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 $141,667

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates 

of Residential Wood Heating Appliances", spread over 6 years. 

Outside Consultants $26,667

Annual 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$10,490

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

an interest rate of 7%. 

Re-tooling1$25,175

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

rate of 7%.

Other Capital Costs1, 2 $51,400

Other capital costs include costs for prototypes ($25,000), test fuel 

($30,000+$15,000), testing services ($100,000+$50,000), and marketing 

($25,000) and were amortized over 6 years at an interest rate of 7%. 

Total Indirect Costs (IAC) $87,065

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

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

1

An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's 

estimate that approximately 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 

203822013

(Step 1 

compliance) 

2014 2015 2016 2017 2018

(Step 2 

compliance) 

2019

2020 through 

20382

Wood Stoves (R&D)334 125 $223,004 $223,004 $223,004 $223,004 $223,004 $223,004 $0 $0 $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)429 125 $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.)92 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.)93 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

7 For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software 

certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer.

Annual Cost of the Rule

6

 For 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.

1 Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2013 through 2018). Ongoing certification costs are incurred through 2038 (based on a model brought to market in 2019 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

2

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

3

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

4

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

costs beginning in 2013 for the 30% of models meeting Step 2, and beginning in 2019 for the remaining 70% of models which underwent R&D re-design.

5

Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis 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.

8

 Reporting 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.

9

 Reporting 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 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12

2104008230 427,224 416,187 Woodstove: fireplace inserts; EPA certified; catalytic Volatile Organic Compounds 15 3,121 0.0073 15

2104008320 873,357 1,540,026 Woodstove: freestanding, EPA certified, non-catalytic Volatile Organic Compounds 12 9,240 0.0106 12

2104008330 374,154 775,602 Woodstove: freestanding, EPA certified, catalytic Volatile Organic Compounds 15 5,817 0.0155 15

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Volatile Organic Compounds 0.041 24 0.0000 0.041

2,206,470 4,668,250 Single Burn Rate Stoves Volatile Organic Compounds 53 123,709 0.0561 12

2104008610 364,560 3,654,153 Hydronic heater: outdoor Volatile Organic Compounds 11.7 21,377 0.0586 1.17

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Volatile Organic Compounds 11.7 15,351 0.0437 2.925

0.0086 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 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)

2013 3$5,466,157 $16,034,510 $3,908,837

2014 4$5,466,157 $16,034,510 $3,908,837 2,212 1,060 1,152 $3,393 2,212 1,060 1,152

2015 4$5,030,830 $14,757,517 $3,908,837 2,256 1,081 1,175 $3,327 4,468 2,141 2,327

2016 4$5,030,830 $14,757,517 $3,908,837 2,301 1,103 1,199 $3,261 6,770 3,244 3,526

2017 4$5,030,830 $14,757,517 $3,908,837 2,347 1,125 1,222 $3,197 9,117 4,369 4,748

2018 4$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 

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.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

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). Years 2039 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.conferenceboard.org/data/globaloutlook.cfm). 

4

 Estimated 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)

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.

Cumulative Emission Reduction 

over 20-year stove lifespan 

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)

2013 3

$2,584,750 $7,582,146 $1,749,726

2014 4

$2,584,750 $7,582,146 $1,749,726 720 720 0 N/A 720 720 0

2015 4

$2,584,750 $7,582,146 $1,749,726 735 735 0 N/A 1,455 1,455 0

2016 4

$2,584,750 $7,582,146 $1,749,726 750 750 0 N/A 2,205 2,205 0

2017 4

$2,584,750 $7,582,146 $1,749,726 765 765 0 N/A 2,969 2,969 0

2018 4

$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

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). Years 2039 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.

4

 Estimated 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.

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.

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year stove lifespan 5 

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Wood Stoves

Year

Annual 

Capital Costs

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 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)

2013 3

$1,999,632 $5,865,753 $1,702,796

2014 4

$1,999,632 $5,865,753 $1,702,796 2 2 0 N/A 2 2 0

2015 4

$1,999,632 $5,865,753 $1,702,796 3 3 0 N/A 5 5 0

2016 4

$1,999,632 $5,865,753 $1,702,796 3 3 0 N/A 8 8 0

2017 4

$1,999,632 $5,865,753 $1,702,796 3 3 0 N/A 10 10 0

2018 4

$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

4

 Estimated 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.

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 Pellet 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). Years 2039 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 Costs

Nationwide 

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)

2013 3$881,775 $2,586,611 $456,316

2014 4$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

2019 4$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). Years 2039 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 Costs

Nationwide 

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)

2013 3

$4,829,241 $14,166,171 $3,392,772

2014 4

$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

2019 4

$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

Nationwide cumulative cost $88,212,079 502,064 $176 5 

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)

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.

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). Years 2039 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.conferenceboard.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.

4

 Estimated 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 

Year lifespan (per ton)

Annual 

Capital Costs

Nationwide 

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)

2013 3

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

2014 4

$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

2019 4

$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). Years 2039 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 Costs

Nationwide 

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)

2013 3

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

2014 4

$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

2019 4

$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). Years 2039 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 Costs

Nationwide 

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)

2013 3$10,295,398 $30,200,681 $7,301,610

2014 4$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

2019 4$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

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.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots

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). Years 2039 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.

4

 Estimated 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