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** 42,610 22,794 32,702annualized over 6 years at 7% interest (note: NERA annualized over 10 years) **Annualized capital cost per model** 67,785 36,641 52,213annualized over 6 years at 7% interest (note: NERA annualized over 10 years) **Annual cost for development of 4 models** 170,438 91,177 130,808 **Annual cost for development of 4 models** 271,140 146,563 208,852 **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 305,882**  **195,530 250,706**  **Annual cost for development of 4 models 1,223,529**  **782,119 1,002,824** 

# 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 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 7% interest (note: NERA annualized over 10 years)**Annualized capital cost per model 506,657**  **Annual cost for development of 4 models 2,026,627** 

# Notes

Low median 2013 dollars

230,000 295,000 5,000 7,000 18,000 25,000 820,0001,025,000

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 50,000HPBA 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** 

**327,911 417,284** annualized over 6 years at 7%

interest (note: NERA annualized over 10 years) **1,311,643 1,669,135** **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 $88,968 $88,968 $88,968 $88,968 $88,968 $88,968 $0 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $0 Pellet Stoves (R&D, R&R, cert)4,7 29 125 $51,179 $51,179 $51,179 $53,941 $53,941 $53,941 $14,240 $1,484,192 $1,484,192 $1,484,192 $1,564,285 $1,564,285 $1,564,285 $412,963 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 7 3 20 $352,506 $352,506 $352,506 $226,704 $226,704 $226,704 $22,025 $1,057,518 $1,057,518 $1,057,518 $680,112 $680,112 $680,112 $66,074 $5,566,638 $5,566,638 $5,566,638 $5,269,325 $5,269,325 $5,269,325 $479,037 Forced Air Furnaces (R&D, R&R, cert.)5, 6, 7 7 50 $2,986,523 $2,986,523 $1,796,681 $1,799,034 $1,799,034 $1,799,034 $36,849 $20,905,663 $20,905,663 $12,576,770 $12,593,240 $12,593,240 $12,593,240 $257,941 Hydronic Heaters (R&D, R&R, cert.)7,8 30 120 $828,513 $828,513 $828,513 $829,831 $829,831 $829,831 $20,635 $24,855,398 $24,855,398 $24,855,398 $24,894,927 $24,894,927 $24,894,927 $619,059 $45,761,061 $45,761,061 $37,432,168 $37,488,168 $37,488,168 $37,488,168 $877,000

Period Nationwide Cost of the Rule
$51,327,699 $51,327,699 $42,998,805 $42,757,493 $42,757,493 $42,757,493 $1,356,037 R&D year average (2015- 2020) $45,654,447 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 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Primary PM2.5 8.76 5,371 0.0041 8.76

2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Primary PM2.5 9.72 2,023 0.0047 9.72

2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Primary PM2.5 8.76 6,745 0.0077 8.76

2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Primary PM2.5 9.72 3,769 0.0101 9.72 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Primary PM2.5 3.06 1,798 0.0021 3.06

2,206,470 4,668,250Single Burn Rate Stoves Primary PM2.5 30.6 71,424 0.0324 8.76 2104008610 364,560 3,654,153Hydronic heater: outdoor Primary PM2.5 64 116,933 0.3208 6.4 2104008510 351,023 2,624,115Furnace: indoor, cordwood Primary PM2.5 64 83,972 0.2392 16 0.0060Baseline woodstove weighted average (Tons/appl)

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

Wood Stoves 126,527 80,851 77,617 79,247 80,911 82,610 84,345 86,116 87,924 Single Burn Rate Stoves 40,000 25,560 24,538 25,053 25,579 26,116 26,665 27,225 27,796 Pellet Stoves 130,381 83,313 79,981 81,661 83,375 85,126 86,914 88,739 90,603 Furnace: indoor, cordwood 41,000 26,199 25,151 25,679 26,218 26,769 27,331 27,905 28,491 Hydronic Heating Systems 13,385 8,553 8,211 8,383 13,100 13,375 13,656 13,943 14,236

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 563 360 345 353 360 368 375 383 391 Single Burn Rate Stoves 1,295 827 794 811 828 845 863 881 900 Pellet Stoves 83 53 51 52 53 54 55 57 58 Furnace: indoor, cordwood 9,808 6,267 6,017 6,143 6,272 6,404 6,538 6,675 6,816 Hydronic Heating Systems 3,520 2,250 2,160 2,205 3,446 3,518 3,592 3,667 3,744 Total **15,269 9,757**  **9,367 9,564**  **10,959 11,189**  **11,424 11,664**  **11,909 Table 4. Estimated Annual Shipped Units** 

**Table 5. Estimated PM 2.5 Emissions (Tons) -- Baseline***

### Baseline PM2.5 

### Emissions2 

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline PM2.5



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $3,024,928 $1,209,971 383 383 0 N/A 383 383 0 2016 $3,024,928 $1,209,971 391 391 0 N/A 775 775 0 2017 $3,024,928 $1,209,971 399 399 0 N/A 1,174 1,174 0 2018 $3,024,928 $1,209,971 445 445 0 N/A 1,619 1,619 0 2019 $3,024,928 $1,209,971 454 454 0 N/A 2,073 2,073 0 20204 

### $3,024,928 $1,209,971 464 260 204 $5,920 2,537 2,333 204 2021 $0 $1,209,971 474 265 209 $5,799 3,011 2,598 413 2022 $0 $1,209,971 484 271 213 $5,679 3,495 2,868 626 2023 $0 $1,209,971 494 276 218 $5,563 3,988 3,145 844 2024 $0 $1,209,971 504 282 222 $5,448 4,492 3,427 1,066 2025 $0 $1,209,971 515 288 227 $5,336 5,007 3,715 1,292 2026 $0 $1,209,971 526 294 232 $5,226 5,533 4,009 1,524 2027 $0 $1,209,971 537 300 236 $5,119 6,069 4,309 1,760 2028 $0 $1,209,971 548 306 241 $5,014 6,617 4,615 2,002 2029 $0 $1,209,971 559 313 246 $4,910 7,176 4,928 2,248 2030 7,176 4,928 2,248 2031 7,176 4,928 2,248 2032 7,176 4,928 2,248 2033 7,176 4,928 2,248 2034 7,176 4,928 2,248 2035 6,793 4,545 2,248 2036 6,402 4,154 2,248 2037 6,002 3,754 2,248 2038 5,557 3,309 2,248 2039 5,103 2,855 2,248 2040 4,639 2,595 2,044 2041 4,165 2,330 1,835 2042 3,682 2,060 1,622 2043 3,188 1,784 1,404 2044 2,684 1,501 1,182 2045 2,169 1,214 956 2046 1,644 920 724 2047 1,107 619 488 2048 559 313 246

$18,149,566 35,231 $515

**Cost Effectiveness (CE) based on annual and cumulative PM 2.5** 

### 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 7% 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 cost5

### Baseline PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline PM2.5



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $1,484,192 $857,473 57 57 0 N/A 57 57 0 2016 $1,484,192 $857,473 58 58 0 N/A 114 114 0 2017 $1,484,192 $857,473 59 59 0 N/A 173 173 0 2018 $1,564,285 $857,473 60 60 0 N/A 233 233 0 2019 $1,564,285 $857,473 61 61 0 N/A 295 295 0 20204 

### $1,564,285 $857,473 63 28 35 $24,611 357 323 35 2021 $412,963 $857,473 64 28 36 $24,104 421 351 70 2022 $412,963 $857,473 65 29 36 $23,609 487 380 107 2023 $412,963 $857,473 67 30 37 $23,123 554 410 144 2024 $412,963 $857,473 68 30 38 $22,647 622 440 182 2025 $412,963 $857,473 70 31 39 $22,182 691 471 220 2026 $412,963 $857,473 71 32 39 $21,725 762 503 260 2027 $412,963 $857,473 73 32 40 $21,279 835 535 300 2028 $412,963 $857,473 74 33 41 $20,841 909 568 341 2029 $412,963 $857,473 76 34 42 $20,412 985 601 383 2030 985 601 383 2031 985 601 383 2032 985 601 383 2033 985 601 383 2034 985 601 383 2035 928 545 383 2036 870 487 383 2037 811 428 383 2038 751 368 383 2039 690 307 383 2040 627 279 348 2041 563 250 313 2042 498 221 277 2043 431 192 239 2044 363 161 202 2045 293 130 163 2046 222 99 123 2047 150 67 83 2048 76 34 42

$12,862,099 6,006 $2,142

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 PM 2.5** 

### 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 7% 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

3

### These 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

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 lifespanBaseline PM2.5 Emissions2 (tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton) Baseline PM2.5

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons) 20154 $1,057,518 $387,171 881 252 629 $616 881 252 629 2016 $1,057,518 $387,171 900 258 642 $603 1,781 510 1,271 2017 $1,057,518 $387,171 919 263 656 $590 2,700 773 1,927 2018 $680,112 $387,171 938 269 669 $578 3,638 1,041 2,596 2019 $680,112 $387,171 958 274 684 $566 4,595 1,316 3,280 20204 $680,112 $387,171 978 124 853 $454 5,573 1,440 4,133 2021 $66,074 $387,171 998 127 871 $444 6,571 1,567 5,004 2022 $66,074 $387,171 1,019 130 890 $435 7,591 1,697 5,894 2023 $66,074 $387,171 1,041 132 908 $426 8,631 1,829 6,802 2024 $66,074 $387,171 1,063 135 927 $418 9,694 1,964 7,730 2025 $66,074 $387,171 1,085 138 947 $409 10,779 2,102 8,676 2026 $66,074 $387,171 1,108 141 967 $401 11,886 2,243 9,643 2027 $66,074 $387,171 1,131 144 987 $392 13,017 2,387 10,630 2028 $66,074 $387,171 1,155 147 1,008 $384 14,172 2,534 11,638 2029 $66,074 $387,171 1,179 150 1,029 $376 15,351 2,684 12,667 2030 15,351 2,684 12,667 2031 15,351 2,684 12,667 2032 15,351 2,684 12,667 2033 15,351 2,684 12,667 2034 15,351 2,684 12,667 2035 14,469 2,432 12,038 2036 13,570 2,174 11,396 2037 12,651 1,911 10,740 2038 11,713 1,643 10,070 2039 10,755 1,368 9,387 2040 9,778 1,244 8,534 2041 8,779 1,117 7,662 2042 7,760 987 6,773 2043 6,719 855 5,864 2044 5,657 720 4,937 2045 4,572 582 3,990 2046 3,464 441 3,024 2047 2,334 297 2,037 2048 1,179 150 1,029

$5,807,558 173,481 $33

**Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **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 7% 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 PM2.5 Emissions2(tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline PM2.5

Emissions (tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $5,566,638 $2,454,615 1,321 692 629 $3,903 1,321 692 629 2016 $5,566,638 $2,454,615 1,349 707 642 $3,822 2,670 1,399 1,271 2017 $5,566,638 $2,454,615 1,377 721 656 $3,744 4,047 2,120 1,927 2018 $5,269,325 $2,454,615 1,443 774 669 $3,667 5,490 2,894 2,596 2019 $5,269,325 $2,454,615 1,473 790 684 $3,591 6,963 3,684 3,280 20204 $5,269,325 $2,454,615 1,504 412 1,093 $2,247 8,468 4,095 4,372 2021 $479,037 $2,454,615 1,536 420 1,116 $2,200 10,004 4,516 5,488 2022 $479,037 $2,454,615 1,568 429 1,139 $2,155 11,572 4,945 6,627 2023 $479,037 $2,454,615 1,601 438 1,163 $2,111 13,173 5,383 7,790 2024 $479,037 $2,454,615 1,635 448 1,187 $2,067 14,808 5,831 8,977 2025 $479,037 $2,454,615 1,669 457 1,212 $2,025 16,477 6,288 10,189 2026 $479,037 $2,454,615 1,704 466 1,238 $1,983 18,181 6,754 11,427 2027 $479,037 $2,454,615 1,740 476 1,264 $1,942 19,921 7,231 12,691 2028 $479,037 $2,454,615 1,777 486 1,290 $1,902 21,698 7,717 13,981 2029 $479,037 $2,454,615 1,814 497 1,317 $1,863 23,512 8,213 15,298 2030 23,512 8,213 15,298 2031 23,512 8,213 15,298 2032 23,512 8,213 15,298 2033 23,512 8,213 15,298 2034 23,512 8,213 15,298 2035 22,191 7,521 14,669 2036 20,842 6,815 14,027 2037 19,465 6,093 13,371 2038 18,022 5,320 12,702 2039 16,548 4,530 12,018 2040 15,044 4,118 10,926 2041 13,508 3,698 9,810 2042 11,940 3,268 8,671 2043 10,338 2,830 7,508 2044 8,704 2,382 6,321 2045 7,034 1,926 5,109 2046 5,330 1,459 3,871 2047 3,590 983 2,608 2048 1,814 497 1,317

$36,819,222 214,718 $171

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 PM 2.5** **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 7% 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.

2Except 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons) CE based on

nationwide average annual cost (per ton) Baseline PM2.5



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons) 20154 

### $20,905,663 $6,299,286 6,675 6,675 0 N/A 6,675 6,675 0 20164 

### $20,905,663 $6,299,286 6,816 5,538 1,278 $4,929 13,491 12,213 1,278 20174 

### $12,576,770 $6,299,286 6,959 1,740 5,219 $1,207 20,450 13,953 6,497 2018 $12,593,240 $6,299,286 7,105 1,776 5,329 $1,182 27,555 15,729 11,826 2019 $12,593,240 $6,299,286 7,254 1,814 5,441 $1,158 34,809 17,543 17,266 20204 

### $12,593,240 $6,299,286 7,406 231 7,175 $878 42,215 17,774 24,441 2021 $257,941 $6,299,286 7,562 236 7,326 $860 49,777 18,010 31,767 2022 $257,941 $6,299,286 7,721 241 7,480 $842 57,498 18,252 39,247 2023 $257,941 $6,299,286 7,883 246 7,637 $825 65,381 18,498 46,883 2024 $257,941 $6,299,286 8,048 252 7,797 $808 73,430 18,750 54,680 2025 $257,941 $6,299,286 8,217 257 7,961 $791 81,647 19,006 62,641 2026 $257,941 $6,299,286 8,390 262 8,128 $775 90,037 19,269 70,769 2027 $257,941 $6,299,286 8,566 268 8,299 $759 98,603 19,536 79,067 2028 $257,941 $6,299,286 8,746 273 8,473 $743 107,350 19,810 87,540 2029 $257,941 $6,299,286 8,930 279 8,651 $728 116,279 20,089 96,191 2030 116,279 20,089 96,191 2031 116,279 20,089 96,191 2032 116,279 20,089 96,191 2033 116,279 20,089 96,191 2034 116,279 20,089 96,191 2035 109,604 13,413 96,191 2036 102,788 7,875 94,913 2037 95,829 6,136 89,694 2038 88,725 4,359 84,365 2039 81,470 2,546 78,924 2040 74,064 2,314 71,749 2041 66,502 2,078 64,424 2042 58,781 1,837 56,944 2043 50,898 1,591 49,308 2044 42,850 1,339 41,511 2045 34,632 1,082 33,550 2046 26,242 820 25,422 2047 17,676 552 17,124 2048 8,930 279 8,651

$94,489,287 1,389,914 $68

**Cost Effectiveness (CE) based on annual and cumulative PM 2.5** 

### 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 7% 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 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

nationwide average annual cost (per ton) Baseline PM2.5



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $24,855,398 $10,321,500.34 3,667 367 3,300 $3,127 3,667 367 3,300 2016 $24,855,398 $10,321,500.34 3,744 374 3,370 $3,063 7,411 741 6,670 2017 $24,855,398 $10,321,500.34 3,823 382 3,441 $3,000 11,234 1,123 10,111 2018 $24,894,927 $10,321,500.34 3,903 390 3,513 $2,938 15,137 1,514 13,623 2019 $24,894,927 $10,321,500.34 3,985 399 3,587 $2,878 19,122 1,912 17,210 20204 

### $24,894,927 $10,321,500.34 4,069 127 3,942 $2,619 23,191 2,039 21,152 2021 $619,059 $10,321,500.34 4,154 130 4,024 $2,565 27,345 2,169 25,176 2022 $619,059 $10,321,500.34 4,241 133 4,109 $2,512 31,587 2,302 29,285 2023 $619,059 $10,321,500.34 4,330 135 4,195 $2,460 35,917 2,437 33,480 2024 $619,059 $10,321,500.34 4,421 138 4,283 $2,410 40,338 2,575 37,763 2025 $619,059 $10,321,500.34 4,514 141 4,373 $2,360 44,853 2,716 42,136 2026 $619,059 $10,321,500.34 4,609 144 4,465 $2,312 49,462 2,860 46,601 2027 $619,059 $10,321,500.34 4,706 147 4,559 $2,264 54,168 3,007 51,160 2028 $619,059 $10,321,500.34 4,805 150 4,655 $2,218 58,972 3,158 55,815 2029 $619,059 $10,321,500.34 4,906 153 4,752 $2,172 63,878 3,311 60,567 2030 63,878 3,311 60,567 2031 63,878 3,311 60,567 2032 63,878 3,311 60,567 2033 63,878 3,311 60,567 2034 63,878 3,311 60,567 2035 60,211 2,944 57,267 2036 56,467 2,570 53,897 2037 52,644 2,187 50,456 2038 48,741 1,797 46,944 2039 44,756 1,399 43,357 2040 40,687 1,271 39,415 2041 36,533 1,142 35,391 2042 32,291 1,009 31,282 2043 27,961 874 27,087 2044 23,539 736 22,804 2045 19,025 595 18,431 2046 14,416 451 13,966 20473 

### 9,710 303 9,407 20483 

### 4,906 153 4,752

$154,822,505 817,858 $189

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 PM 2.5** 

### 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 7% 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

### Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 PM2.5 Emissions2(tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline PM2.5

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $45,761,061 $16,620,786 10,343 7,042 3,300 $5,036 10,343 7,042 3,300 20164 $45,761,061 $16,620,786 10,560 5,912 4,648 $3,576 20,902 12,954 7,948 20174 $37,432,168 $16,620,786 10,782 2,122 8,660 $1,919 31,684 15,076 16,608 2018 $37,488,168 $16,620,786 11,008 2,167 8,841 $1,880 42,692 17,243 25,449 2019 $37,488,168 $16,620,786 11,239 2,212 9,027 $1,841 53,931 19,455 34,476 20204 $37,488,168 $16,620,786 11,475 359 11,117 $1,495 65,406 19,813 45,593 2021 $877,000 $16,620,786 11,716 366 11,350 $1,464 77,123 20,180 56,943 2022 $877,000 $16,620,786 11,962 374 11,588 $1,434 89,085 20,553 68,531 2023 $877,000 $16,620,786 12,213 382 11,832 $1,405 101,298 20,935 80,363 2024 $877,000 $16,620,786 12,470 390 12,080 $1,376 113,768 21,325 92,443 2025 $877,000 $16,620,786 12,732 398 12,334 $1,348 126,500 21,723 104,777 2026 $877,000 $16,620,786 12,999 406 12,593 $1,320 139,499 22,129 117,370 2027 $877,000 $16,620,786 13,272 415 12,857 $1,293 152,771 22,544 130,227 2028 $877,000 $16,620,786 13,551 423 13,127 $1,266 166,322 22,967 143,355 2029 $877,000 $16,620,786 13,835 432 13,403 $1,240 180,157 23,399 156,758 2030 180,157 23,399 156,758 2031 180,157 23,399 156,758 2032 180,157 23,399 156,758 2033 180,157 23,399 156,758 2034 180,157 23,399 156,758 2035 169,815 16,357 153,457 2036 159,255 10,445 148,810 2037 148,473 8,323 140,150 2038 137,465 6,157 131,309 2039 126,226 3,945 122,282 2040 114,751 3,586 111,165 2041 103,035 3,220 99,815 2042 91,073 2,846 88,227 2043 78,859 2,464 76,395 2044 66,389 2,075 64,315 2045 53,657 1,677 51,981 2046 40,658 1,271 39,388 20473 27,386 856 26,530 20483 13,835 432 13,403

$249,311,792 2,207,772 $113 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 PM 2.5** **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 7% 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.

2Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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 PM2.5 Emissions2(tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

nationwide average annual cost (per ton) Baseline PM2.5

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $51,327,699 $19,075,401 11,664 7,734 3,929 $4,854 11,664 7,734 3,929 20164 $51,327,699 $19,075,401 11,909 6,619 5,290 $3,606 23,572 14,353 9,219 20174 $42,998,805 $19,075,401 12,159 2,843 9,315 $2,048 35,731 17,196 18,535 2018 $42,757,493 $19,075,401 12,451 2,940 9,511 $2,006 48,182 20,137 28,046 2019 $42,757,493 $19,075,401 12,713 3,002 9,711 $1,964 60,895 23,139 37,756 20204 $42,757,493 $19,075,401 12,980 770 12,209 $1,562 73,874 23,909 49,965 2021 $1,356,037 $19,075,401 13,252 787 12,466 $1,530 87,126 24,696 62,431 2022 $1,356,037 $19,075,401 13,530 803 12,727 $1,499 100,657 25,499 75,158 2023 $1,356,037 $19,075,401 13,815 820 12,995 $1,468 114,471 26,319 88,153 2024 $1,356,037 $19,075,401 14,105 837 13,268 $1,438 128,576 27,156 101,420 2025 $1,356,037 $19,075,401 14,401 855 13,546 $1,408 142,977 28,011 114,966 2026 $1,356,037 $19,075,401 14,703 873 13,831 $1,379 157,680 28,883 128,797 2027 $1,356,037 $19,075,401 15,012 891 14,121 $1,351 172,692 29,774 142,918 2028 $1,356,037 $19,075,401 15,327 910 14,418 $1,323 188,020 30,684 157,336 2029 $1,356,037 $19,075,401 15,649 929 14,720 $1,296 203,669 31,613 172,056 2030 203,669 31,613 172,056 2031 203,669 31,613 172,056 2032 203,669 31,613 172,056 2033 203,669 31,613 172,056 2034 203,669 31,613 172,056 2035 192,005 23,879 168,127 2036 180,097 17,260 162,837 2037 167,938 14,417 153,521 2038 155,487 11,476 144,010 2039 142,774 8,474 134,300 2040 129,795 7,704 122,091 2041 116,543 6,917 109,625 2042 103,012 6,114 96,898 2043 89,197 5,294 83,903 2044 75,093 4,457 70,636 2045 60,692 3,602 57,090 2046 45,989 2,730 43,259 20473 30,977 1,839 29,138 20483 15,649 929 14,720

$286,131,014 2,422,490 $118

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 PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)** 

CE based on total cost & cumulative emission reduction over 20-year 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 7% 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.

2Except for adjustments in years 2012 and 2018 based on an industry projections (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.1% from 2015 through 2029, for the purposes of a sensitivity analysis.

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.