E

C

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122

MEMORANDUM

DATE: February 26, 2013

SUBJECT: Residential Wood Heater Cost Effectiveness Analysis

FROM: Jill Mozier, EC/R Inc.

Beth Friedman, EC/R Inc.

TO: Gil Wood, EPA/OAQPS

David Cole, EPA/OAQPS

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

emission reduction options being considered for residential wood heaters as part of the New 

Source Performance Standards (NSPS) review of residential wood heaters. We analyzed the CE 

of two options: the proposed NSPS (“Proposal”) and an alternative approach (“Alternative”) that 

differ in the number of stepped emission limits and in the phased-in compliance dates. These 

options and their underlying emission and cost assumptions have already been summarized in the 

emissions1, unit cost2, and manufacturer cost3 memos. This memo will explain how we applied 

the derived cost and emission estimates (based on our already-documented assumptions) in our 

CE analyses.

I. Application of Cost Estimates to CE Analysis 

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

As noted in our manufacturer cost memo, under the Proposal scenario, one round of R&D 

is assumed – beginning in 2013 and ending in 2018 – in order to meet the proposed Step 2 limit. 

Under the Alternative scenario, two rounds of R&D are assumed for all appliances except 

masonry heaters (for which there is only one standard with no additional phased-in standards to 

meet). It should be noted that for the second round of R&D (in the Alternative scenario), for 

purposes of our CE analysis, we adjusted the annualized cost because we assumed that 

manufacturers would use the same lab equipment purchased for the first round of R&D. 

Therefore the round two annualized costs exclude the laboratory equipment cost, and 

consequently are estimated at $61,227 (per year for 6 years) rather than the $63,850 annual 

estimate for round one, as shown in Table 1.

 

1 Memo to Gil Wood, USEPA, from EC/R, Inc. Estimated Emissions from Wood Heaters. February 15, 2013.

2 Memo to Gil Wood, USEPA, from EC/R, Inc. Unit Cost Estimates of Residential Wood Heating Appliances. 

February 21, 2013.

3 Memo to Gil Wood, USEPA, from EC/R, Inc. Estimated Residential Wood Heater Manufacturer Cost Impacts. 

February 22, 2013.
2

Under both the Proposal and the Alternative, we made assumptions regarding the number 

of model lines that would undergo R&D and assume the related costs. In cases where we 

assumed less than 100% of the models would undergo R&D (e.g., wood stoves and pellet 

stoves), this was based on the percentage of models already meeting the proposed 2019 Step 2 

limit/Alternative 2022 Step 3 limit. In reality, more appliances than we assumed have models 

meeting the most stringent limit (e.g., hydronic heaters). Furthermore, manufacturers will likely

consolidate their model lines, focusing on models able to achieve the limit, rather than incur 

R&D costs for every existing non-compliant model line. Notwithstanding these points, in order 

to reasonably estimate what might happen in our CE analyses, we assumed the following 

appliance model lines would incur NSPS-related R&D costs beginning in 2013:

 95% of wood stove manufacturers (with an estimated 125 models representing both 

catalytic and noncatalytic designs);

 70% of pellet stove manufacturers (with an estimated 125 models);

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

doubling of R&D costs in 2013 and 2014 to represent intensification of R&D efforts for 

this previously unregulated appliance type;

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

doubling of R&D costs in 2013 and 2014 to represent intensification of R&D efforts for 

this previously unregulated appliance type;

 100% of hydronic heater manufacturers (with an estimated 120 models); and

 Two large masonry heater manufacturers (with an estimated 4 models) would incur R&D 

costs beginning in 2013 with 9 other large manufacturer models facing certification 

testing costs (spread out over the 5 year certification period), and the remaining 8 large 

manufacturer models and 85 small custom manufacturer models facing software 

certification costs beginning in 2013.
3

Table 1. Annual Cost Summary: Development of 4 Model Fireboxes

Round One 

6-year R&D 

Period

Round Two

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. $141,667

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. $26,667

Total Direct Costs (DC) $168,333 $168,333

Indirect Annual Costs (IAC)

Laboratory Equipment

1, 2 $10,490

The laboratory equipment cost of $50,000 was 

amortized over 6 years at an interest rate of 7%. $0

Re-tooling

1

$25,175

The re-tooling cost of $120,000 was amortized

over 6 years at an interest rate of 7%. $25,175

Other Capital Costs1, 3 $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%. $51,400

Total Indirect Costs (IAC) $87,065 $76,575

Round One Round Two

2

Total Annual Cost $255,399 Annual cost for development of 4 model fireboxes. $244,909

Total Annual Cost $63,850 Average annual cost per firebox model. $61,227

3 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.

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

 It is assumed that the same lab equipment can be used for round two R&D, so the round two costs exclude the

lab equipment cost.
4

For the Alternative scenario, we made the further assumption that by 2017 all 

manufacturers (except masonry heater manufacturers who face only one stepped NSPS limit 

under both the Proposal and Alternative) would begin a second round of R&D for 80% of their 

models (i.e., we assumed that only 20% of models achieve the strictest limit in the first round of 

R&D). This meant that during 2017 and 2018, we assumed an overlapping period of NSPSrelated R&D amortized costs.

As noted in the manufacturer cost memo, all manufacturers, except for wood stoves that 

are subject to the current 1988 NSPS, will face ongoing certification costs above baseline 

conditions. However, in the 2013 to 2018 timeframe under the Proposal scenario and in the 2013 

to 2022 timeframe under the Alternative scenario, we have incorporated these costs as part of the 

overall R&D expenditures. After 2018 under the Proposal scenario and after 2022 under the 

Alternative scenario, the ongoing certification costs will be the only NSPS related costs faced by 

manufacturers besides ongoing reporting and recordkeeping costs. 

We based reporting and recordkeeping (R&R) costs on the annual average costs derived 

from development of the Information Collection Request (ICR) supporting statements4. These 

are annual estimates of the ongoing R&R burden to manufacturers associated with the Proposal 

and Alternative scenarios. (We do not expect the R&R burden to differ substantially between the 

two scenarios.) 

B. Model Design Lifespan

We assumed a 20-year model design lifespan. We made this assumption to best

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

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

working parts with merely exterior cosmetic changes. Therefore, beyond the 6-year amortization 

period of the round(s) of R&D, we estimated the certification and reporting and recordkeeping 

costs to be incurred by manufacturers for the full 20-year model design lifespan. Under the 

Proposal, we estimated costs from 2013 through 2038 – that is, 20 years after the 2019 

compliance year marking the beginning of the model lifespan designed to meet the Proposal Step 

2 limit. Under the Alternative, we estimated costs from 2013 through 2041 – that is, 20 years 

after the 2022 compliance year marking the beginning of the model lifespan designed to meet the 

Alternative Step 3 limit.

II. Application of Emission Estimates to CE Analysis

A. Baseline and NSPS emission estimates

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

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

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

NSPS) and under each NSPS scenario (Proposal and Alternative). The emission estimates 

assume that the total number of shipped units meet the standard in the year the standard is 

implemented. This simplifying assumption means that we underestimated how soon emission 

reductions will happen under both NSPS scenarios. In reality, some models will meet the NSPS 

 

4

ICR Supporting Statements for the Proposed NSPS Subparts have not been finalized as of the date of this memo.
5

limits prior to the NSPS compliance year and will therefore be emitting less than baseline levels 

prior to that year as well. Our emission estimates represent the assumption that models do not 

come into compliance until the year they are required to; therefore we do not claim emission 

reductions from either NSPS scenario until each compliance year. Furthermore, based on 

available data for wood stoves and pellet stoves, we assumed that baseline emissions for both of 

these appliance types are already at the Step 1 level. We therefore claimed no emission 

reductions for wood stoves and pellet stoves until the 2019 Step 2 under the Proposal and the 

2017 Step 2 under the Alternative.

B. Appliance Emitting Lifespan

As noted above, we assumed a 20-year model design lifespan for estimating costs. We 

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

characterize the actual use lifespan given that most stoves in consumer homes emit for at least 20 

years and often much longer. Our CE analysis therefore tracks emission reductions out through 

2057 for the Proposal and through 2060 for the Alternative, assuming a 20 year design life for a 

model meeting each phased-in limit, and assuming that stoves shipped in the 20th year of design 

life will be emitting in homes for another 20 years. Note that our CE analysis incorporates 

“trailing emissions” as part of our 20 year lifespan assumptions. For example, our analysis 

assumes that a stove shipped in 2014 will emit in homes for 20 years – or until 2033 (inclusive of 

both 2014 and 2023). We therefore drop emissions from this stove in our analysis in year 2034. 

Likewise, we drop emissions for a stove shipped in 2015 in year 2035, and so on.

III. Resulting CE Tables

Tables 2 through 9 show the results of our CE analyses based on PM2.5 reductions under 

the Proposal for each appliance, for appliances grouped by subparts AAA (Room Heaters) and 

QQQQ (Central Heaters), and for Subparts AAA and QQQQ combined. Tables 10 through 17 

show the results of our CE analyses based on PM2.5 reductions under the Alternative. Each table 

shown is based on a 7% interest rate applied to the amortized costs during the R&D periods. We 

also prepared tables based on a 3% interest rate. Finally, we prepared both sets of tables based 

on VOC emissions and based on CO emissions. 

Note that, as of the date of this memo, we did not calculate the CE for masonry heaters 

because we were unable to estimate the tons of emissions per appliance for this appliance type; 

so while we estimated the NSPS-related costs we did not estimate baseline or NSPS related 

emissions.
6

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

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

2014 4$5,466,157 $16,034,510 $3,908,837 1,549 935 614 $6,370 1,549 935 614

2015 4$5,030,830 $14,757,517 $3,908,837 1,580 954 626 $6,245 3,129 1,889 1,240

2016 4$5,030,830 $14,757,517 $3,908,837 1,611 973 638 $6,123 4,740 2,862 1,878

2017 4$5,030,830 $14,757,517 $3,908,837 1,644 992 651 $6,003 6,384 3,854 2,529

2018 4$5,030,830 $14,757,517 $3,908,837 1,677 1,012 664 $5,885 8,060 4,867 3,193

2019 $0 $526,534 $3,908,837 1,710 374 1,336 $2,927 9,770 5,241 4,529

2020 $0 $526,534 $3,908,837 1,744 382 1,362 $2,869 11,514 5,623 5,891

2021 $0 $526,534 $3,908,837 1,779 390 1,390 $2,813 13,294 6,013 7,281

2022 $0 $526,534 $3,908,837 1,815 397 1,417 $2,758 15,108 6,410 8,698

2023 $0 $526,534 $3,908,837 1,851 405 1,446 $2,704 16,959 6,815 10,144

2024 $0 $526,534 $3,908,837 1,888 413 1,475 $2,651 18,847 7,229 11,618

2025 $0 $526,534 $3,908,837 1,926 422 1,504 $2,599 20,773 7,651 13,122

2026 $0 $526,534 $3,908,837 1,964 430 1,534 $2,548 22,737 8,081 14,657

2027 $0 $526,534 $3,908,837 2,004 439 1,565 $2,498 24,741 8,519 16,221

2028 $0 $526,534 $3,908,837 2,044 448 1,596 $2,449 26,785 8,967 17,818

2029 $0 $526,534 $3,908,837 2,085 456 1,628 $2,401 28,869 9,423 19,446

2030 $0 $526,534 $3,908,837 2,126 466 1,661 $2,354 30,995 9,889 21,106

2031 $0 $526,534 $3,908,837 2,169 475 1,694 $2,308 33,164 10,364 22,800

2032 $0 $526,534 $3,908,837 2,212 484 1,728 $2,262 35,376 10,848 24,528

2033 $0 $526,534 $3,908,837 2,256 494 1,762 $2,218 37,632 11,342 26,290

2034 $0 $526,534 $3,908,837 2,301 504 1,798 $2,175 38,385 10,911 27,474

2035 $0 $526,534 $3,908,837 2,348 514 1,833 $2,132 39,153 10,471 28,681

2036 $0 $526,534 $3,908,837 2,394 524 1,870 $2,090 39,936 10,023 29,913

2037 $0 $526,534 $3,908,837 2,442 535 1,908 $2,049 40,735 9,565 31,169

2038 $0 $526,534 $3,908,837 2,491 546 1,946 $2,009 41,549 9,098 32,451

2039 39,839 8,724 31,115

2040 38,095 8,342 29,753

2041 36,316 7,952 28,364

2042 34,501 7,555 26,946

2043 32,650 7,150 25,501

2044 30,762 6,736 24,026

2045 28,836 6,315 22,522

2046 26,872 5,884 20,988

2047 24,869 5,446 19,423

2048 22,825 4,998 17,827

2049 20,740 4,542 16,199

2050 18,614 4,076 14,538

2051 16,445 3,601 12,844

2052 14,233 3,117 11,117

2053 11,977 2,623 9,354

2054 9,675 2,119 7,557

2055 7,328 1,605 5,723

2056 4,934 1,080 3,853

2057 2,491 546 1,946

$101,629,772 362,045 $281

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

Table 2. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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). 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). 

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.
7

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,584,750 $7,582,146 $1,749,726

2014 4$2,584,750 $7,582,146 $1,749,726 505 505 0 N/A 505 505 0

2015 4$2,584,750 $7,582,146 $1,749,726 515 515 0 N/A 1,021 1,021 0

2016 4$2,584,750 $7,582,146 $1,749,726 526 526 0 N/A 1,546 1,546 0

2017 4$2,584,750 $7,582,146 $1,749,726 536 536 0 N/A 2,082 2,082 0

2018 4$2,584,750 $7,582,146 $1,749,726 547 547 0 N/A 2,629 2,629 0

2019 $0 $0 $1,749,726 558 202 356 $4,914 3,187 2,831 356

2020 $0 $0 $1,749,726 569 206 363 $4,818 3,756 3,037 719

2021 $0 $0 $1,749,726 580 210 370 $4,723 4,336 3,247 1,090

2022 $0 $0 $1,749,726 592 214 378 $4,631 4,928 3,461 1,468

2023 $0 $0 $1,749,726 604 218 385 $4,540 5,532 3,679 1,853

2024 $0 $0 $1,749,726 616 223 393 $4,451 6,148 3,902 2,246

2025 $0 $0 $1,749,726 628 227 401 $4,363 6,776 4,129 2,647

2026 $0 $0 $1,749,726 641 232 409 $4,278 7,417 4,361 3,056

2027 $0 $0 $1,749,726 654 236 417 $4,194 8,071 4,597 3,473

2028 $0 $0 $1,749,726 667 241 426 $4,112 8,737 4,838 3,899

2029 $0 $0 $1,749,726 680 246 434 $4,031 9,417 5,084 4,333

2030 $0 $0 $1,749,726 694 251 443 $3,952 10,111 5,335 4,776

2031 $0 $0 $1,749,726 707 256 452 $3,875 10,818 5,591 5,227

2032 $0 $0 $1,749,726 722 261 461 $3,799 11,540 5,852 5,688

2033 $0 $0 $1,749,726 736 266 470 $3,724 12,276 6,118 6,158

2034 $0 $0 $1,749,726 751 272 479 $3,651 12,522 5,885 6,637

2035 $0 $0 $1,749,726 766 277 489 $3,580 12,772 5,646 7,126

2036 $0 $0 $1,749,726 781 283 499 $3,509 13,027 5,403 7,624

2037 $0 $0 $1,749,726 797 288 509 $3,441 13,288 5,155 8,133

2038 $0 $0 $1,749,726 813 294 519 $3,373 13,554 4,902 8,652

2039 12,996 4,700 8,295

2040 12,427 4,495 7,932

2041 11,847 4,285 7,562

2042 11,255 4,071 7,184

2043 10,651 3,852 6,799

2044 10,035 3,629 6,405

2045 9,407 3,402 6,004

2046 8,766 3,170 5,595

2047 8,112 2,934 5,178

2048 7,446 2,693 4,753

2049 6,766 2,447 4,319

2050 6,072 2,196 3,876

2051 5,365 1,940 3,424

2052 4,643 1,679 2,964

2053 3,907 1,413 2,494

2054 3,156 1,142 2,015

2055 2,390 865 1,526

2056 1,609 582 1,027

2057 813 294 519

$45,492,874 96,523 $471

Table 3 DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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)

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.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. 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 over 20-year stove

Nationwide cumulative cost lifespan 

5 
8

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$1,999,632 $5,865,753 $1,702,796

2014 4$1,999,632 $5,865,753 $1,702,796 184 184 0 N/A 184 184 0

2015 4$1,999,632 $5,865,753 $1,702,796 187 187 0 N/A 371 371 0

2016 4$1,999,632 $5,865,753 $1,702,796 191 191 0 N/A 563 563 0

2017 4$1,999,632 $5,865,753 $1,702,796 195 195 0 N/A 758 758 0

2018 4$1,999,632 $5,865,753 $1,702,796 199 199 0 N/A 957 957 0

2019 $0 $453,909 $1,702,796 203 95 108 $15,771 1,160 1,052 108

2020 $0 $453,909 $1,702,796 207 97 110 $15,462 1,367 1,148 218

2021 $0 $453,909 $1,702,796 211 99 112 $15,159 1,578 1,247 330

2022 $0 $453,909 $1,702,796 215 101 115 $14,861 1,793 1,348 445

2023 $0 $453,909 $1,702,796 220 103 117 $14,570 2,013 1,451 562

2024 $0 $453,909 $1,702,796 224 105 119 $14,284 2,237 1,556 681

2025 $0 $453,909 $1,702,796 229 107 122 $14,004 2,465 1,663 803

2026 $0 $453,909 $1,702,796 233 109 124 $13,730 2,699 1,772 927

2027 $0 $453,909 $1,702,796 238 111 127 $13,460 2,936 1,883 1,053

2028 $0 $453,909 $1,702,796 243 114 129 $13,196 3,179 1,997 1,182

2029 $0 $453,909 $1,702,796 247 116 132 $12,938 3,426 2,112 1,314

2030 $0 $453,909 $1,702,796 252 118 134 $12,684 3,679 2,231 1,448

2031 $0 $453,909 $1,702,796 257 120 137 $12,435 3,936 2,351 1,585

2032 $0 $453,909 $1,702,796 263 123 140 $12,191 4,199 2,474 1,725

2033 $0 $453,909 $1,702,796 268 125 142 $11,952 4,466 2,599 1,867

2034 $0 $453,909 $1,702,796 273 128 145 $11,718 4,556 2,543 2,012

2035 $0 $453,909 $1,702,796 279 130 148 $11,488 4,647 2,486 2,161

2036 $0 $453,909 $1,702,796 284 133 151 $11,263 4,740 2,428 2,312

2037 $0 $453,909 $1,702,796 290 136 154 $11,042 4,835 2,368 2,466

2038 $0 $453,909 $1,702,796 296 138 157 $10,826 4,931 2,308 2,623

2039 4,728 2,213 2,515

2040 4,521 2,116 2,405

2041 4,310 2,017 2,293

2042 4,095 1,916 2,178

2043 3,875 1,814 2,062

2044 3,651 1,709 1,942

2045 3,422 1,602 1,821

2046 3,189 1,493 1,697

2047 2,951 1,381 1,570

2048 2,709 1,268 1,441

2049 2,462 1,152 1,310

2050 2,209 1,034 1,175

2051 1,952 913 1,038

2052 1,689 791 899

2053 1,421 665 756

2054 1,148 537 611

2055 870 407 463

2056 586 274 312

2057 296 138 157

$44,272,694 29,269 $1,513

Table 4. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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.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.

Year

Annual 

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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 
9

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

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

2014 4$881,775 $2,586,611 $456,316 860 246 614 $744 860 246 614

2015 $446,448 $1,309,618 $456,316 877 251 626 $729 1,737 497 1,240

2016 $446,448 $1,309,618 $456,316 895 256 638 $715 2,631 753 1,878

2017 $446,448 $1,309,618 $456,316 912 261 651 $701 3,544 1,014 2,529

2018 $446,448 $1,309,618 $456,316 931 266 664 $687 4,474 1,281 3,193

2019 4$0 $72,625 $456,316 949 78 872 $524 5,424 1,359 4,065

2020 $0 $72,625 $456,316 968 79 889 $513 6,392 1,438 4,954

2021 $0 $72,625 $456,316 988 81 907 $503 7,379 1,519 5,861

2022 $0 $72,625 $456,316 1,007 82 925 $493 8,387 1,601 6,786

2023 $0 $72,625 $456,316 1,027 84 943 $484 9,414 1,685 7,729

2024 $0 $72,625 $456,316 1,048 86 962 $474 10,462 1,771 8,691

2025 $0 $72,625 $456,316 1,069 88 981 $465 11,531 1,859 9,673

2026 $0 $72,625 $456,316 1,090 89 1,001 $456 12,622 1,948 10,674

2027 $0 $72,625 $456,316 1,112 91 1,021 $447 13,734 2,039 11,695

2028 $0 $72,625 $456,316 1,134 93 1,042 $438 14,868 2,132 12,736

2029 $0 $72,625 $456,316 1,157 95 1,062 $430 16,025 2,227 13,799

2030 $0 $72,625 $456,316 1,180 97 1,084 $421 17,206 2,323 14,882

2031 $0 $72,625 $456,316 1,204 99 1,105 $413 18,410 2,422 15,988

2032 $0 $72,625 $456,316 1,228 101 1,127 $405 19,638 2,522 17,115

2033 $0 $72,625 $456,316 1,253 103 1,150 $397 20,890 2,625 18,265

2034 $0 $72,625 $456,316 1,278 105 1,173 $389 21,308 2,483 18,824

2035 $0 $72,625 $456,316 1,303 107 1,196 $381 21,734 2,339 19,395

2036 $0 $72,625 $456,316 1,329 109 1,220 $374 22,169 2,192 19,977

2037 $0 $72,625 $456,316 1,356 111 1,245 $367 22,612 2,042 20,570

2038 $0 $72,625 $456,316 1,383 113 1,270 $359 23,064 1,888 21,176

2039 22,115 1,811 20,304

2040 21,147 1,731 19,415

2041 20,159 1,651 18,509

2042 19,152 1,568 17,584

2043 18,124 1,484 16,640

2044 17,076 1,398 15,678

2045 16,007 1,311 14,697

2046 14,917 1,221 13,696

2047 13,805 1,130 12,674

2048 12,670 1,037 11,633

2049 11,513 943 10,571

2050 10,333 846 9,487

2051 9,129 747 8,382

2052 7,901 647 7,254

2053 6,649 544 6,104

2054 5,371 440 4,931

2055 4,068 333 3,735

2056 2,739 224 2,514

2057 1,383 113 1,270

$11,864,204 236,254 $50

Table 5. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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.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.

Year

Annual 

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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 
10

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$4,829,241 $14,166,171 $3,392,772

2014 4$4,829,241 $14,166,171 $3,392,772 4,038 825 3,213 $1,056 4,038 825 3,213

2015 $3,740,925 $10,973,689 $3,392,772 4,119 842 3,277 $1,035 8,157 1,667 6,490

2016 $3,740,925 $10,973,689 $3,392,772 4,201 858 3,343 $1,015 12,358 2,525 9,833

2017 $3,740,925 $10,973,689 $3,392,772 4,285 876 3,410 $995 16,643 3,401 13,242

2018 $3,740,925 $10,973,689 $3,392,772 4,371 893 3,478 $976 21,014 4,294 16,720

2019 4$0 $799,249 $3,392,772 4,458 89 4,369 $777 25,472 4,383 21,089

2020 $0 $799,249 $3,392,772 4,547 91 4,456 $761 30,019 4,474 25,545

2021 $0 $799,249 $3,392,772 4,638 93 4,546 $746 34,658 4,567 30,091

2022 $0 $799,249 $3,392,772 4,731 95 4,636 $732 39,389 4,661 34,727

2023 $0 $799,249 $3,392,772 4,826 97 4,729 $717 44,214 4,758 39,457

2024 $0 $799,249 $3,392,772 4,922 98 4,824 $703 49,137 4,856 44,280

2025 $0 $799,249 $3,392,772 5,021 100 4,920 $690 54,157 4,957 49,201

2026 $0 $799,249 $3,392,772 5,121 102 5,019 $676 59,278 5,059 54,219

2027 $0 $799,249 $3,392,772 5,224 104 5,119 $663 64,502 5,164 59,338

2028 $0 $799,249 $3,392,772 5,328 107 5,221 $650 69,830 5,270 64,560

2029 $0 $799,249 $3,392,772 5,435 109 5,326 $637 75,264 5,379 69,886

2030 $0 $799,249 $3,392,772 5,543 111 5,432 $625 80,808 5,490 75,318

2031 $0 $799,249 $3,392,772 5,654 113 5,541 $612 86,462 5,603 80,859

2032 $0 $799,249 $3,392,772 5,767 115 5,652 $600 92,229 5,718 86,511

2033 $0 $799,249 $3,392,772 5,883 118 5,765 $589 98,111 5,836 92,276

2034 $0 $799,249 $3,392,772 6,000 120 5,880 $577 100,074 5,131 94,943

2035 $0 $799,249 $3,392,772 6,120 122 5,998 $566 102,075 4,411 97,664

2036 $0 $799,249 $3,392,772 6,243 125 6,118 $555 104,117 3,678 100,439

2037 $0 $799,249 $3,392,772 6,367 127 6,240 $544 106,199 2,930 103,269

2038 $0 $799,249 $3,392,772 6,495 130 6,365 $533 108,323 2,166 106,156

2039 103,865 2,077 101,787

2040 99,317 1,986 97,331

2041 94,679 1,894 92,785

2042 89,948 1,799 88,149

2043 85,122 1,702 83,420

2044 80,200 1,604 78,596

2045 75,179 1,504 73,676

2046 70,058 1,401 68,657

2047 64,835 1,297 63,538

2048 59,507 1,190 58,317

2049 54,072 1,081 52,991

2050 48,529 971 47,558

2051 42,875 857 42,017

2052 37,108 742 36,365

2053 31,225 625 30,601

2054 25,225 504 24,720

2055 19,105 382 18,723

2056 12,862 257 12,605

2057 6,495 130 6,365

$88,212,079 1,184,357 $74

Year

Annual 

Capital 

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission 

Reduction over 20-year stove 

lifespan 

Table 6. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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.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.

CE based on total

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)
11

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,188,588 $6,420,038 $1,171,222

2014 4$2,188,588 $6,420,038 $1,171,222 2,809 702 2,106 $556 2,809 702 2,106

2015 $1,100,272 $3,227,556 $1,171,222 2,865 716 2,149 $545 5,673 1,418 4,255

2016 $1,100,272 $3,227,556 $1,171,222 2,922 731 2,192 $534 8,595 2,149 6,446

2017 $1,100,272 $3,227,556 $1,171,222 2,980 745 2,235 $524 11,576 2,894 8,682

2018 $1,100,272 $3,227,556 $1,171,222 3,040 760 2,280 $514 14,616 3,654 10,962

2019 4$0 $235,073 $1,171,222 3,101 62 3,039 $385 17,717 3,716 14,001

2020 $0 $235,073 $1,171,222 3,163 63 3,100 $378 20,880 3,779 17,100

2021 $0 $235,073 $1,171,222 3,226 65 3,162 $370 24,106 3,844 20,262

2022 $0 $235,073 $1,171,222 3,291 66 3,225 $363 27,396 3,910 23,487

2023 $0 $235,073 $1,171,222 3,356 67 3,289 $356 30,753 3,977 26,776

2024 $0 $235,073 $1,171,222 3,424 68 3,355 $349 34,177 4,045 30,131

2025 $0 $235,073 $1,171,222 3,492 70 3,422 $342 37,669 4,115 33,554

2026 $0 $235,073 $1,171,222 3,562 71 3,491 $336 41,231 4,186 37,044

2027 $0 $235,073 $1,171,222 3,633 73 3,561 $329 44,864 4,259 40,605

2028 $0 $235,073 $1,171,222 3,706 74 3,632 $322 48,570 4,333 44,236

2029 $0 $235,073 $1,171,222 3,780 76 3,704 $316 52,349 4,409 47,941

2030 $0 $235,073 $1,171,222 3,856 77 3,778 $310 56,205 4,486 51,719

2031 $0 $235,073 $1,171,222 3,933 79 3,854 $304 60,138 4,564 55,573

2032 $0 $235,073 $1,171,222 4,011 80 3,931 $298 64,149 4,645 59,504

2033 $0 $235,073 $1,171,222 4,092 82 4,010 $292 68,241 4,726 63,514

2034 $0 $235,073 $1,171,222 4,173 83 4,090 $286 69,605 4,108 65,498

2035 $0 $235,073 $1,171,222 4,257 85 4,172 $281 70,997 3,477 67,521

2036 $0 $235,073 $1,171,222 4,342 87 4,255 $275 72,417 2,833 69,584

2037 $0 $235,073 $1,171,222 4,429 89 4,340 $270 73,866 2,177 71,689

2038 $0 $235,073 $1,171,222 4,517 90 4,427 $265 75,343 1,507 73,836

2039 72,242 1,445 70,797

2040 69,079 1,382 67,698

2041 65,853 1,317 64,536

2042 62,562 1,251 61,311

2043 59,206 1,184 58,022

2044 55,782 1,116 54,667

2045 52,290 1,046 51,244

2046 48,728 975 47,754

2047 45,095 902 44,193

2048 41,389 828 40,562

2049 37,609 752 36,857

2050 33,754 675 33,079

2051 29,821 596 29,225

2052 25,810 516 25,294

2053 21,718 434 21,284

2054 17,545 351 17,194

2055 13,288 266 13,022

2056 8,946 179 8,767

2057 4,517 90 4,427

$30,451,763 823,770 $37

Table 7. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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.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.

Year

Annual

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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 
12

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,640,653 $7,746,133 $2,221,551

2014 4$2,640,653 $7,746,133 $2,221,551 1,229 123 1,106 $2,008 1,229 123 1,106

2015 $2,640,653 $7,746,133 $2,221,551 1,254 125 1,129 $1,968 2,483 248 2,235

2016 $2,640,653 $7,746,133 $2,221,551 1,279 128 1,151 $1,930 3,762 376 3,386

2017 $2,640,653 $7,746,133 $2,221,551 1,305 130 1,174 $1,892 5,067 507 4,560

2018 $2,640,653 $7,746,133 $2,221,551 1,331 133 1,198 $1,855 6,398 640 5,758

2019 4$0 $564,176 $2,221,551 1,357 27 1,330 $1,670 7,755 667 7,088

2020 $0 $564,176 $2,221,551 1,384 28 1,357 $1,637 9,140 695 8,445

2021 $0 $564,176 $2,221,551 1,412 28 1,384 $1,605 10,552 723 9,829

2022 $0 $564,176 $2,221,551 1,440 29 1,412 $1,574 11,992 752 11,241

2023 $0 $564,176 $2,221,551 1,469 29 1,440 $1,543 13,461 781 12,680

2024 $0 $564,176 $2,221,551 1,499 30 1,469 $1,513 14,960 811 14,149

2025 $0 $564,176 $2,221,551 1,529 31 1,498 $1,483 16,489 842 15,647

2026 $0 $564,176 $2,221,551 1,559 31 1,528 $1,454 18,048 873 17,175

2027 $0 $564,176 $2,221,551 1,590 32 1,559 $1,425 19,638 905 18,734

2028 $0 $564,176 $2,221,551 1,622 32 1,590 $1,397 21,260 937 20,323

2029 $0 $564,176 $2,221,551 1,655 33 1,621 $1,370 22,915 970 21,945

2030 $0 $564,176 $2,221,551 1,688 34 1,654 $1,343 24,603 1,004 23,599

2031 $0 $564,176 $2,221,551 1,721 34 1,687 $1,317 26,324 1,038 25,286

2032 $0 $564,176 $2,221,551 1,756 35 1,721 $1,291 28,080 1,073 27,006

2033 $0 $564,176 $2,221,551 1,791 36 1,755 $1,266 29,871 1,109 28,762

2034 $0 $564,176 $2,221,551 1,827 37 1,790 $1,241 30,468 1,023 29,445

2035 $0 $564,176 $2,221,551 1,863 37 1,826 $1,217 31,078 935 30,143

2036 $0 $564,176 $2,221,551 1,901 38 1,863 $1,193 31,699 845 30,854

2037 $0 $564,176 $2,221,551 1,939 39 1,900 $1,169 32,333 753 31,580

2038 $0 $564,176 $2,221,551 1,977 40 1,938 $1,146 32,980 660 32,320

2039 31,622 632 30,990

2040 30,238 605 29,633

2041 28,826 577 28,249

2042 27,385 548 26,838

2043 25,916 518 25,398

2044 24,418 488 23,929

2045 22,889 458 22,431

2046 21,330 427 20,903

2047 19,739 395 19,345

2048 18,117 362 17,755

2049 16,463 329 16,133

2050 14,775 296 14,480

2051 13,054 261 12,793

2052 11,298 226 11,072

2053 9,507 190 9,317

2054 7,680 154 7,526

2055 5,817 116 5,700

2056 3,916 78 3,838

2057 1,977 40 1,938

$57,760,316 360,587 $160

Table 8. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

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 
13

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

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

2014 4$10,295,398 $30,200,681 $7,301,610 5,587 1,760 3,827 $1,908 5,587 1,760 3,827

2015 $8,771,756 $25,731,206 $7,301,610 5,699 1,795 3,903 $1,871 11,285 3,556 7,730

2016 $8,771,756 $25,731,206 $7,301,610 5,812 1,831 3,981 $1,834 17,098 5,387 11,711

2017 $8,771,756 $25,731,206 $7,301,610 5,929 1,868 4,061 $1,798 23,026 7,255 15,771

2018 $8,771,756 $25,731,206 $7,301,610 6,047 1,905 4,142 $1,763 29,074 9,161 19,913

2019 4$0 $1,325,783 $7,301,610 6,168 464 5,705 $1,280 35,242 9,624 25,618

2020 $0 $1,325,783 $7,301,610 6,292 473 5,819 $1,255 41,534 10,097 31,437

2021 $0 $1,325,783 $7,301,610 6,417 482 5,935 $1,230 47,951 10,579 37,372

2022 $0 $1,325,783 $7,301,610 6,546 492 6,054 $1,206 54,497 11,071 43,425

2023 $0 $1,325,783 $7,301,610 6,677 502 6,175 $1,182 61,174 11,573 49,600

2024 $0 $1,325,783 $7,301,610 6,810 512 6,298 $1,159 67,984 12,085 55,899

2025 $0 $1,325,783 $7,301,610 6,946 522 6,424 $1,137 74,930 12,607 62,323

2026 $0 $1,325,783 $7,301,610 7,085 533 6,553 $1,114 82,016 13,140 68,876

2027 $0 $1,325,783 $7,301,610 7,227 543 6,684 $1,092 89,243 13,683 75,560

2028 $0 $1,325,783 $7,301,610 7,372 554 6,818 $1,071 96,614 14,237 82,377

2029 $0 $1,325,783 $7,301,610 7,519 565 6,954 $1,050 104,133 14,802 89,331

2030 $0 $1,325,783 $7,301,610 7,669 576 7,093 $1,029 111,803 15,379 96,424

2031 $0 $1,325,783 $7,301,610 7,823 588 7,235 $1,009 119,626 15,967 103,659

2032 $0 $1,325,783 $7,301,610 7,979 600 7,380 $989 127,605 16,566 111,039

2033 $0 $1,325,783 $7,301,610 8,139 612 7,527 $970 135,744 17,178 118,566

2034 $0 $1,325,783 $7,301,610 8,302 624 7,678 $951 138,459 16,042 122,417

2035 $0 $1,325,783 $7,301,610 8,468 636 7,831 $932 141,228 14,883 126,345

2036 $0 $1,325,783 $7,301,610 8,637 649 7,988 $914 144,052 13,701 130,352

2037 $0 $1,325,783 $7,301,610 8,810 662 8,148 $896 146,933 12,495 134,439

2038 $0 $1,325,783 $7,301,610 8,986 675 8,311 $879 149,872 11,265 138,607

2039 143,704 10,801 132,903

2040 137,412 10,328 127,084

2041 130,995 9,846 121,149

2042 124,449 9,354 115,095

2043 117,772 8,852 108,920

2044 110,962 8,340 102,622

2045 104,016 7,818 96,198

2046 96,930 7,286 89,645

2047 89,703 6,742 82,961

2048 82,332 6,188 76,143

2049 74,812 5,623 69,189

2050 67,143 5,047 62,096

2051 59,320 4,459 54,862

2052 51,341 3,859 47,482

2053 43,202 3,247 39,955

2054 34,900 2,623 32,277

2055 26,433 1,987 24,446

2056 17,796 1,338 16,458

2057 8,986 675 8,311

$189,841,851 1,546,402 $123

Table 9. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters 

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

CE based on total

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 

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 .
14

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$5,466,157 $16,034,510 $5,828,073

2014 4$5,466,157 $16,034,510 $5,828,073 1,549 935 614 $9,498 1,549 935 614

2015 4$5,030,830 $14,757,517 $5,828,073 1,580 954 626 $9,311 3,129 1,889 1,240

2016 4$5,030,830 $14,757,517 $5,828,073 1,611 973 638 $9,129 4,740 2,862 1,878

2017 $8,808,721 $25,839,640 $5,828,073 1,644 692 951 $6,125 6,384 3,554 2,829

2018 $8,808,721 $25,839,640 $5,828,073 1,677 706 971 $6,005 8,060 4,260 3,800

2019 $3,898,751 $11,436,657 $5,828,073 1,710 720 990 $5,887 9,770 4,980 4,790

2020 $3,898,751 $11,436,657 $5,828,073 1,744 735 1,010 $5,772 11,514 5,715 5,800

2021 $3,898,751 $11,436,657 $5,828,073 1,779 749 1,030 $5,659 13,294 6,464 6,830

2022 $3,898,751 $11,436,657 $5,828,073 1,815 397 1,417 $4,112 15,108 6,861 8,247

2023 $0 $526,534 $5,828,073 1,851 405 1,446 $4,031 16,959 7,267 9,692

2024 $0 $526,534 $5,828,073 1,888 413 1,475 $3,952 18,847 7,680 11,167

2025 $0 $526,534 $5,828,073 1,926 422 1,504 $3,875 20,773 8,102 12,671

2026 $0 $526,534 $5,828,073 1,964 430 1,534 $3,799 22,737 8,532 14,205

2027 $0 $526,534 $5,828,073 2,004 439 1,565 $3,724 24,741 8,971 15,770

2028 $0 $526,534 $5,828,073 2,044 448 1,596 $3,651 26,785 9,418 17,366

2029 $0 $526,534 $5,828,073 2,085 456 1,628 $3,580 28,869 9,875 18,994

2030 $0 $526,534 $5,828,073 2,126 466 1,661 $3,510 30,995 10,340 20,655

2031 $0 $526,534 $5,828,073 2,169 475 1,694 $3,441 33,164 10,815 22,349

2032 $0 $526,534 $5,828,073 2,212 484 1,728 $3,373 35,376 11,300 24,076

2033 $0 $526,534 $5,828,073 2,256 494 1,762 $3,307 37,632 11,794 25,839

2034 $0 $526,534 $5,828,073 2,301 504 1,798 $3,242 38,385 11,362 27,023

2035 $0 $526,534 $5,828,073 2,348 514 1,833 $3,179 39,153 10,923 28,230

2036 $0 $526,534 $5,828,073 2,394 524 1,870 $3,116 39,936 10,474 29,462

2037 $0 $526,534 $5,828,073 2,442 535 1,908 $3,055 40,735 10,317 30,418

2038 $0 $526,534 $5,828,073 2,491 546 1,946 $2,995 41,549 10,156 31,393

2039 $0 $526,534 $5,828,073 2,541 556 1,985 $2,937 42,380 9,992 32,388

2040 $0 $526,534 $5,828,073 2,592 568 2,024 $2,879 43,228 9,826 33,402

2041 $0 $526,534 $5,828,073 2,644 579 2,065 $2,823 44,092 9,655 34,437

2042 42,278 9,258 33,020

2043 40,427 8,853 31,574

2044 38,539 8,439 30,100

2045 36,613 8,017 28,596

2046 34,649 7,587 27,061

2047 32,645 7,149 25,497

2048 30,601 6,701 23,900

2049 28,517 6,245 22,272

2050 26,391 5,779 20,612

2051 24,222 5,304 18,918

2052 22,010 4,820 17,190

2053 19,753 4,326 15,428

2054 17,452 3,822 13,630

2055 15,105 3,308 11,797

2056 12,710 2,783 9,927

2057 10,268 2,248 8,019

2058 7,777 1,703 6,074

2059 5,236 1,146 4,089

2060 2,644 579 2,065

$169,014,114 384,206 $440

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

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting 

& recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be

emitting through 2060.

Year

Annual

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 

for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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). 

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves and pellet stoves, estimates 

conservatively assume that most models meet Step 1 and that manufacturers will certify and sell existing models meeting Step 1 from 2014 through 2016. Therefore no emission 

reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2017.

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
15

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,584,750 $7,582,146 $2,772,151

2014 4$2,584,750 $7,582,146 $2,772,151 505 505 0 N/A 505 505 0

2015 4$2,584,750 $7,582,146 $2,772,151 515 515 0 N/A 1,021 1,021 0

2016 4$2,584,750 $7,582,146 $2,772,151 526 526 0 N/A 1,546 1,546 0

2017 $4,567,621 $13,398,730 $2,772,151 536 373 163 $16,982 2,082 1,919 163

2018 $4,567,621 $13,398,730 $2,772,151 547 380 167 $16,649 2,629 2,300 330

2019 $1,982,871 $5,816,584 $2,772,151 558 388 170 $16,323 3,187 2,688 500

2020 $1,982,871 $5,816,584 $2,772,151 569 396 173 $16,003 3,756 3,083 673

2021 $1,982,871 $5,816,584 $2,772,151 580 404 177 $15,689 4,336 3,487 849

2022 $1,982,871 $5,816,584 $2,772,151 592 214 378 $7,336 4,928 3,701 1,227

2023 $0 $0 $2,772,151 604 218 385 $7,193 5,532 3,919 1,613

2024 $0 $0 $2,772,151 616 223 393 $7,051 6,148 4,142 2,006

2025 $0 $0 $2,772,151 628 227 401 $6,913 6,776 4,369 2,407

2026 $0 $0 $2,772,151 641 232 409 $6,778 7,417 4,601 2,816

2027 $0 $0 $2,772,151 654 236 417 $6,645 8,071 4,838 3,233

2028 $0 $0 $2,772,151 667 241 426 $6,514 8,737 5,079 3,659

2029 $0 $0 $2,772,151 680 246 434 $6,387 9,417 5,325 4,093

2030 $0 $0 $2,772,151 694 251 443 $6,262 10,111 5,575 4,535

2031 $0 $0 $2,772,151 707 256 452 $6,139 10,818 5,831 4,987

2032 $0 $0 $2,772,151 722 261 461 $6,018 11,540 6,092 5,448

2033 $0 $0 $2,772,151 736 266 470 $5,900 12,276 6,359 5,917

2034 $0 $0 $2,772,151 751 272 479 $5,785 12,522 6,125 6,397

2035 $0 $0 $2,772,151 766 277 489 $5,671 12,772 5,887 6,885

2036 $0 $0 $2,772,151 781 283 499 $5,560 13,027 5,643 7,384

2037 $0 $0 $2,772,151 797 288 509 $5,451 13,288 5,559 7,729

2038 $0 $0 $2,772,151 813 294 519 $5,344 13,554 5,472 8,082

2039 $0 $0 $2,772,151 829 300 529 $5,239 13,825 5,384 8,441

2040 $0 $0 $2,772,151 845 306 540 $5,137 14,101 5,294 8,807

2041 $0 $0 $2,772,151 862 312 550 $5,036 14,383 5,202 9,181

2042 13,791 4,988 8,803

2043 13,188 4,770 8,418

2044 12,572 4,547 8,025

2045 11,943 4,320 7,624

2046 11,303 4,088 7,215

2047 10,649 3,852 6,797

2048 9,982 3,610 6,372

2049 9,302 3,365 5,938

2050 8,609 3,114 5,495

2051 7,901 2,858 5,044

2052 7,180 2,597 4,583

2053 6,444 2,331 4,113

2054 5,693 2,059 3,634

2055 4,927 1,782 3,145

2056 4,146 1,500 2,647

2057 3,349 1,211 2,138

2058 2,537 918 1,619

2059 1,708 618 1,090

2060 862 312 550

$80,392,378 102,431 $785

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for 

round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves, estimates conservatively assume that 

most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are 

estimated until Step 2 in 2017.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be 

emitting through 2060.

Cumulative Emission 

Reduction over 20-year stove 

Nationwide cumulative cost lifespan 

5 

11. DRAFT Cost Effectiveness (CE) based on annual and cumulative PM2.5 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)
16

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average 

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$1,999,632 $5,865,753 $2,441,029

2014 4$1,999,632 $5,865,753 $2,441,029 184 184 0 N/A 184 184 0

2015 4$1,999,632 $5,865,753 $2,441,029 187 187 0 N/A 371 371 0

2016 4$1,999,632 $5,865,753 $2,441,029 191 191 0 N/A 563 563 0

2017 $3,460,695 $10,151,657 $2,441,029 195 176 20 $125,135 758 738 20

2018 $3,460,695 $10,151,657 $2,441,029 199 179 20 $122,682 957 917 39

2019 $1,568,074 $4,599,813 $2,441,029 203 183 20 $120,276 1,160 1,100 60

2020 $1,568,074 $4,599,813 $2,441,029 207 186 21 $117,918 1,367 1,286 80

2021 $1,568,074 $4,599,813 $2,441,029 211 190 21 $115,606 1,578 1,476 102

2022 $1,568,074 $4,599,813 $2,441,029 215 101 115 $21,304 1,793 1,577 216

2023 $0 $453,909 $2,441,029 220 103 117 $20,887 2,013 1,680 333

2024 $0 $453,909 $2,441,029 224 105 119 $20,477 2,237 1,785 452

2025 $0 $453,909 $2,441,029 229 107 122 $20,076 2,465 1,892 574

2026 $0 $453,909 $2,441,029 233 109 124 $19,682 2,699 2,001 698

2027 $0 $453,909 $2,441,029 238 111 127 $19,296 2,936 2,112 824

2028 $0 $453,909 $2,441,029 243 114 129 $18,918 3,179 2,226 953

2029 $0 $453,909 $2,441,029 247 116 132 $18,547 3,426 2,341 1,085

2030 $0 $453,909 $2,441,029 252 118 134 $18,183 3,679 2,459 1,219

2031 $0 $453,909 $2,441,029 257 120 137 $17,826 3,936 2,580 1,356

2032 $0 $453,909 $2,441,029 263 123 140 $17,477 4,199 2,703 1,496

2033 $0 $453,909 $2,441,029 268 125 142 $17,134 4,466 2,828 1,638

2034 $0 $453,909 $2,441,029 273 128 145 $16,798 4,556 2,772 1,784

2035 $0 $453,909 $2,441,029 279 130 148 $16,469 4,647 2,715 1,932

2036 $0 $453,909 $2,441,029 284 133 151 $16,146 4,740 2,657 2,083

2037 $0 $453,909 $2,441,029 290 136 154 $15,829 4,835 2,617 2,218

2038 $0 $453,909 $2,441,029 296 138 157 $15,519 4,931 2,576 2,355

2039 $0 $453,909 $2,441,029 302 141 160 $15,215 5,030 2,535 2,495

2040 $0 $453,909 $2,441,029 308 144 164 $14,916 5,130 2,492 2,638

2041 $0 $453,909 $2,441,029 314 147 167 $14,624 5,233 2,449 2,784

2042 5,018 2,348 2,669

2043 4,798 2,245 2,553

2044 4,574 2,141 2,433

2045 4,345 2,034 2,312

2046 4,112 1,925 2,188

2047 3,874 1,813 2,061

2048 3,632 1,700 1,932

2049 3,384 1,584 1,801

2050 3,132 1,466 1,666

2051 2,875 1,345 1,529

2052 2,612 1,223 1,390

2053 2,344 1,097 1,247

2054 2,071 969 1,102

2055 1,793 839 954

2056 1,508 706 803

2057 1,219 570 648

2058 923 432 491

2059 621 291 331

2060 314 147 167

$70,789,844 31,060 $2,279

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For pellet stoves, estimates conservatively assume that 

most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated 

until Step 2 in 2017.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be

emitting through 2060.

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 

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

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for 

round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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.

Year

Annual 

Capital 

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
17

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction (tons)

2013 3$881,775 $2,586,611 $614,893

2014 4$881,775 $2,586,611 $614,893 860 246 614 $1,002 860 246 614

2015 $446,448 $1,309,618 $614,893 877 251 626 $982 1,737 497 1,240

2016 $446,448 $1,309,618 $614,893 895 256 638 $963 2,631 753 1,878

2017 4$780,405 $2,289,254 $614,893 912 144 769 $800 3,544 897 2,647

2018 $780,405 $2,289,254 $614,893 931 147 784 $784 4,474 1,043 3,431

2019 $347,806 $1,020,261 $614,893 949 149 800 $769 5,424 1,193 4,231

2020 $347,806 $1,020,261 $614,893 968 152 816 $754 6,392 1,345 5,046

2021 $347,806 $1,020,261 $614,893 988 155 832 $739 7,379 1,501 5,878

2022 4$347,806 $1,020,261 $614,893 1,007 82 925 $665 8,387 1,583 6,803

2023 $0 $72,625 $614,893 1,027 84 943 $652 9,414 1,667 7,747

2024 $0 $72,625 $614,893 1,048 86 962 $639 10,462 1,753 8,709

2025 $0 $72,625 $614,893 1,069 88 981 $626 11,531 1,841 9,690

2026 $0 $72,625 $614,893 1,090 89 1,001 $614 12,622 1,930 10,692

2027 $0 $72,625 $614,893 1,112 91 1,021 $602 13,734 2,021 11,713

2028 $0 $72,625 $614,893 1,134 93 1,042 $590 14,868 2,114 12,754

2029 $0 $72,625 $614,893 1,157 95 1,062 $579 16,025 2,209 13,817

2030 $0 $72,625 $614,893 1,180 97 1,084 $567 17,206 2,305 14,900

2031 $0 $72,625 $614,893 1,204 99 1,105 $556 18,410 2,404 16,006

2032 $0 $72,625 $614,893 1,228 101 1,127 $545 19,638 2,504 17,133

2033 $0 $72,625 $614,893 1,253 103 1,150 $535 20,890 2,607 18,283

2034 $0 $72,625 $614,893 1,278 105 1,173 $524 21,308 2,466 18,842

2035 $0 $72,625 $614,893 1,303 107 1,196 $514 21,734 2,321 19,413

2036 $0 $72,625 $614,893 1,329 109 1,220 $504 22,169 2,174 19,995

2037 $0 $72,625 $614,893 1,356 111 1,245 $494 22,612 2,141 20,471

2038 $0 $72,625 $614,893 1,383 113 1,270 $484 23,064 2,108 20,956

2039 $0 $72,625 $614,893 1,411 115 1,295 $475 23,526 2,074 21,452

2040 $0 $72,625 $614,893 1,439 118 1,321 $465 23,996 2,039 21,957

2041 $0 $72,625 $614,893 1,468 120 1,347 $456 24,476 2,004 22,472

2042 23,469 1,921 21,547

2043 22,441 1,837 20,604

2044 21,393 1,752 19,642

2045 20,324 1,664 18,660

2046 19,234 1,575 17,659

2047 18,122 1,484 16,638

2048 16,987 1,391 15,596

2049 15,830 1,296 14,534

2050 14,650 1,199 13,450

2051 13,446 1,101 12,345

2052 12,218 1,000 11,218

2053 10,965 898 10,068

2054 9,688 793 8,895

2055 8,385 686 7,698

2056 7,055 578 6,478

2057 5,700 467 5,233

2058 4,317 353 3,963

2059 2,906 238 2,668

2060 1,468 120 1,347

$17,831,892 250,714 $71

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting 

through 2060.

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 

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

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for 

round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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.

Year

Annual

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
18

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$4,829,241 $14,166,171 $4,772,249

2014 4$4,829,241 $14,166,171 $4,772,249 4,038 825 3,213 $1,485 4,038 825 3,213

2015 $3,740,925 $10,973,689 $4,772,249 4,119 842 3,277 $1,456 8,157 1,667 6,490

2016 $3,740,925 $10,973,689 $4,772,249 4,201 858 3,343 $1,428 12,358 2,525 9,833

2017 4$6,579,561 $19,300,588 $4,772,249 4,285 214 4,071 $1,172 16,643 2,739 13,903

2018 $6,579,561 $19,300,588 $4,772,249 4,371 219 4,152 $1,149 21,014 2,958 18,056

2019 $2,925,650 $8,582,148 $4,772,249 4,458 223 4,235 $1,127 25,472 3,181 22,291

2020 $2,925,650 $8,582,148 $4,772,249 4,547 227 4,320 $1,105 30,019 3,408 26,611

2021 $2,925,650 $8,582,148 $4,772,249 4,638 232 4,406 $1,083 34,658 3,640 31,017

2022 4$2,925,650 $8,582,148 $4,772,249 4,731 95 4,636 $1,029 39,389 3,735 35,654

2023 $0 $799,249 $4,772,249 4,826 97 4,729 $1,009 44,214 3,831 40,383

2024 $0 $799,249 $4,772,249 4,922 98 4,824 $989 49,137 3,930 45,207

2025 $0 $799,249 $4,772,249 5,021 100 4,920 $970 54,157 4,030 50,127

2026 $0 $799,249 $4,772,249 5,121 102 5,019 $951 59,278 4,132 55,146

2027 $0 $799,249 $4,772,249 5,224 104 5,119 $932 64,502 4,237 60,265

2028 $0 $799,249 $4,772,249 5,328 107 5,221 $914 69,830 4,344 65,486

2029 $0 $799,249 $4,772,249 5,435 109 5,326 $896 75,264 4,452 70,812

2030 $0 $799,249 $4,772,249 5,543 111 5,432 $878 80,808 4,563 76,245

2031 $0 $799,249 $4,772,249 5,654 113 5,541 $861 86,462 4,676 81,786

2032 $0 $799,249 $4,772,249 5,767 115 5,652 $844 92,229 4,791 87,437

2033 $0 $799,249 $4,772,249 5,883 118 5,765 $828 98,111 4,909 93,202

2034 $0 $799,249 $4,772,249 6,000 120 5,880 $812 100,074 4,204 95,870

2035 $0 $799,249 $4,772,249 6,120 122 5,998 $796 102,075 3,485 98,590

2036 $0 $799,249 $4,772,249 6,243 125 6,118 $780 104,117 2,751 101,365

2037 $0 $799,249 $4,772,249 6,367 127 6,240 $765 106,199 2,664 103,534

2038 $0 $799,249 $4,772,249 6,495 130 6,365 $750 108,323 2,576 105,747

2039 $0 $799,249 $4,772,249 6,625 132 6,492 $735 110,489 2,485 108,004

2040 $0 $799,249 $4,772,249 6,757 135 6,622 $721 112,699 2,393 110,306

2041 $0 $799,249 $4,772,249 6,892 138 6,754 $707 114,953 2,299 112,654

2042 110,222 2,204 108,018

2043 105,396 2,108 103,288

2044 100,474 2,009 98,465

2045 95,453 1,909 93,544

2046 90,332 1,807 88,526

2047 85,109 1,702 83,407

2048 79,781 1,596 78,185

2049 74,346 1,487 72,859

2050 68,803 1,376 67,427

2051 63,149 1,263 61,886

2052 57,382 1,148 56,234

2053 51,499 1,030 50,469

2054 45,499 910 44,589

2055 39,379 788 38,591

2056 33,136 663 32,474

2057 26,769 535 26,234

2058 20,274 405 19,869

2059 13,649 273 13,376

2060 6,892 138 6,754

Nationwide cumulative cost $138,395,222 1,256,849 $110 5 

Cumulative Emission 

Reduction over 20-year stove

lifespan 

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be

emitting through 2060.

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 

for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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, Step 2 standard in 2017, and Step 3 standard in 2022.

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
19

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,188,588 $6,420,038 $1,559,018

2014 4$2,188,588 $6,420,038 $1,559,018 2,809 702 2,106 $740 2,809 702 2,106

2015 $1,100,272 $3,227,556 $1,559,018 2,865 716 2,149 $726 5,673 1,418 4,255

2016 $1,100,272 $3,227,556 $1,559,018 2,922 731 2,192 $711 8,595 2,149 6,446

2017 4$1,935,165 $5,676,644 $1,559,018 2,980 149 2,831 $551 11,576 2,298 9,278

2018 $1,935,165 $5,676,644 $1,559,018 3,040 152 2,888 $540 14,616 2,450 12,166

2019 $860,485 $2,524,161 $1,559,018 3,101 155 2,946 $529 17,717 2,605 15,112

2020 $860,485 $2,524,161 $1,559,018 3,163 158 3,005 $519 20,880 2,763 18,117

2021 $860,485 $2,524,161 $1,559,018 3,226 161 3,065 $509 24,106 2,924 21,181

2022 4$860,485 $2,524,161 $1,559,018 3,291 66 3,225 $483 27,396 2,990 24,406

2023 $0 $235,073 $1,559,018 3,356 67 3,289 $474 30,753 3,057 27,696

2024 $0 $235,073 $1,559,018 3,424 68 3,355 $465 34,177 3,126 31,051

2025 $0 $235,073 $1,559,018 3,492 70 3,422 $456 37,669 3,196 34,473

2026 $0 $235,073 $1,559,018 3,562 71 3,491 $447 41,231 3,267 37,964

2027 $0 $235,073 $1,559,018 3,633 73 3,561 $438 44,864 3,340 41,524

2028 $0 $235,073 $1,559,018 3,706 74 3,632 $429 48,570 3,414 45,156

2029 $0 $235,073 $1,559,018 3,780 76 3,704 $421 52,349 3,489 48,860

2030 $0 $235,073 $1,559,018 3,856 77 3,778 $413 56,205 3,566 52,639

2031 $0 $235,073 $1,559,018 3,933 79 3,854 $405 60,138 3,645 56,493

2032 $0 $235,073 $1,559,018 4,011 80 3,931 $397 64,149 3,725 60,424

2033 $0 $235,073 $1,559,018 4,092 82 4,010 $389 68,241 3,807 64,433

2034 $0 $235,073 $1,559,018 4,173 83 4,090 $381 69,605 3,188 66,417

2035 $0 $235,073 $1,559,018 4,257 85 4,172 $374 70,997 2,557 68,440

2036 $0 $235,073 $1,559,018 4,342 87 4,255 $366 72,417 1,914 70,504

2037 $0 $235,073 $1,559,018 4,429 89 4,340 $359 73,866 1,853 72,013

2038 $0 $235,073 $1,559,018 4,517 90 4,427 $352 75,343 1,792 73,551

2039 $0 $235,073 $1,559,018 4,608 92 4,516 $345 76,850 1,729 75,121

2040 $0 $235,073 $1,559,018 4,700 94 4,606 $338 78,387 1,665 76,722

2041 $0 $235,073 $1,559,018 4,794 96 4,698 $332 79,955 1,599 78,356

2042 76,664 1,533 75,131

2043 73,307 1,466 71,841

2044 69,884 1,398 68,486

2045 66,392 1,328 65,064

2046 62,830 1,257 61,573

2047 59,197 1,184 58,013

2048 55,491 1,110 54,381

2049 51,711 1,034 50,677

2050 47,855 957 46,898

2051 43,923 878 43,044

2052 39,911 798 39,113

2053 35,820 716 35,103

2054 31,647 633 31,014

2055 27,390 548 26,842

2056 23,048 461 22,587

2057 18,619 372 18,247

2058 14,102 282 13,819

2059 9,494 190 9,304

2060 4,794 96 4,698

$45,211,511 874,191 $52

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be 

emitting through 2060.

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 

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

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 

for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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.

Year

Annual

Capital

Costs

Nationwide 

Annual Cost1 

Nationwide 

Average

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
20

Baseline PM2.5 

Emissions

2 

(tons)

NSPS PM2.5 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$2,640,653 $7,746,133 $3,213,231

2014 4$2,640,653 $7,746,133 $3,213,231 1,229 123 1,106 $2,904 1,229 123 1,106

2015 $2,640,653 $7,746,133 $3,213,231 1,254 125 1,129 $2,847 2,483 248 2,235

2016 $2,640,653 $7,746,133 $3,213,231 1,279 128 1,151 $2,791 3,762 376 3,386

2017 4$4,644,396 $13,623,945 $3,213,231 1,305 65 1,239 $2,593 5,067 441 4,626

2018 $4,644,396 $13,623,945 $3,213,231 1,331 67 1,264 $2,542 6,398 508 5,890

2019 $2,065,165 $6,057,987 $3,213,231 1,357 68 1,289 $2,492 7,755 576 7,179

2020 $2,065,165 $6,057,987 $3,213,231 1,384 69 1,315 $2,443 9,140 645 8,494

2021 $2,065,165 $6,057,987 $3,213,231 1,412 71 1,342 $2,395 10,552 716 9,836

2022 4 $2,065,165 $6,057,987 $3,213,231 1,440 29 1,412 $2,276 11,992 745 11,248

2023 $0 $564,176 $3,213,231 1,469 29 1,440 $2,232 13,461 774 12,688

2024 $0 $564,176 $3,213,231 1,499 30 1,469 $2,188 14,960 804 14,156

2025 $0 $564,176 $3,213,231 1,529 31 1,498 $2,145 16,489 834 15,654

2026 $0 $564,176 $3,213,231 1,559 31 1,528 $2,103 18,048 866 17,182

2027 $0 $564,176 $3,213,231 1,590 32 1,559 $2,062 19,638 897 18,741

2028 $0 $564,176 $3,213,231 1,622 32 1,590 $2,021 21,260 930 20,330

2029 $0 $564,176 $3,213,231 1,655 33 1,621 $1,982 22,915 963 21,952

2030 $0 $564,176 $3,213,231 1,688 34 1,654 $1,943 24,603 997 23,606

2031 $0 $564,176 $3,213,231 1,721 34 1,687 $1,905 26,324 1,031 25,293

2032 $0 $564,176 $3,213,231 1,756 35 1,721 $1,867 28,080 1,066 27,014

2033 $0 $564,176 $3,213,231 1,791 36 1,755 $1,831 29,871 1,102 28,769

2034 $0 $564,176 $3,213,231 1,827 37 1,790 $1,795 30,468 1,016 29,453

2035 $0 $564,176 $3,213,231 1,863 37 1,826 $1,760 31,078 928 30,150

2036 $0 $564,176 $3,213,231 1,901 38 1,863 $1,725 31,699 838 30,861

2037 $0 $564,176 $3,213,231 1,939 39 1,900 $1,691 32,333 811 31,522

2038 $0 $564,176 $3,213,231 1,977 40 1,938 $1,658 32,980 784 32,196

2039 $0 $564,176 $3,213,231 2,017 40 1,977 $1,626 33,639 757 32,883

2040 $0 $564,176 $3,213,231 2,057 41 2,016 $1,594 34,312 729 33,584

2041 $0 $564,176 $3,213,231 2,098 42 2,056 $1,563 34,998 700 34,298

2042 33,558 671 32,887

2043 32,089 642 31,447

2044 30,590 612 29,978

2045 29,062 581 28,480

2046 27,502 550 26,952

2047 25,912 518 25,394

2048 24,290 486 23,804

2049 22,635 453 22,183

2050 20,948 419 20,529

2051 19,226 385 18,842

2052 17,470 349 17,121

2053 15,679 314 15,366

2054 13,853 277 13,576

2055 11,989 240 11,749

2056 10,089 202 9,887

2057 8,150 163 7,987

2058 6,173 123 6,049

2059 4,156 83 4,073

2060 2,098 42 2,056

$93,183,711 382,658 $244

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 in 2022.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be 

emitting through 2060.

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 

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

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 

for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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
21

Baseline PM2.5 

Emissions2 

(tons)

NSPS PM2.5 

Emissions

2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average

annual cost 

(per ton)

Baseline PM2.5 

Emissions 

(tons)

NSPS PM2.5 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$10,295,398 $30,200,681 $10,600,322

2014 4$10,295,398 $30,200,681 $10,600,322 5,587 1,760 3,827 $2,770 5,587 1,760 3,827

2015 $8,771,756 $25,731,206 $10,600,322 5,699 1,795 3,903 $2,716 11,285 3,556 7,730

2016 $8,771,756 $25,731,206 $10,600,322 5,812 1,831 3,981 $2,663 17,098 5,387 11,711

2017 4$15,388,282 $45,140,228 $10,600,322 5,929 906 5,022 $2,111 23,026 6,294 16,733

2018 $15,388,282 $45,140,228 $10,600,322 6,047 925 5,123 $2,069 29,074 7,218 21,856

2019 $6,824,401 $20,018,806 $10,600,322 6,168 943 5,225 $2,029 35,242 8,161 27,081

2020 $6,824,401 $20,018,806 $10,600,322 6,292 962 5,330 $1,989 41,534 9,123 32,411

2021 $6,824,401 $20,018,806 $10,600,322 6,417 981 5,436 $1,950 47,951 10,104 37,847

2022 4$6,824,401 $20,018,806 $10,600,322 6,546 492 6,054 $1,751 54,497 10,596 43,901

2023 $0 $1,325,783 $10,600,322 6,677 502 6,175 $1,717 61,174 11,098 50,076

2024 $0 $1,325,783 $10,600,322 6,810 512 6,298 $1,683 67,984 11,610 56,374

2025 $0 $1,325,783 $10,600,322 6,946 522 6,424 $1,650 74,930 12,132 62,798

2026 $0 $1,325,783 $10,600,322 7,085 533 6,553 $1,618 82,016 12,664 69,351

2027 $0 $1,325,783 $10,600,322 7,227 543 6,684 $1,586 89,243 13,208 76,035

2028 $0 $1,325,783 $10,600,322 7,372 554 6,818 $1,555 96,614 13,762 82,853

2029 $0 $1,325,783 $10,600,322 7,519 565 6,954 $1,524 104,133 14,327 89,806

2030 $0 $1,325,783 $10,600,322 7,669 576 7,093 $1,494 111,803 14,903 96,899

2031 $0 $1,325,783 $10,600,322 7,823 588 7,235 $1,465 119,626 15,491 104,134

2032 $0 $1,325,783 $10,600,322 7,979 600 7,380 $1,436 127,605 16,091 111,514

2033 $0 $1,325,783 $10,600,322 8,139 612 7,527 $1,408 135,744 16,703 119,041

2034 $0 $1,325,783 $10,600,322 8,302 624 7,678 $1,381 138,459 15,567 122,892

2035 $0 $1,325,783 $10,600,322 8,468 636 7,831 $1,354 141,228 14,408 126,820

2036 $0 $1,325,783 $10,600,322 8,637 649 7,988 $1,327 144,052 13,225 130,827

2037 $0 $1,325,783 $10,600,322 8,810 662 8,148 $1,301 146,933 12,981 133,952

2038 $0 $1,325,783 $10,600,322 8,986 675 8,311 $1,276 149,872 12,732 137,140

2039 $0 $1,325,783 $10,600,322 9,166 689 8,477 $1,251 152,870 12,478 140,392

2040 $0 $1,325,783 $10,600,322 9,349 703 8,646 $1,226 155,927 12,219 143,708

2041 $0 $1,325,783 $10,600,322 9,536 717 8,819 $1,202 159,045 11,954 147,091

2042 152,500 11,462 141,037

2043 145,823 10,960 134,863

2044 139,013 10,449 128,564

2045 132,066 9,926 122,140

2046 124,981 9,394 115,587

2047 117,754 8,851 108,903

2048 110,382 8,297 102,086

2049 102,863 7,731 95,132

2050 95,194 7,155 88,039

2051 87,371 6,567 80,804

2052 79,392 5,967 73,424

2053 71,253 5,356 65,897

2054 62,951 4,732 58,220

2055 54,483 4,095 50,388

2056 45,846 3,446 42,400

2057 37,037 2,784 34,253

2058 28,051 2,108 25,942

2059 18,885 1,419 17,466

2060 9,536 717 8,819

$307,409,335 1,641,055 $187

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be 

emitting through 2060.

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 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 

for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 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 2041, 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, Step 2 standard in 2017, and Step 3 standard in 2022. No emission reductions are estimated for woodstoves 

and pellet stoves until 2017, although emission reductions are estimated for all other devices starting in 2014.

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

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

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission 

Reduction over 20-year stove

lifespan