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 42,610 22,794 32,702

annualized over 6 years at 7% 

interest (note: NERA annualized 

over 10 years) Annualized capital cost per model 67,785 36,641 52,213

annualized 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 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 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

820,000 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

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)334 125 $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.)7,830 120 $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: 

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 Primary PM2.5 8.76 5,371 0.0041 8.76

2104008230 427,224 416,187

Woodstove: fireplace inserts; EPA 

certified; catalytic Primary PM2.5 9.72 2,023 0.0047 9.72

2104008320 873,357 1,540,026

Woodstove: freestanding, EPA 

certified, non-catalytic Primary PM2.5 8.76 6,745 0.0077 8.76

2104008330 374,154 775,602

Woodstove: freestanding, EPA 

certified, catalytic Primary PM2.5 9.72 3,769 0.0101 9.72

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Primary PM2.5 3.06 1,798 0.0021 3.06

2,206,470 4,668,250 Single Burn Rate Stoves Primary PM2.5 30.6 71,424 0.0324 8.76

2104008610 364,560 3,654,153 Hydronic heater: outdoor Primary PM2.5 64 116,933 0.3208 6.4

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Primary PM2.5 64 83,972 0.2392 16

0.0060 Baseline 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

2015 4$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

2020 4$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 PM2.5 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 7% 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 

2.1% 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 

Nationwide cumulative cost over 20-year emitting lifespan 5 
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

2015 4$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

2020 4$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 PM2.5 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). 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 2.1% 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.

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 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)

2015 4$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

2020 4$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 PM2.5 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 7% 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 2.1% 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 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 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

2015 4$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

2020 4$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

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 PM2.5 emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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 7% 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

 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. 

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 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)

2015 4$20,905,663 $6,299,286 6,675 6,675 0 N/A 6,675 6,675 0

2016 4$20,905,663 $6,299,286 6,816 5,538 1,278 $4,929 13,491 12,213 1,278

2017 4$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

2020 4$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 PM2.5 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). 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 2.1% 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.

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 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

2015 4$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

2020 4$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

2047 3

9,710 303 9,407

2048 3

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 PM2.5 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). Years 2030 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 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

2015 4$45,761,061 $16,620,786 10,343 7,042 3,300 $5,036 10,343 7,042 3,300

2016 4$45,761,061 $16,620,786 10,560 5,912 4,648 $3,576 20,902 12,954 7,948

2017 4$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

2020 4$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

2047 3

27,386 856 26,530

2048 3

13,835 432 13,403

$249,311,792 2,207,772 $113

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 PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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 7% 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

 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 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 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

2015 4$51,327,699 $19,075,401 11,664 7,734 3,929 $4,854 11,664 7,734 3,929

2016 4$51,327,699 $19,075,401 11,909 6,619 5,290 $3,606 23,572 14,353 9,219

2017 4$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

2020 4$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

2047 3 30,977 1,839 29,138

2048 3

15,649 929 14,720

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

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 PM2.5 emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, 

Pellet Stoves, and Single Burn Rate Stoves)

CE based on total 

cost & cumulative 

emission reduction 

over 20-year 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 7% 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

 Except 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. 

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.