Notes Notes

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

Capital Costs Capital Costs

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

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 45,500 19,000 32,250

Market research, aesthetic design, initial 

prototype design/construction/testing, 

formulate design changes, modify/test 

prototype 91,000 38,000 64,500

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

construct final prototypes, safety test check. 

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

construct final prototypes, safety test check. 

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

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

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

 Tooling Tooling

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

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

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

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

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

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

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

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

Fixed Costs per model Fixed Costs per model

 Certification Certification

EPA testing, Confirmation safety testing or full 

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

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

EPA testing, Confirmation safety testing or full 

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

HBPA costs for personal at lab 

and travel expenses not 

accepted as independent third 

party testing costs

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

 Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS Roll-out 0 0 0

roll-out considered normal 

business operation and not due 

to NSPS

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

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

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

annualized over 6 years at 3% 

interest (note: NERA annualized 

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

annualized over 6 years at 3% 

interest (note: NERA annualized 

over 10 years)

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

Adjustable Burn Rate Stoves, 

Pellet Stoves & Single Burn Rate 

Stoves

Single Burn Rate Stoves, first 2 

years (doubled R&D / 

Engineering Costs)
Hydronic Heater Uncontrolled to 0.32 High Low median

Capital Costs

 R&D/Engineering costs

Market research, aesthetic design, initial prototype 

design/construction/testing, formulate design changes, 

modify/test prototype 180,000 115,000 147,500

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

Modify prototype 16,000 9,000 12,500

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

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

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

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

 Manuracturing/Manufacturing Engineering

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

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

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

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

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

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

 Other Capital Cost components

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

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

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

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

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

Fixed Costs per model

 Certification

Hydronic Heaters & Forced-Air 

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

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

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

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

 Roll-out 0 0 0

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

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

Annualized capital cost per model 269,143 172,045 220,594

Annual cost for development of 4 models 1,076,573 688,179 882,376
Notes

2013 dollars High

Capital Costs

 R&D/Engineering costs

Market research, aesthetic design, initial prototype 

design/construction/testing, formulate design 

changes, modify/test prototype 360,000

Formulate design changes 9,000

Modify prototype 32,000

Test/Retest 1,230,000

Construct final prototype, confirm testing, safety 

testing 267,000

Document final changes 16,000

App. A (NERA) concludes erroneously 

$887,000 for high cost and $581,000 

for low cost. R&D/Engineering total costs 1,914,000

 Manuracturing/Manufacturing Engineering

Programming and Tooling - Steel parts 22,000

Tooling - Refractory 45,000

Electronic Control System 10,000

Final Production samples/Confirm product. Fitup 25,000

Create QA/QC specs 4,000

 Manuracturing/Manufacturing Engineering total costs106,000

 Other Capital Cost components

Purchased parts sourcing 41,000

Test first production heaters 200,000

HPBA costs for equipment and 

integration not included because these 

are considered duplicative of R&D 

costs, above Equipment and facilities 75,000

 Other Capital Cost components total costs 316,000

Total Capital Cost per model 2,336,000

Fixed Costs per model

 Certification

Forced air furnaces, First 2 ye

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

travel expenses not accepted as 

independent third party testing costs

EPA testing, Confirmation safety testing or full safety 

testing, shipping of prototype 72,500

Owner's manual, labeling 6,500

 Certification Total Costs 79,000

roll-out considered normal business 

operation and not due to NSPS Roll-out 0

Total Fixed Capital Cost per model 79,000

Total Costs per Model 2,415,000

annualized over 6 years at 3% interest 

(note: NERA annualized over 10 years) Annualized capital cost per model 445,803

Annual cost for development of 4 models 1,783,212
Notes

Low median 2013 dollars

230,000 295,000

5,000 7,000

18,000 25,000

820,000 1,025,000

177,000 222,000

12,000 14,000

1,262,000 1,588,000

App. A (NERA) concludes 

erroneously $887,000 for high 

cost and $581,000 for low cost.

13,000 17,500

28,000 36,500

5,000 7,500

15,000 20,000

2,000 3,000

63,000 84,500

23,500 32,250

150,000 175,000

25,000 50,000

HPBA costs for equipment and 

integration not included because 

these are considered duplicative 

of R&D costs, above

198,500 257,250

1,523,500 1,929,750

Forced air furnaces, First 2 years 

(doubled R&D / Engineering 

costs)
36,000 54,250

HBPA costs for personal at lab 

and travel expenses not accepted 

as independent third party 

testing costs

3,500 5,000

39,500 59,250

0 0

roll-out considered normal 

business operation and not due 

to NSPS

39,500 59,250

1,563,000 1,989,000

288,526 367,164

annualized over 6 years at 3% 

interest (note: NERA annualized 

over 10 years)

1,154,104 1,468,658
Table 9. Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2015-2020) and through model lifespan (2020-2029)

(Step 1 

compliance) 

2015 2016 2017 2018 2019

(Step 2 

compliance) 

2020

2021 through 

20292 

(Step 1 

compliance) 

2015 2016 2017 2018 2019

(Step 2 

compliance) 

2020

2021 through 

20292 

Wood Stoves (R&D)334 125 $78,283 $78,283 $78,283 $78,283 $78,283 $78,283 $0 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $2,661,608 $0

Pellet Stoves (R&D, R&R, cert)4,7 29 125 $46,100 $46,100 $46,100 $48,862 $48,862 $48,862 $14,240 $1,336,900 $1,336,900 $1,336,900 $1,416,993 $1,416,993 $1,416,993 $412,963

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 7 3 20 $310,698 $310,698 $310,698 $200,519 $200,519 $200,519 $22,025 $932,093 $932,093 $932,093 $601,557 $601,557 $601,557 $66,074

$4,930,601 $4,930,601 $4,930,601 $4,680,157 $4,680,157 $4,680,157 $479,037

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 7 7 50 $2,628,527 $2,628,527 $1,581,596 $1,583,949 $1,583,949 $1,583,949 $36,849 $18,399,692 $18,399,692 $11,071,171 $11,087,642 $11,087,642 $11,087,642 $257,941

Hydronic Heaters (R&D, R&R, cert.)7,830 120 $729,746 $729,746 $729,746 $731,064 $731,064 $731,064 $20,635 $21,892,380 $21,892,380 $21,892,380 $21,931,910 $21,931,910 $21,931,910 $619,059

$40,292,072 $40,292,072 $32,963,552 $33,019,552 $33,019,552 $33,019,552 $877,000

Period

Nationwide Cost of 

the Rule

$45,222,674 $45,222,674 $37,894,153 $37,699,709 $37,699,709 $37,699,709 $1,356,037

R&D year average (2015-

2020) $40,239,771

Post R&D year average 

(2021-2029) $1,356,037

Subpart: Years Annual $

AAA: 2015-2017 Laboratories $55,000

Third-Party Certifiers $16,000

AAA: 2018-2020 Laboratories $73,000

Third-Party Certifiers $9,000

QQQQ: 2015-2017 Laboratories $36,000

Third-Party Certifiers $15,000

QQQQ: 2018-2020 Laboratories $49,000

Third-Party Certifiers $5,000

* Reporting and Recordkeeping (R&R) costs for laboratories and certifying entities are not included in this cost analysis but are estimated as follows: 

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

Annual Cost of the Rule

6

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

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

5

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

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

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

4

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

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

3

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

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

2

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

7

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

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

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

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

are estimated beginning in 2015.

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 1,303,142 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12

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

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

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

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

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

2104008610 364,560 3,654,153 Hydronic heater: outdoor Volatile Organic Compounds 67.4 123,145 0.3378 6.74

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Volatile Organic Compounds 67.4 88,433 0.2519 16.85

0.0086 Baseline woodstove weighted average (Tons/appl)
2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 126,527 80,851 77,617 79,169 80,752 82,367 84,015 85,695 87,409

Single Burn Rate 

Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,091 27,633

Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,305 90,072

Furnace: indoor, 

cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,769 28,324

Hydronic Heating 

Systems 13,385 8,553 8,211 8,375 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

2015 4$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

2020 4$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

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

CE based on total 

cost & cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020 ). Years 2030 through 2048 are past 

the 10-year model design lifespan used in this analysis.

2

 Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) 

of 2.0% from 2015 through 2029, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; 

see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For woodstoves, estimates assume that most models already meet the Step 1 limit 

and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS assuming a 10-year model life. 

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year emitting lifespan 5 
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

2015 4$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

2020 4$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

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount pellet stoves already meeting the Step 2 limit (i.e., 70% of pellet stoves already meet the 

Step 2 limit).

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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real 

GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For pellet stoves, estimates assume that most models already meet the Step 1 limit and 

that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2015 through 2029. 

CE based on total 

cost & cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
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)

2015 4$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

2020 4$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

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting & 

recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real 

GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2015 through 2029. 

CE based on total cost 

& cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 
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

2015 4$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

2020 4$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

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters already meeting the Step 2 limit (i.e., 26% of wood stoves and 70% of 

pellet stoves are estimated to already meet the Step 2 limit).

CE based on total 

cost & cumulative 

emission reduction 

over 20-year 

emitting lifespan 

(per ton)

3

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

Cumulative Emission Reduction 

over 20-year emitting lifespan 

Annual Snapshots Emission Reduction, cumulative per year

Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these stoves to market from 2015 through 2029. 

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and 

reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth 

in real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. In order to not overestimate emission reductions resulting from the rule, for 

woodstoves and pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard 

from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2020. 
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)

2015 4$18,399,692 $5,563,663 6,996 6,996 0 N/A 6,996 6,996 0

2016 4$18,399,692 $5,563,663 7,136 5,798 1,338 $4,158 14,131 12,793 1,338

2017 4$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

2020 4$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). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in 

real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

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

2015 4$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

2020 4$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

2047 3

10,062 314 9,748

2048 3

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). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in real 

GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

Year

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these heaters to market from 2014 through 2029. 

CE based on total cost 

& cumulative 

emission reduction 

over 20-year emitting 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 
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

2015 4$40,292,072 $14,699,957 10,846 7,381 3,466 $4,242 10,846 7,381 3,466

2016 4$40,292,072 $14,699,957 11,063 6,190 4,873 $3,017 21,910 13,571 8,338

2017 4$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

2020 4$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

2047 3

28,343 886 27,457

2048 3

14,312 447 13,864

$220,499,351 2,294,614 $96

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount central heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are 

estimated to already meet the Step 2 limit).

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year emitting lifespan 

Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these heaters to market from 2014 through 2029. 

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and reporting 

& recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in 

real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards 

in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020. 

CE based on total 

cost & cumulative 

emission reduction 

over 20-year emitting 

Year lifespan (per ton) 3

Nationwide 

Annual Cost1 
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

2015 4$45,222,674 $16,909,531 12,910 8,269 4,641 $3,644 12,910 8,269 4,641

2016 4$45,222,674 $16,909,531 13,168 7,097 6,071 $2,785 26,078 15,366 10,712

2017 4$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

2020 4$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

2047 3 33,876 2,175 31,701

2048 317,106 1,098 16,008

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

6 In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit (i.e., 26% of wood 

stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit).

Cost Effectiveness (CE) based on annual and cumulative 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 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & 

recordkeeping costs to bring these heaters to market from 2014 through 2029. 

Year 3

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots

1

 Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 3% interest rate (during 2015-2020), plus annual certification and 

reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years 2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0% from 2015 through 2029, in keeping with the average annual growth in 

real GDP predicted by the US Bureau of Economic Analysis (May 2014 Update of Global Outlook projections; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

4

 Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational 

standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.