 8,478 2046 12,500 4,599 7,901 2047 11,568 4,256 7,312 2048 10,617 3,906 6,711 2049 9,647 3,549 6,098 2050 8,658 3,185 5,473 2051 7,650 2,814 4,835 2052 6,621 2,436 4,185 2053 5,571 2,050 3,521 2054 4,501 1,656 2,845 2055 3,409 1,254 2,155 2056 2,295 844 1,451 2057 1,159 426 732

$45,492,874 136,293 $334

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Cumulative Emission Reduction over 20-year stove lifespan Nationwide cumulative cost5 **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Wood Stoves**

Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year
CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)Baseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons) 20133 $1,999,632$5,865,753$1,702,796 20144 $1,999,632$5,865,753$1,702,796 2 2 0 N/A 2 2 0 20154 $1,999,632$5,865,753$1,702,796 3 3 0 N/A 5 5 0 20164 $1,999,632$5,865,753$1,702,796 3 3 0 N/A 8 8 0 20174 $1,999,632$5,865,753$1,702,796 3 3 0 N/A 10 10 0 20184 $1,999,632$5,865,753$1,702,796 3 3 0 N/A 13 13 0 2019 $0 $453,909 $1,702,796 3 1 1 $1,177,050 16 14 1 2020 $0 $453,909 $1,702,796 3 1 1 $1,153,971 18 15 3 2021 $0 $453,909 $1,702,796 3 1 2 $1,131,344 21 17 4 2022 $0 $453,909 $1,702,796 3 1 2 $1,109,161 24 18 6 2023 $0 $453,909 $1,702,796 3 1 2 $1,087,412 27 19 8 2024 $0 $453,909 $1,702,796 3 1 2 $1,066,090 30 21 9 2025 $0 $453,909 $1,702,796 3 1 2 $1,045,187 33 22 11 2026 $0 $453,909 $1,702,796 3 1 2 $1,024,693 36 24 12 2027 $0 $453,909 $1,702,796 3 1 2 $1,004,601 39 25 14 2028 $0 $453,909 $1,702,796 3 2 2 $984,903 43 27 16 2029 $0 $453,909 $1,702,796 3 2 2 $965,591 46 28 18 2030 $0 $453,909 $1,702,796 3 2 2 $946,658 49 30 19 2031 $0 $453,909 $1,702,796 3 2 2 $928,096 53 31 21 2032 $0 $453,909 $1,702,796 4 2 2 $909,898 56 33 23 2033 $0 $453,909 $1,702,796 4 2 2 $892,057 60 35 25 2034 $0 $453,909 $1,702,796 4 2 2 $874,566 61 34 27 2035 $0 $453,909 $1,702,796 4 2 2 $857,417 62 33 29 2036 $0 $453,909 $1,702,796 4 2 2 $840,605 64 33 31 2037 $0 $453,909 $1,702,796 4 2 2 $824,123 65 32 33 2038 $0 $453,909 $1,702,796 4 2 2 $807,963 66 31 35 2039 63 30 34 2040 61 28 32 2041 58 27 31 2042 55 26 29 2043 52 24 28 2044 49 23 26 2045 46 21 24 2046 43 20 23 2047 40 19 21 2048 36 17 19 2049 33 15 18 2050 30 14 16 2051 26 12 14 2052 23 11 12 2053 19 9 10 2054 15 7 8 2055 12 5 6 2056 8 4 4 2057 4 2 2

$44,272,694 392 $112,894

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For pellet stoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Pellet Stoves**

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline VOC Emissions2 

### (tons) NSPS VOC

Emissions2 

### (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons)NSPS VOC

Emissions (tons) Emission

Reduction (tons) 20133 

### $881,775$2,586,611 $456,316 20144 

### $881,775$2,586,611 $456,316 1,489 337 1,152 $396 1,489 337 1,152 2015 $446,448$1,309,618 $456,316 1,519 344 1,175 $388 3,008 681 2,327 2016 $446,448$1,309,618 $456,316 1,549 351 1,199 $381 4,557 1,032 3,526 2017 $446,448$1,309,618 $456,316 1,580 358 1,222 $373 6,138 1,390 4,748 2018 $446,448$1,309,618 $456,316 1,612 365 1,247 $366 7,750 1,755 5,995 20194 

### $0 $72,625 $456,316 1,644 106 1,538 $297 9,394 1,861 7,533 2020 $0 $72,625 $456,316 1,677 109 1,568 $291 11,071 1,970 9,101 2021 $0 $72,625 $456,316 1,711 111 1,600 $285 12,781 2,080 10,701 2022 $0 $72,625 $456,316 1,745 113 1,632 $280 14,526 2,193 12,333 2023 $0 $72,625 $456,316 1,780 115 1,664 $274 16,306 2,309 13,997 2024 $0 $72,625 $456,316 1,815 118 1,698 $269 18,121 2,426 15,695 2025 $0 $72,625 $456,316 1,852 120 1,732 $264 19,972 2,546 17,426 2026 $0 $72,625 $456,316 1,889 122 1,766 $258 21,861 2,668 19,193 2027 $0 $72,625 $456,316 1,926 125 1,802 $253 23,787 2,793 20,994 2028 $0 $72,625 $456,316 1,965 127 1,838 $248 25,752 2,920 22,832 2029 $0 $72,625 $456,316 2,004 130 1,874 $243 27,756 3,050 24,706 2030 $0 $72,625 $456,316 2,044 132 1,912 $239 29,801 3,183 26,618 2031 $0 $72,625 $456,316 2,085 135 1,950 $234 31,886 3,318 28,568 2032 $0 $72,625 $456,316 2,127 138 1,989 $229 34,013 3,455 30,557 2033 $0 $72,625 $456,316 2,169 140 2,029 $225 36,182 3,596 32,586 2034 $0 $72,625 $456,316 2,213 143 2,069 $220 36,906 3,402 33,504 2035 $0 $72,625 $456,316 2,257 146 2,111 $216 37,644 3,204 34,440 2036 $0 $72,625 $456,316 2,302 149 2,153 $212 38,397 3,002 35,394 2037 $0 $72,625 $456,316 2,348 152 2,196 $208 39,165 2,797 36,368 2038 $0 $72,625 $456,316 2,395 155 2,240 $204 39,948 2,587 37,361 2039 38,304 2,480 35,823 2040 36,627 2,372 34,255 2041 34,916 2,261 32,655 2042 33,172 2,148 31,024 2043 31,392 2,033 29,359 2044 29,577 1,915 27,661 2045 27,725 1,795 25,930 2046 25,836 1,673 24,163 2047 23,910 1,548 22,362 2048 21,945 1,421 20,524 2049 19,941 1,291 18,650 2050 17,897 1,159 16,738 2051 15,812 1,024 14,788 2052 13,685 886 12,799 2053 11,515 746 10,770 2054 9,303 602 8,700 2055 7,046 456 6,589 2056 4,743 307 4,436 2057 2,395 155 2,240

$11,864,204 416,828 $28

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Single Burn Rate Stoves**

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

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

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons)Emission

Reduction (tons) 20133 $4,829,241$14,166,171$3,392,772 20144 $4,829,241$14,166,171$3,392,772 1,712 350 1,362 $2,491 1,712 350 1,362 2015 $3,740,925$10,973,689$3,392,772 1,746 357 1,389 $2,442 3,458 707 2,751 2016 $3,740,925$10,973,689$3,392,772 1,781 364 1,417 $2,394 5,239 1,070 4,168 2017 $3,740,925$10,973,689$3,392,772 1,817 371 1,445 $2,347 7,055 1,442 5,614 2018 $3,740,925$10,973,689$3,392,772 1,853 379 1,474 $2,301 8,908 1,820 7,088 20194 $0 $799,249 $3,392,772 1,890 38 1,852 $1,832 10,798 1,858 8,940 2020 $0 $799,249 $3,392,772 1,928 39 1,889 $1,796 12,726 1,897 10,829 2021 $0 $799,249 $3,392,772 1,966 39 1,927 $1,761 14,692 1,936 12,756 2022 $0 $799,249 $3,392,772 2,006 40 1,965 $1,726 16,697 1,976 14,721 2023 $0 $799,249 $3,392,772 2,046 41 2,005 $1,692 18,743 2,017 16,726 2024 $0 $799,249 $3,392,772 2,087 42 2,045 $1,659 20,830 2,059 18,771 2025 $0 $799,249 $3,392,772 2,128 43 2,086 $1,627 22,958 2,101 20,857 2026 $0 $799,249 $3,392,772 2,171 43 2,127 $1,595 25,129 2,145 22,984 2027 $0 $799,249 $3,392,772 2,214 44 2,170 $1,563 27,343 2,189 25,154 2028 $0 $799,249 $3,392,772 2,259 45 2,213 $1,533 29,602 2,234 27,368 2029 $0 $799,249 $3,392,772 2,304 46 2,258 $1,503 31,906 2,280 29,625 2030 $0 $799,249 $3,392,772 2,350 47 2,303 $1,473 34,255 2,327 31,928 2031 $0 $799,249 $3,392,772 2,397 48 2,349 $1,444 36,652 2,375 34,277 2032 $0 $799,249 $3,392,772 2,445 49 2,396 $1,416 39,097 2,424 36,673 2033 $0 $799,249 $3,392,772 2,494 50 2,444 $1,388 41,591 2,474 39,117 2034 $0 $799,249 $3,392,772 2,544 51 2,493 $1,361 42,422 2,175 40,248 2035 $0 $799,249 $3,392,772 2,594 52 2,543 $1,334 43,271 1,870 41,401 2036 $0 $799,249 $3,392,772 2,646 53 2,593 $1,308 44,136 1,559 42,577 2037 $0 $799,249 $3,392,772 2,699 54 2,645 $1,283 45,019 1,242 43,777 2038 $0 $799,249 $3,392,772 2,753 55 2,698 $1,257 45,919 918 45,001 2039 44,030 881 43,149 2040 42,102 842 41,260 2041 40,136 803 39,333 2042 38,130 763 37,367 2043 36,084 722 35,363 2044 33,998 680 33,318 2045 31,869 637 31,232 2046 29,699 594 29,105 2047 27,484 550 26,935 2048 25,226 505 24,721 2049 22,922 458 22,463 2050 20,572 411 20,161 2051 18,175 364 17,812 2052 15,730 315 15,416 2053 13,237 265 12,972 2054 10,693 214 10,479 2055 8,099 162 7,937 2056 5,452 109 5,343 2057 2,753 55 2,698

$88,212,079 502,064 $176 Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC 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 proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. 1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton) Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline VOC Emissions2

### (tons)NSPS VOC

Emissions2 

### (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons)NSPS VOC

Emissions (tons)Emission

Reduction (tons) 20133 

### $2,188,588$6,420,038 $1,171,222 20144 

### $2,188,588$6,420,038 $1,171,222 1,191 298 893 $1,312 1,191 298 893 2015 $1,100,272$3,227,556 $1,171,222 1,214 304 911 $1,286 2,405 601 1,804 2016 $1,100,272$3,227,556 $1,171,222 1,239 310 929 $1,261 3,644 911 2,733 2017 $1,100,272$3,227,556 $1,171,222 1,263 316 948 $1,236 4,907 1,227 3,680 2018 $1,100,272$3,227,556 $1,171,222 1,289 322 967 $1,212 6,196 1,549 4,647 20194 

### $0 $235,073 $1,171,222 1,315 26 1,288 $909 7,510 1,575 5,935 2020 $0 $235,073 $1,171,222 1,341 27 1,314 $891 8,851 1,602 7,249 2021 $0 $235,073 $1,171,222 1,368 27 1,340 $874 10,219 1,629 8,589 2022 $0 $235,073 $1,171,222 1,395 28 1,367 $857 11,614 1,657 9,956 2023 $0 $235,073 $1,171,222 1,423 28 1,394 $840 13,037 1,686 11,351 2024 $0 $235,073 $1,171,222 1,451 29 1,422 $823 14,488 1,715 12,773 2025 $0 $235,073 $1,171,222 1,480 30 1,451 $807 15,968 1,744 14,224 2026 $0 $235,073 $1,171,222 1,510 30 1,480 $792 17,478 1,775 15,704 2027 $0 $235,073 $1,171,222 1,540 31 1,509 $776 19,018 1,805 17,213 2028 $0 $235,073 $1,171,222 1,571 31 1,540 $761 20,589 1,837 18,752 2029 $0 $235,073 $1,171,222 1,602 32 1,570 $746 22,192 1,869 20,323 2030 $0 $235,073 $1,171,222 1,634 33 1,602 $731 23,826 1,902 21,924 2031 $0 $235,073 $1,171,222 1,667 33 1,634 $717 25,493 1,935 23,558 2032 $0 $235,073 $1,171,222 1,700 34 1,666 $703 27,194 1,969 25,225 2033 $0 $235,073 $1,171,222 1,734 35 1,700 $689 28,928 2,004 26,924 2034 $0 $235,073 $1,171,222 1,769 35 1,734 $676 29,507 1,741 27,765 2035 $0 $235,073 $1,171,222 1,805 36 1,768 $662 30,097 1,474 28,623 2036 $0 $235,073 $1,171,222 1,841 37 1,804 $649 30,699 1,201 29,498 2037 $0 $235,073 $1,171,222 1,877 38 1,840 $637 31,313 923 30,390 2038 $0 $235,073 $1,171,222 1,915 38 1,877 $624 31,939 639 31,300 2039 30,624 612 30,012 2040 29,284 586 28,698 2041 27,916 558 27,358 2042 26,521 530 25,991 2043 25,098 502 24,596 2044 23,647 473 23,174 2045 22,167 443 21,723 2046 20,657 413 20,243 2047 19,116 382 18,734 2048 17,545 351 17,195 2049 15,943 319 15,624 2050 14,309 286 14,023 2051 12,642 253 12,389 2052 10,941 219 10,722 2053 9,207 184 9,023 2054 7,438 149 7,289 2055 5,633 113 5,520 2056 3,792 76 3,717 2057 1,915 38 1,877

$30,451,763 349,207 $87

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Forced Air Furnaces**

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline VOC Emissions2 

### (tons) NSPS VOC

Emissions2 

### (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons)NSPS VOC

Emissions (tons)Emission

Reduction (tons) 20133 

### $2,640,653$7,746,133$2,221,551 20144 

### $2,640,653$7,746,133$2,221,551 521 52 469 $4,736 521 52 469 2015 $2,640,653$7,746,133$2,221,551 532 53 478 $4,644 1,053 105 947 2016 $2,640,653$7,746,133$2,221,551 542 54 488 $4,552 1,595 159 1,435 2017 $2,640,653$7,746,133$2,221,551 553 55 498 $4,463 2,148 215 1,933 2018 $2,640,653$7,746,133$2,221,551 564 56 508 $4,376 2,712 271 2,441 20194 

### $0 $564,176 $2,221,551 575 12 564 $3,940 3,287 283 3,005 2020 $0 $564,176 $2,221,551 587 12 575 $3,862 3,874 294 3,580 2021 $0 $564,176 $2,221,551 599 12 587 $3,787 4,473 306 4,167 2022 $0 $564,176 $2,221,551 611 12 598 $3,712 5,084 319 4,765 2023 $0 $564,176 $2,221,551 623 12 610 $3,640 5,706 331 5,375 2024 $0 $564,176 $2,221,551 635 13 623 $3,568 6,342 344 5,998 2025 $0 $564,176 $2,221,551 648 13 635 $3,498 6,990 357 6,633 2026 $0 $564,176 $2,221,551 661 13 648 $3,430 7,651 370 7,281 2027 $0 $564,176 $2,221,551 674 13 661 $3,363 8,325 383 7,941 2028 $0 $564,176 $2,221,551 688 14 674 $3,297 9,013 397 8,615 2029 $0 $564,176 $2,221,551 701 14 687 $3,232 9,714 411 9,303 2030 $0 $564,176 $2,221,551 715 14 701 $3,169 10,429 426 10,004 2031 $0 $564,176 $2,221,551 730 15 715 $3,106 11,159 440 10,719 2032 $0 $564,176 $2,221,551 744 15 729 $3,046 11,903 455 11,448 2033 $0 $564,176 $2,221,551 759 15 744 $2,986 12,663 470 12,192 2034 $0 $564,176 $2,221,551 774 15 759 $2,927 12,916 434 12,482 2035 $0 $564,176 $2,221,551 790 16 774 $2,870 13,174 396 12,778 2036 $0 $564,176 $2,221,551 806 16 790 $2,814 13,438 358 13,080 2037 $0 $564,176 $2,221,551 822 16 805 $2,758 13,706 319 13,387 2038 $0 $564,176 $2,221,551 838 17 821 $2,704 13,981 280 13,701 2039 13,405 268 13,137 2040 12,818 256 12,562 2041 12,220 244 11,975 2042 11,609 232 11,377 2043 10,986 220 10,766 2044 10,351 207 10,144 2045 9,703 194 9,509 2046 9,042 181 8,861 2047 8,368 167 8,200 2048 7,680 154 7,527 2049 6,979 140 6,839 2050 6,263 125 6,138 2051 5,534 111 5,423 2052 4,789 96 4,693 2053 4,030 81 3,949 2054 3,256 65 3,191 2055 2,466 49 2,416 2056 1,660 33 1,627 2057 838 17 821

$57,760,316 152,858 $378

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Hydronic Heating Systems**

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

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

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons)NSPS VOC

Emissions (tons)Emission

Reduction (tons) 20133$10,295,398$30,200,681$7,301,610 20144$10,295,398$30,200,681$7,301,610 3,924 1,410 2,514 $2,904 3,924 1,410 2,514 2015 $8,771,756$25,731,206$7,301,610 4,002 1,438 2,564 $2,847 7,926 2,848 5,078 2016 $8,771,756$25,731,206$7,301,610 4,082 1,467 2,616 $2,792 12,008 4,315 7,694 2017 $8,771,756$25,731,206$7,301,610 4,164 1,496 2,668 $2,737 16,172 5,811 10,362 2018 $8,771,756$25,731,206$7,301,610 4,247 1,526 2,721 $2,683 20,419 7,337 13,083 20194 $0 $1,325,783 $7,301,610 4,332 438 3,894 $1,875 24,752 7,775 16,977 2020 $0 $1,325,783 $7,301,610 4,419 447 3,972 $1,838 29,170 8,222 20,949 2021 $0 $1,325,783 $7,301,610 4,507 456 4,051 $1,802 33,678 8,678 25,000 2022 $0 $1,325,783 $7,301,610 4,597 465 4,132 $1,767 38,275 9,143 29,132 2023 $0 $1,325,783 $7,301,610 4,689 474 4,215 $1,732 42,964 9,617 33,347 2024 $0 $1,325,783 $7,301,610 4,783 484 4,299 $1,698 47,747 10,101 37,646 2025 $0 $1,325,783 $7,301,610 4,879 493 4,385 $1,665 52,626 10,594 42,032 2026 $0 $1,325,783 $7,301,610 4,976 503 4,473 $1,632 57,602 11,098 46,505 2027 $0 $1,325,783 $7,301,610 5,076 513 4,562 $1,600 62,678 11,611 51,067 2028 $0 $1,325,783 $7,301,610 5,177 524 4,654 $1,569 67,855 12,135 55,721 2029 $0 $1,325,783 $7,301,610 5,281 534 4,747 $1,538 73,136 12,669 60,467 2030 $0 $1,325,783 $7,301,610 5,387 545 4,842 $1,508 78,523 13,214 65,309 2031 $0 $1,325,783 $7,301,610 5,494 556 4,939 $1,479 84,017 13,769 70,248 2032 $0 $1,325,783 $7,301,610 5,604 567 5,037 $1,450 89,621 14,336 75,285 2033 $0 $1,325,783 $7,301,610 5,716 578 5,138 $1,421 95,337 14,914 80,423 2034 $0 $1,325,783 $7,301,610 5,831 590 5,241 $1,393 97,244 14,094 83,150 2035 $0 $1,325,783 $7,301,610 5,947 602 5,346 $1,366 99,189 13,258 85,931 2036 $0 $1,325,783 $7,301,610 6,066 614 5,453 $1,339 101,173 12,405 88,768 2037 $0 $1,325,783 $7,301,610 6,187 626 5,562 $1,313 103,196 11,534 91,662 2038 $0 $1,325,783 $7,301,610 6,311 638 5,673 $1,287 105,260 10,647 94,614 2039 100,928 10,208 90,720 2040 96,509 9,761 86,748 2041 92,002 9,306 82,696 2042 87,405 8,841 78,564 2043 82,715 8,366 74,349 2044 77,932 7,882 70,050 2045 73,054 7,389 65,665 2046 68,077 6,886 61,192 2047 63,002 6,372 56,629 2048 57,824 5,849 51,976 2049 52,543 5,315 47,229 2050 47,157 4,770 42,387 2051 41,663 4,214 37,449 2052 36,058 3,647 32,411 2053 30,342 3,069 27,273 2054 24,512 2,479 22,032 2055 18,565 1,878 16,687 2056 12,499 1,264 11,234 2057 6,311 638 5,673

$189,841,851 1,055,577 $180

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-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 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. No emission reductions are estimated to result from woodstoves and pellet stoves until 2019, although emission reductions are estimated for all other devices starting in 2014 . **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC 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 stove lifespan (per ton) Emission Reduction, cumulative per year

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