Notes Notes



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

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

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

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

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

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

# Hydronic Heater Uncontrolled to 0.32 High Low median

**Capital Costs R&D/Engineering costs** 

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

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

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

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

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

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

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

# Notes

2013 dollars High **Capital Costs R&D/Engineering costs** 

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

# HBPA costs for personal at lab and

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

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

# Notes

Low median 2013 dollars

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

177,000222,000 12,000 14,000

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

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

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

23,500 32,250 150,000175,000

25,000 50,000HPBA costs for equipment and

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

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

**costs)**

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

**0 0** roll-out considered normal

business operation and not due to NSPS

**39,500 59,250** 

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

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

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

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

20292 (Step 1

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

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

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

(2021-2029) $1,356,037

Subpart: Years Annual $

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

AAA: 2018-2020 Laboratories $73,000 Third-Party Certifiers $9,000
QQQQ: 2015-2017 Laboratories $36,000 Third-Party Certifiers $15,000
QQQQ: 2018-2020 Laboratories $49,000 Third-Party Certifiers $5,000 * Reporting and Recordkeeping (R&R) costs for laboratories and certifying entities are not included in this cost analysis but are estimated as follows: 1Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2015 through 2020). Ongoing certification and reporting & recordkeeping costs are incurred through 2029 (based on a model brought to market in 2020 with a lifespan of 10 years). Annual Cost of the Rule

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

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

8For hydronic heaters, the analysis assumes that 18% of models meet Step 2 already so that 82% must undergo R&D to meet Step 2 in 2020. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. Average Annual Cost per Manufacturer based on 6-year R&D round (2015-2020) to meet Step 1 and Step 2 limits with ongoing certification costs (through 2029)

# Manufacturers # Models Nationwide Annual Costs1

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

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

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

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

**Tons/appl 2015 Step** 

**1 Emission**  **Factor** 2104008220 1,303,1421,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Volatile Organic Compounds 15 3,121 0.0073 15 2104008320 873,3571,540,026Woodstove: freestanding, EPA certified, non-catalytic Volatile Organic Compounds 12 9,240 0.0106 12 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Volatile Organic Compounds 15 5,817 0.0155 15 2104008400 846,9311,175,337Woodstove: pellet-fired, general Volatile Organic Compounds 0.041 24 0.0000 0.041

2,206,4704,668,250Single Burn Rate Stoves Volatile Organic Compounds 53 123,709 0.0561 12 2104008610 364,5603,654,153Hydronic heater: outdoor Volatile Organic Compounds 67.4 123,145 0.3378 6.74 2104008510 351,0232,624,115Furnace: indoor, cordwood Volatile Organic Compounds 67.4 88,433 0.2519 16.85 0.0086Baseline woodstove weighted average (Tons/appl)

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

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

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 803 513 493 502 512 523 533 544 555 Single Burn Rate Stoves 2,243 1,433 1,376 1,403 1,431 1,460 1,489 1,519 1,549 Pellet Stoves 1 1 1 1 1 1 1 1 1 Furnace: indoor, cordwood 10,329 6,600 6,336 6,463 6,592 6,724 6,859 6,996 7,136 Hydronic Heating Systems 3,707 2,369 2,274 2,320 3,629 3,701 3,775 3,851 3,928 Total **17,083 10,916**  **10,480 10,689**  **12,165 12,409**  **12,657 12,910**  **13,168 Table 4. Estimated Annual Shipped Units** 

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

### Baseline VOC Emissions2 

### (tons) NSPS VOC

Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $2,661,608 $1,064,643 544 544 0 N/A 544 544 0 2016 $2,661,608 $1,064,643 555 555 0 N/A 1,098 1,098 0 2017 $2,661,608 $1,064,643 566 566 0 N/A 1,664 1,664 0 2018 $2,661,608 $1,064,643 635 635 0 N/A 2,299 2,299 0 2019 $2,661,608 $1,064,643 647 647 0 N/A 2,946 2,946 0 20204 

### $2,661,608 $1,064,643 660 376 285 $3,741 3,606 3,322 285 2021 $0 $1,064,643 673 383 290 $3,667 4,280 3,705 575 2022 $0 $1,064,643 687 391 296 $3,595 4,966 4,095 871 2023 $0 $1,064,643 701 399 302 $3,525 5,667 4,494 1,173 2024 $0 $1,064,643 715 407 308 $3,456 6,382 4,901 1,481 2025 $0 $1,064,643 729 415 314 $3,388 7,111 5,315 1,795 2026 $0 $1,064,643 743 423 321 $3,322 7,854 5,738 2,116 2027 $0 $1,064,643 758 431 327 $3,257 8,612 6,170 2,443 2028 $0 $1,064,643 774 440 333 $3,193 9,386 6,610 2,776 2029 $0 $1,064,643 789 449 340 $3,130 10,175 7,059 3,116 2030 10,175 7,059 3,116 2031 10,175 7,059 3,116 2032 10,175 7,059 3,116 2033 10,175 7,059 3,116 2034 10,175 7,059 3,116 2035 9,631 6,515 3,116 2036 9,077 5,960 3,116 2037 8,511 5,394 3,116 2038 7,876 4,760 3,116 2039 7,229 4,113 3,116 2040 6,569 3,737 2,832 2041 5,895 3,354 2,541 2042 5,208 2,963 2,245 2043 4,508 2,565 1,943 2044 3,793 2,158 1,635 2045 3,064 1,743 1,321 2046 2,321 1,320 1,001 2047 1,563 889 674 2048 789 449 340

$15,969,645 48,813 $327

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

Year3 

### Nationwide

Annual Cost1 

### Nationwide

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

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020 ). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

3

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

4

### Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For woodstoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS assuming a 10-year model life. Cumulative Emission Reduction over 20-year emitting lifespan Nationwide cumulative cost5Baseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6
20154 $1,336,900 $798,556 1 1 0 N/A 1 1 0 2016 $1,336,900 $798,556 1 1 0 N/A 2 2 0 2017 $1,336,900 $798,556 1 1 0 N/A 2 2 0 2018 $1,416,993 $798,556 1 1 0 N/A 3 3 0 2019 $1,416,993 $798,556 1 1 0 N/A 4 4 0 20204 $1,416,993 $798,556 1 0 0 $1,727,431 5 4 0 2021 $412,963 $798,556 1 0 0 $1,693,560 6 5 1 2022 $412,963 $798,556 1 0 0 $1,660,353 6 5 1 2023 $412,963 $798,556 1 0 0 $1,627,797 7 5 2 2024 $412,963 $798,556 1 0 1 $1,595,879 8 6 2 2025 $412,963 $798,556 1 0 1 $1,564,587 9 6 3 2026 $412,963 $798,556 1 0 1 $1,533,909 10 7 3 2027 $412,963 $798,556 1 0 1 $1,503,833 11 7 4 2028 $412,963 $798,556 1 0 1 $1,474,346 12 8 5 2029 $412,963 $798,556 1 0 1 $1,445,437 13 8 5 2030 13 8 5 2031 13 8 5 2032 13 8 5 2033 13 8 5 2034 13 8 5 2035 12 7 5 2036 12 6 5 2037 11 6 5 2038 10 5 5 2039 9 4 5 2040 8 4 5 2041 7 3 4 2042 7 3 4 2043 6 3 3 2044 5 2 3 2045 4 2 2 2046 3 1 2 2047 2 1 1 2048 1 0 1

$11,978,347 79 $151,080

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

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

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

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespanBaseline 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) 20154 $932,093 $346,374 1,519 344 1,175 $295 1,519 344 1,175 2016 $932,093 $346,374 1,549 351 1,199 $289 3,068 695 2,374 2017 $932,093 $346,374 1,580 358 1,222 $283 4,649 1,052 3,596 2018 $601,557 $346,374 1,612 365 1,247 $278 6,260 1,417 4,843 2019 $601,557 $346,374 1,644 372 1,272 $272 7,905 1,790 6,115 20204 $601,557 $346,374 1,677 169 1,508 $230 9,582 1,958 7,623 2021 $66,074 $346,374 1,711 172 1,538 $225 11,292 2,131 9,161 2022 $66,074 $346,374 1,745 176 1,569 $221 13,037 2,306 10,731 2023 $66,074 $346,374 1,780 179 1,601 $216 14,816 2,485 12,331 2024 $66,074 $346,374 1,815 183 1,633 $212 16,632 2,668 13,964 2025 $66,074 $346,374 1,852 186 1,665 $208 18,483 2,854 15,629 2026 $66,074 $346,374 1,889 190 1,699 $204 20,372 3,044 17,328 2027 $66,074 $346,374 1,926 194 1,733 $200 22,298 3,238 19,060 2028 $66,074 $346,374 1,965 198 1,767 $196 24,263 3,436 20,827 2029 $66,074 $346,374 2,004 202 1,803 $192 26,267 3,638 22,630 2030 26,267 3,638 22,630 2031 26,267 3,638 22,630 2032 26,267 3,638 22,630 2033 26,267 3,638 22,630 2034 26,267 3,638 22,630 2035 24,748 3,294 21,455 2036 23,199 2,943 20,256 2037 21,619 2,585 19,034 2038 20,007 2,220 17,787 2039 18,363 1,848 16,515 2040 16,686 1,679 15,007 2041 14,975 1,507 13,468 2042 13,230 1,331 11,899 2043 11,451 1,152 10,299 2044 9,636 970 8,666 2045 7,784 783 7,001 2046 5,895 593 5,302 2047 3,969 399 3,570 2048 2,004 202 1,803

$5,195,617 307,839 $17

**Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Single Burn Rate Stoves** 

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

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

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

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespanBaseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6
20154 $4,930,601 $2,209,574 2,063 888 1,175 $1,880 2,063 888 1,175 2016 $4,930,601 $2,209,574 2,105 906 1,199 $1,844 4,168 1,795 2,374 2017 $4,930,601 $2,209,574 2,147 924 1,222 $1,807 6,315 2,719 3,596 2018 $4,680,157 $2,209,574 2,247 1,000 1,247 $1,772 8,562 3,719 4,843 2019 $4,680,157 $2,209,574 2,292 1,020 1,272 $1,737 10,854 4,740 6,115 20204 $4,680,157 $2,209,574 2,338 545 1,793 $1,232 13,192 5,284 7,908 2021 $479,037 $2,209,574 2,385 556 1,829 $1,208 15,577 5,840 9,737 2022 $479,037 $2,209,574 2,432 567 1,866 $1,184 18,010 6,407 11,603 2023 $479,037 $2,209,574 2,481 578 1,903 $1,161 20,491 6,985 13,506 2024 $479,037 $2,209,574 2,531 590 1,941 $1,138 23,022 7,574 15,447 2025 $479,037 $2,209,574 2,581 601 1,980 $1,116 25,603 8,176 17,427 2026 $479,037 $2,209,574 2,633 613 2,020 $1,094 28,236 8,789 19,447 2027 $479,037 $2,209,574 2,686 626 2,060 $1,073 30,922 9,415 21,507 2028 $479,037 $2,209,574 2,739 638 2,101 $1,052 33,661 10,053 23,608 2029 $479,037 $2,209,574 2,794 651 2,143 $1,031 36,455 10,704 25,751 2030 36,455 10,704 25,751 2031 36,455 10,704 25,751 2032 36,455 10,704 25,751 2033 36,455 10,704 25,751 2034 36,455 10,704 25,751 2035 34,392 9,816 24,576 2036 32,287 8,909 23,378 2037 30,140 7,985 22,155 2038 27,893 6,985 20,908 2039 25,601 5,964 19,636 2040 23,263 5,420 17,843 2041 20,878 4,864 16,014 2042 18,446 4,297 14,148 2043 15,964 3,719 12,245 2044 13,434 3,130 10,304 2045 10,852 2,528 8,324 2046 8,219 1,915 6,304 2047 5,534 1,289 4,244 2048 2,794 651 2,143

$33,143,609 356,731 $93

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

3These heaters have in-home emitting lifespans of at least 20 years; thus room heaters shipped in 2029 will be emitting through 2048. Cumulative Emission Reduction over 20-year emitting lifespan Emission Reduction, cumulative per year Annual Snapshots **Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)** 

Nationwide cumulative cost5

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

Annual Cost1 Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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

### 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) 20154 

### $18,399,692 $5,563,663 6,996 6,996 0 N/A 6,996 6,996 0 20164 

### $18,399,692 $5,563,663 7,136 5,798 1,338 $4,158 14,131 12,793 1,338 20174 

### $11,071,171 $5,563,663 7,278 1,820 5,459 $1,019 21,410 14,613 6,797 2018 $11,087,642 $5,563,663 7,424 1,856 5,568 $999 28,834 16,469 12,365 2019 $11,087,642 $5,563,663 7,572 1,893 5,679 $980 36,406 18,362 18,044 20204 

### $11,087,642 $5,563,663 7,724 241 7,482 $744 44,130 18,604 25,526 2021 $257,941 $5,563,663 7,878 246 7,632 $729 52,008 18,850 33,159 2022 $257,941 $5,563,663 8,036 251 7,785 $715 60,044 19,101 40,943 2023 $257,941 $5,563,663 8,197 256 7,940 $701 68,241 19,357 48,884 2024 $257,941 $5,563,663 8,361 261 8,099 $687 76,601 19,618 56,983 2025 $257,941 $5,563,663 8,528 266 8,261 $673 85,129 19,885 65,244 2026 $257,941 $5,563,663 8,698 272 8,427 $660 93,828 20,157 73,671 2027 $257,941 $5,563,663 8,872 277 8,595 $647 102,700 20,434 82,266 2028 $257,941 $5,563,663 9,050 283 8,767 $635 111,750 20,717 91,033 2029 $257,941 $5,563,663 9,231 288 8,942 $622 120,980 21,005 99,975 2030 120,980 21,005 99,975 2031 120,980 21,005 99,975 2032 120,980 21,005 99,975 2033 120,980 21,005 99,975 2034 120,980 21,005 99,975 2035 113,985 14,009 99,975 2036 106,849 8,212 98,637 2037 99,571 6,392 93,179 2038 92,147 4,536 87,611 2039 84,574 2,643 81,931 2040 76,850 2,402 74,449 2041 68,972 2,155 66,817 2042 60,936 1,904 59,032 2043 52,739 1,648 51,091 2044 44,379 1,387 42,992 2045 35,851 1,120 34,731 2046 27,153 849 26,304 2047 18,280 571 17,709 2048 9,231 288 8,942

$83,454,951 1,443,252 $58

**Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Forced Air Furnaces** 

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### These heaters have in-home emitting lifespans of at least 20 years; thus forced-air furnaces shipped in 2029 will be emitting through 2048. Year3 

### Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4

### Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.
5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year emitting lifespan

### Baseline VOC Emissions2

### (tons) NSPS VOC

Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $21,892,380 $9,136,293.29 3,851 385 3,466 $2,636 3,851 385 3,466 2016 $21,892,380 $9,136,293.29 3,928 393 3,535 $2,585 7,778 778 7,000 2017 $21,892,380 $9,136,293.29 4,006 401 3,606 $2,534 11,785 1,178 10,606 2018 $21,931,910 $9,136,293.29 4,086 409 3,678 $2,484 15,871 1,587 14,284 2019 $21,931,910 $9,136,293.29 4,168 417 3,751 $2,436 20,039 2,004 18,035 20204 

### $21,931,910 $9,136,293.29 4,251 133 4,119 $2,218 24,290 2,137 22,154 2021 $619,059 $9,136,293.29 4,336 136 4,201 $2,175 28,627 2,272 26,355 2022 $619,059 $9,136,293.29 4,423 138 4,285 $2,132 33,050 2,410 30,639 2023 $619,059 $9,136,293.29 4,512 141 4,371 $2,090 37,562 2,551 35,010 2024 $619,059 $9,136,293.29 4,602 144 4,458 $2,049 42,163 2,695 39,468 2025 $619,059 $9,136,293.29 4,694 147 4,547 $2,009 46,857 2,842 44,015 2026 $619,059 $9,136,293.29 4,788 150 4,638 $1,970 51,645 2,992 48,654 2027 $619,059 $9,136,293.29 4,884 153 4,731 $1,931 56,529 3,144 53,385 2028 $619,059 $9,136,293.29 4,981 156 4,826 $1,893 61,510 3,300 58,210 2029 $619,059 $9,136,293.29 5,081 159 4,922 $1,856 66,591 3,459 63,132 2030 66,591 3,459 63,132 2031 66,591 3,459 63,132 2032 66,591 3,459 63,132 2033 66,591 3,459 63,132 2034 66,591 3,459 63,132 2035 62,740 3,074 59,667 2036 58,812 2,681 56,132 2037 54,806 2,280 52,526 2038 50,720 1,872 48,848 2039 46,552 1,455 45,097 2040 42,300 1,322 40,979 2041 37,964 1,186 36,778 2042 33,541 1,048 32,493 2043 29,029 907 28,122 2044 24,427 763 23,664 2045 19,733 617 19,117 2046 14,946 467 14,479 20473 

### 10,062 314 9,748 20483 

### 5,081 159 4,922

$137,044,399 851,363 $161

6

### In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount hydronic heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are estimated to already meet the Step 2 limit). **Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Hydronic Heating Systems** 

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### These heaters have in-home emitting lifespans of at least 20 years; thus hydronic heaters shipped in 2029 will be emitting through 2048. Year Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year emitting lifespanBaseline VOC Emissions2(tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6
20154 $40,292,072 $14,699,957 10,846 7,381 3,466 $4,242 10,846 7,381 3,466 20164 $40,292,072 $14,699,957 11,063 6,190 4,873 $3,017 21,910 13,571 8,338 20174 $32,963,552 $14,699,957 11,285 2,220 9,064 $1,622 33,194 15,792 17,403 2018 $33,019,552 $14,699,957 11,510 2,265 9,246 $1,590 44,705 18,056 26,648 2019 $33,019,552 $14,699,957 11,740 2,310 9,431 $1,559 56,445 20,366 36,079 20204 $33,019,552 $14,699,957 11,975 374 11,601 $1,267 68,420 20,740 47,680 2021 $877,000 $14,699,957 12,215 382 11,833 $1,242 80,635 21,122 59,513 2022 $877,000 $14,699,957 12,459 389 12,070 $1,218 93,094 21,511 71,583 2023 $877,000 $14,699,957 12,708 397 12,311 $1,194 105,803 21,908 83,894 2024 $877,000 $14,699,957 12,962 405 12,557 $1,171 118,765 22,314 96,451 2025 $877,000 $14,699,957 13,222 413 12,809 $1,148 131,987 22,727 109,260 2026 $877,000 $14,699,957 13,486 421 13,065 $1,125 145,473 23,148 122,325 2027 $877,000 $14,699,957 13,756 430 13,326 $1,103 159,229 23,578 135,651 2028 $877,000 $14,699,957 14,031 438 13,592 $1,081 173,260 24,016 149,243 2029 $877,000 $14,699,957 14,312 447 13,864 $1,060 187,571 24,464 163,107 2030 187,571 24,464 163,107 2031 187,571 24,464 163,107 2032 187,571 24,464 163,107 2033 187,571 24,464 163,107 2034 187,571 24,464 163,107 2035 176,725 17,083 159,642 2036 165,661 10,892 154,769 2037 154,377 8,672 145,705 2038 142,867 6,408 136,459 2039 131,126 4,098 127,028 2040 119,151 3,723 115,427 2041 106,936 3,342 103,594 2042 94,477 2,952 91,525 2043 81,769 2,555 79,213 2044 68,806 2,150 66,656 2045 55,585 1,737 53,847 2046 42,098 1,316 40,783 20473 28,343 886 27,457 20483 14,312 447 13,864

$220,499,351 2,294,614 $96 Nationwide Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount central heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are estimated to already meet the Step 2 limit). Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespan **Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)** 

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. 1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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

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

Annual Cost1Baseline VOC Emissions2 (tons) NSPS VOC

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton)Baseline VOC

Emissions (tons) NSPS VOC

Emissions (tons) Emission

Reduction (tons)6
20154 $45,222,674 $16,909,531 12,910 8,269 4,641 $3,644 12,910 8,269 4,641 20164 $45,222,674 $16,909,531 13,168 7,097 6,071 $2,785 26,078 15,366 10,712 20174 $37,894,153 $16,909,531 13,431 3,145 10,287 $1,644 39,509 18,511 20,999 2018 $37,699,709 $16,909,531 13,758 3,265 10,493 $1,612 53,267 21,775 31,491 2019 $37,699,709 $16,909,531 14,033 3,330 10,702 $1,580 67,300 25,106 42,194 20204 $37,699,709 $16,909,531 14,313 919 13,394 $1,262 81,613 26,025 55,588 2021 $1,356,037 $16,909,531 14,600 937 13,662 $1,238 96,212 26,962 69,250 2022 $1,356,037 $16,909,531 14,892 956 13,936 $1,213 111,104 27,918 83,186 2023 $1,356,037 $16,909,531 15,189 975 14,214 $1,190 126,293 28,893 97,400 2024 $1,356,037 $16,909,531 15,493 995 14,499 $1,166 141,787 29,888 111,899 2025 $1,356,037 $16,909,531 15,803 1,015 14,788 $1,143 157,590 30,902 126,687 2026 $1,356,037 $16,909,531 16,119 1,035 15,084 $1,121 173,709 31,937 141,772 2027 $1,356,037 $16,909,531 16,442 1,056 15,386 $1,099 190,150 32,993 157,157 2028 $1,356,037 $16,909,531 16,770 1,077 15,694 $1,077 206,921 34,070 172,851 2029 $1,356,037 $16,909,531 17,106 1,098 16,008 $1,056 224,026 35,168 188,859 2030 224,026 35,168 188,859 2031 224,026 35,168 188,859 2032 224,026 35,168 188,859 2033 224,026 35,168 188,859 2034 224,026 35,168 188,859 2035 211,117 26,899 184,218 2036 197,949 19,802 178,147 2037 184,517 16,657 167,860 2038 170,760 13,392 157,367 2039 156,727 10,062 146,665 2040 142,414 9,143 133,270 2041 127,814 8,206 119,608 2042 112,922 7,250 105,673 2043 97,733 6,275 91,458 2044 82,240 5,280 76,960 2045 66,437 4,265 62,171 2046 50,318 3,230 47,087 20473 33,876 2,175 31,701 20483 17,106 1,098 16,008

$253,642,960 2,651,345 $96

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit (i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit). **Cost Effectiveness (CE) based on annual and cumulative 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 emitting lifespan (per ton) Emission Reduction, cumulative per year

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

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

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm).

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

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