# 12/2/2010, revised 12/3/2012, 1/5/2013 and 2/4/2013

**DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation**
**R&D Annual Cost Summary Development of 4 Model Fireboxes**  **Round One 6-year R&D**  **Period Direct Annual Costs (DAC)** 

Operator labor $141,667

Outside Consultants $26,667
**Total Direct Costs (DC)** $168,333
**Indirect Annual Costs (IAC)**

Laboratory Equipment1, 2 

# $9,230
Re-tooling1 

# $22,152

Other Capital Costs1, 3 

# $45,226
**Total Indirect Costs (IAC)** $76,608 **Round One Total Annual Cost**  $244,941 **Total Annual Cost** $61,235

0.31 Note: Fraction that Capital Cost is of Total Cost = 3

# To conservatively estimate the additional cost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib only was increased by $15,000 and the testing services estimate of $100,000 based on crib only (which covered not only emissions testing but also efficiency and safety testing) was increased by $50,000. 1

# An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's estimate that approximately 6 years of R&D are required to bring a product to market .

2

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

# DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation

**Round Two 6- year R&D**  **Period**

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $141,667 Annual outside consultant cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $26,667
$168,333

The laboratory equipment cost of $50,000 was amortized over 6 years at an interest rate of 3%. $0 The re-tooling cost of $120,000 was amortized over 6 years at an interest rate of 3%. $22,152
Other capital costs include costs for prototypes ($25,000), test fuel ($30,000+$15,000), testing services ($100,000+$50,000), and marketing ($25,000) and were amortized over 6 years at an interest rate of 3%. $45,226
$67,378 **Round Two 2**  

# Annual cost for development of 4 model fireboxes. $235,711 Average annual cost per firebox model. $58,928

To conservatively estimate the additional cost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib only was increased by $15,000 and the testing services estimate of $100,000 based on crib only (which covered not only emissions testing but also An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's estimate that approximately 6 years of R&D are required to bring a product to market .

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

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

2013 Wood Stoves (R&D)3 

# 34 125 $213,873 Pellet Stoves (R&D, R&R)4, 8 

# 29 125 $191,793 Pellet Stoves (certification)4 

# 29 125 $2,586 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 

# 3 20 $827,346

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 

# 7 50 $879,801 Hydronic Heating Systems (R&D, R&R, cert.)6, 8 

# 30 120 $247,747

MH - large companies (R&D, R&R, cert.)9 

# 2 4 $124,940 MH - large companies (R&R, cert.)9 

# 3 9 $9,704 MH - large companies (R&R, software cert.)7, 9 

# 1 8 $11,378 MH - small companies (R&R, software cert.)7, 9 

# 42 85 $3,852

7

# For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer. Appliance Type

8

# Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496. Annual Cost of the Rule

6

# For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. 1

# Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

2

# Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

3

# This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing NSPS.
4

# For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013.

5

# Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 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 conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more stringent 2017 Step 2 and 2022 Step 3 standards.

9

# Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872.# Manufacturers # ModelsAverage Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing

QQQQ: Central Heaters

RRRR: Masonry Heaters AAA: Room Heaters NSPS Subpart

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

(Step 1 compliance) 2014 2015 2016 (Step 2 compliance) 2017 2018 2019 2020 $213,873 $213,873 $213,873 $378,525 $378,525 $164,651 $164,651 $191,793 $191,793 $191,793 $334,033 $334,033 $149,271 $149,271 $2,586 $2,586 $2,586 $2,586 $2,586 $3,793 $3,793 $827,346 $419,111 $419,111 $733,393 $733,393 $327,824 $327,824
$879,801 $442,406 $442,406 $779,136 $779,136 $347,455 $347,455 $247,747 $247,747 $247,747 $436,316 $436,316 $194,575 $194,575
$124,940 $124,940 $124,940 $124,940 $124,940 $6,469 $6,469 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802

For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer. Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496. For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS. Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year. This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 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 conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more stringent 2017 Step 2 and 2022 Step 3 standards.

Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872. Average Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing certification costs (through 2041)

# 2021 (Step 3 compliance) 2022 2023

through 20412 

# 2013 2014 2015 2016 2017 $164,651 $164,651 $0 7,271,695 7,271,695 7,271,695 7,271,69512,869,841 $149,271 $149,271 $7,031 5,562,000 5,562,000 5,562,000 5,562,000 9,686,950 $3,793 $3,793 $8,621 75,000 75,000 75,000 75,000 75,000 $327,824 $327,824$24,208 2,482,038 2,482,038 1,257,332 1,257,332 2,200,178 15,390,73315,390,73314,166,02614,166,02624,831,968 $347,455 $347,455$33,582 6,158,606 6,158,606 3,096,839 3,096,839 5,453,954 $194,575 $194,575$18,806 7,432,415 7,432,415 7,432,415 7,432,41513,089,489 $13,591,020$13,591,020$10,529,254$10,529,254$18,543,442 $6,469 $6,469 $6,469 $249,880 $249,880 $249,880 $249,880 $249,880 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328$10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $452,158 $407,008 $407,008 $407,008 $407,008
$29,433,911$29,388,761$25,102,289$25,102,289$43,782,419

For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using
Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 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 conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs

Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872. Average Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing Nationwide Annual Costs

# 2018 2019 2020 2021 2022 2023 through 20412 

# 12,869,841 5,598,146 5,598,146 5,598,146 5,598,146 $0 9,686,950 4,328,859 4,328,859 4,328,859 4,328,859 $203,909 75,000 110,000 110,000 110,000 110,000 $250,000 2,200,178 983,471 983,471 983,471 983,471 $72,625 24,831,96811,020,47611,020,47611,020,47611,020,476 $526,534 5,453,954 2,432,187 2,432,187 2,432,187 2,432,187 $235,073 13,089,489 5,837,250 5,837,250 5,837,250 5,837,250 $564,176 $18,543,442$8,269,437$8,269,437$8,269,437$8,269,437 $799,249 $249,880 $12,939 $12,939 $12,939 $12,939 $12,939 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $407,008 $170,067 $170,067 $170,067 $170,067 $170,067
$43,782,419$19,459,980$19,459,980$19,459,980$19,459,980$1,495,850

Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 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 conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs Nationwide Annual Costs1

# Period Nationwide Cost of the Rule Year 2022 $19,459,980 Year 2023 & following $1,495,850

Cumulative (2013 through 2033) $302,853,163

# SCC **Appliance Population**  **Total Tons Burned Emission Inventory Category**  **Pollutant Baseline**  **Emission factor**  **(lb/ton) Baseline** 

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

**Tons/appl Step 1** 

**Emission Factor**  2104008220 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Volatile Organic Compounds 15 3,121 0.0073 15 2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Volatile Organic Compounds 12 9,240 0.0106 12 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Volatile Organic Compounds 15 5,817 0.0155 15 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Volatile Organic Compounds 0.041 24 0.0000 0.041 2,206,470 4,668,250Single Burn Rate Stoves Volatile Organic Compounds 53 123,709 0.0561 12 2104008610 364,560 3,654,153Hydronic heater: outdoor Volatile Organic Compounds 11.7 21,377 0.0586 1.17 2104008510 351,023 2,624,115Furnace: indoor, cordwood Volatile Organic Compounds 11.7 15,351 0.0437 2.925

0.0086Baseline woodstove weighted average (Tons/appl)

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

Wood Stoves 126,527 80,851 77,617 79,169 80,752 82,367 84,015 85,69587,409 Single Burn Rate Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,09127,633 Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,30590,072 Furnace: indoor, cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,76928,324 Hydronic Heating Systems 13,385 8,553 8,211 8,375 8,543 8,713 8,888 9,065 9,247

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 1,085 693 666 679 692 706 720 735 750 Single Burn Rate Stoves 2,243 1,433 1,376 1,403 1,431 1,460 1,489 1,519 1,549 Pellet Stoves 4 2 2 2 2 2 2 3 3 Furnace: indoor, cordwood 1,793 1,146 1,100 1,122 1,144 1,167 1,191 1,214 1,239 Hydronic Heating Systems 785 502 481 491 501 511 521 532 542 Total **5,909 3,776**  **3,625 3,697**  **3,771 3,847**  **3,924 4,002**  **4,082 Table 4. Estimated Annual Shipped Units** 

**Table 5. Estimated VOC Emissions (Tons) -- Baseline**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) 20133 $4,813,613$15,390,733$5,615,983 20144 $4,813,613$15,390,733$5,615,983 2,212 1,060 1,152 $4,875 2,212 1,060 1,152 20154 $4,430,573$14,166,026$5,615,983 2,256 1,081 1,175 $4,780 4,468 2,141 2,327 20164 $4,430,573$14,166,026$5,615,983 2,301 1,103 1,199 $4,686 6,770 3,244 3,526 2017 $7,766,459$24,831,968$5,615,983 2,347 740 1,607 $3,494 9,117 3,984 5,133 2018 $7,766,459$24,831,968$5,615,983 2,394 755 1,640 $3,425 11,512 4,739 6,772 2019 $3,446,770$11,020,476$5,615,983 2,442 770 1,672 $3,358 13,954 5,509 8,445 2020 $3,446,770$11,020,476$5,615,983 2,491 785 1,706 $3,292 16,445 6,294 10,150 2021 $3,446,770$11,020,476$5,615,983 2,541 801 1,740 $3,228 18,986 7,096 11,890 2022 $3,446,770$11,020,476$5,615,983 2,592 425 2,167 $2,592 21,578 7,520 14,057 2023 $0 $526,534 $5,615,983 2,644 433 2,210 $2,541 24,221 7,954 16,267 2024 $0 $526,534 $5,615,983 2,696 442 2,254 $2,491 26,918 8,396 18,522 2025 $0 $526,534 $5,615,983 2,750 451 2,299 $2,442 29,668 8,847 20,821 2026 $0 $526,534 $5,615,983 2,805 460 2,345 $2,394 32,473 9,307 23,167 2027 $0 $526,534 $5,615,983 2,862 469 2,392 $2,347 35,335 9,776 25,559 2028 $0 $526,534 $5,615,983 2,919 478 2,440 $2,301 38,254 10,254 27,999 2029 $0 $526,534 $5,615,983 2,977 488 2,489 $2,256 41,231 10,742 30,488 2030 $0 $526,534 $5,615,983 3,037 498 2,539 $2,212 44,267 11,240 33,027 2031 $0 $526,534 $5,615,983 3,097 508 2,590 $2,169 47,365 11,748 35,617 2032 $0 $526,534 $5,615,983 3,159 518 2,641 $2,126 50,524 12,266 38,258 2033 $0 $526,534 $5,615,983 3,223 528 2,694 $2,084 53,747 12,794 40,953 2034 $0 $526,534 $5,615,983 3,287 539 2,748 $2,044 54,822 12,273 42,549 2035 $0 $526,534 $5,615,983 3,353 550 2,803 $2,004 55,918 11,741 44,177 2036 $0 $526,534 $5,615,983 3,420 561 2,859 $1,964 57,036 11,199 45,837 2037 $0 $526,534 $5,615,983 3,488 572 2,916 $1,926 58,177 11,031 47,146 2038 $0 $526,534 $5,615,983 3,558 583 2,975 $1,888 59,341 10,859 48,481 2039 $0 $526,534 $5,615,983 3,629 595 3,034 $1,851 60,528 10,684 49,843 2040 $0 $526,534 $5,615,983 3,702 607 3,095 $1,815 61,738 10,506 51,232 2041 $0 $526,534 $5,615,983 3,776 619 3,157 $1,779 62,973 10,324 52,649 2042 60,381 9,899 50,482 2043 57,737 9,465 48,272 2044 55,041 9,023 46,018 2045 52,291 8,572 43,718 2046 49,485 8,113 41,373 2047 46,624 7,643 38,980 2048 43,705 7,165 36,540 2049 40,728 6,677 34,051 2050 37,691 6,179 31,512 2051 34,594 5,671 28,923 2052 31,435 5,153 26,281 2053 28,212 4,625 23,587 2054 24,925 4,086 20,839 2055 21,572 3,537 18,036 2056 18,153 2,976 15,177 2057 14,664 2,404 12,260 2058 11,106 1,821 9,286 2059 7,477 1,226 6,252 2060 3,776 619 3,157

$162,863,508 587,392 $277 **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)**

Nationwide cumulative cost5

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves and pellet stoves, estimates conservatively assume that most models meet Step 1 and that manufacturers will certify and sell existing models meeting Step 1 from 2014 through 2016. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2017. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Cumulative Emission Reduction over 20-year stove lifespan Emission Reduction, cumulative per year Annual SnapshotsBaseline 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) 20133 $2,274,299$7,271,695 $2,662,726 20144 $2,274,299$7,271,695 $2,662,726 720 720 0 N/A 720 720 0 20154 $2,274,299$7,271,695 $2,662,726 735 735 0 N/A 1,455 1,455 0 20164 $2,274,299$7,271,695 $2,662,726 750 750 0 N/A 2,205 2,205 0 2017 $4,025,178$12,869,841$2,662,726 765 541 224 $11,908 2,969 2,746 224 2018 $4,025,178$12,869,841$2,662,726 780 552 228 $11,674 3,749 3,297 452 2019 $1,750,879$5,598,146 $2,662,726 795 563 233 $11,445 4,545 3,860 684 2020 $1,750,879$5,598,146 $2,662,726 811 574 237 $11,221 5,356 4,434 922 2021 $1,750,879$5,598,146 $2,662,726 828 586 242 $11,001 6,183 5,020 1,164 2022 $1,750,879$5,598,146 $2,662,726 844 311 534 $4,991 7,028 5,330 1,697 2023 $0 $0 $2,662,726 861 317 544 $4,893 7,889 5,647 2,241 2024 $0 $0 $2,662,726 878 323 555 $4,797 8,767 5,970 2,797 2025 $0 $0 $2,662,726 896 330 566 $4,703 9,663 6,300 3,363 2026 $0 $0 $2,662,726 914 336 578 $4,610 10,576 6,636 3,940 2027 $0 $0 $2,662,726 932 343 589 $4,520 11,508 6,979 4,529 2028 $0 $0 $2,662,726 951 350 601 $4,431 12,459 7,329 5,130 2029 $0 $0 $2,662,726 970 357 613 $4,345 13,428 7,685 5,743 2030 $0 $0 $2,662,726 989 364 625 $4,259 14,417 8,049 6,368 2031 $0 $0 $2,662,726 1,009 371 638 $4,176 15,426 8,420 7,006 2032 $0 $0 $2,662,726 1,029 379 650 $4,094 16,455 8,799 7,656 2033 $0 $0 $2,662,726 1,050 386 663 $4,014 17,505 9,185 8,320 2034 $0 $0 $2,662,726 1,071 394 677 $3,935 17,855 8,858 8,996 2035 $0 $0 $2,662,726 1,092 402 690 $3,858 18,212 8,525 9,687 2036 $0 $0 $2,662,726 1,114 410 704 $3,782 18,576 8,186 10,391 2037 $0 $0 $2,662,726 1,136 418 718 $3,708 18,948 8,063 10,885 2038 $0 $0 $2,662,726 1,159 426 732 $3,635 19,327 7,937 11,390 2039 $0 $0 $2,662,726 1,182 435 747 $3,564 19,713 7,809 11,904 2040 $0 $0 $2,662,726 1,206 444 762 $3,494 20,107 7,679 12,429 2041 $0 $0 $2,662,726 1,230 452 777 $3,426 20,510 7,546 12,964 2042 19,665 7,235 12,430 2043 18,805 6,918 11,886 2044 17,926 6,595 11,331 2045 17,031 6,266 10,765 2046 16,117 5,930 10,187 2047 15,185 5,587 9,598 2048 14,234 5,237 8,997 2049 13,265 4,880 8,384 2050 12,276 4,516 7,759 2051 11,267 4,145 7,122 2052 10,238 3,767 6,471 2053 9,188 3,380 5,808 2054 8,118 2,987 5,131 2055 7,026 2,585 4,441 2056 5,912 2,175 3,737 2057 4,776 1,757 3,019 2058 3,617 1,331 2,286 2059 2,435 896 1,539 2060 1,230 452 777

$77,219,046 144,635 $534

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Cumulative Emission Reduction over 20-year stove lifespan Nationwide cumulative cost5 **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Wood Stoves**

Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year
CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)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) 20133 $1,763,031$5,637,000 $2,360,400 20144 $1,763,031$5,637,000 $2,360,400 2 2 0 N/A 2 2 0 20154 $1,763,031$5,637,000 $2,360,400 3 3 0 N/A 5 5 0 20164 $1,763,031$5,637,000 $2,360,400 3 3 0 N/A 8 8 0 2017 $3,053,152$9,761,950 $2,360,400 3 2 0 $9,030,877 10 10 0 2018 $3,053,152$9,761,950 $2,360,400 3 2 0 $8,853,801 13 12 1 2019 $1,388,300$4,438,859 $2,360,400 3 2 0 $8,680,197 16 15 1 2020 $1,388,300$4,438,859 $2,360,400 3 2 0 $8,509,997 18 17 1 2021 $1,388,300$4,438,859 $2,360,400 3 3 0 $8,343,134 21 20 1 2022 $1,388,300$4,438,859 $2,360,400 3 1 2 $1,537,508 24 21 3 2023 $0 $453,909 $2,360,400 3 1 2 $1,507,361 27 23 4 2024 $0 $453,909 $2,360,400 3 1 2 $1,477,805 30 24 6 2025 $0 $453,909 $2,360,400 3 1 2 $1,448,828 33 25 8 2026 $0 $453,909 $2,360,400 3 1 2 $1,420,420 36 27 9 2027 $0 $453,909 $2,360,400 3 1 2 $1,392,568 39 28 11 2028 $0 $453,909 $2,360,400 3 2 2 $1,365,263 43 30 13 2029 $0 $453,909 $2,360,400 3 2 2 $1,338,493 46 31 15 2030 $0 $453,909 $2,360,400 3 2 2 $1,312,248 49 33 16 2031 $0 $453,909 $2,360,400 3 2 2 $1,286,518 53 35 18 2032 $0 $453,909 $2,360,400 4 2 2 $1,261,292 56 36 20 2033 $0 $453,909 $2,360,400 4 2 2 $1,236,561 60 38 22 2034 $0 $453,909 $2,360,400 4 2 2 $1,212,315 61 37 24 2035 $0 $453,909 $2,360,400 4 2 2 $1,188,544 62 36 26 2036 $0 $453,909 $2,360,400 4 2 2 $1,165,239 64 36 28 2037 $0 $453,909 $2,360,400 4 2 2 $1,142,391 65 35 30 2038 $0 $453,909 $2,360,400 4 2 2 $1,119,991 66 35 32 2039 $0 $453,909 $2,360,400 4 2 2 $1,098,031 67 34 33 2040 $0 $453,909 $2,360,400 4 2 2 $1,076,501 69 33 35 2041 $0 $453,909 $2,360,400 4 2 2 $1,055,393 70 33 37 2042 67 31 36 2043 64 30 34 2044 61 29 33 2045 58 27 31 2046 55 26 29 2047 52 24 28 2048 49 23 26 2049 45 21 24 2050 42 20 22 2051 39 18 20 2052 35 16 19 2053 31 15 17 2054 28 13 15 2055 24 11 13 2056 20 9 11 2057 16 8 9 2058 12 6 7 2059 8 4 4 2060 4 2 2

$68,451,599 416 $164,482

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For pellet stoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Pellet Stoves**

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### 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) 20133 

### $776,284$2,482,038 $592,857 20144 

### $776,284$2,482,038 $592,857 1,489 337 1,152 $515 1,489 337 1,152 2015 $393,244$1,257,332 $592,857 1,519 344 1,175 $505 3,008 681 2,327 2016 $393,244$1,257,332 $592,857 1,549 351 1,199 $495 4,557 1,032 3,526 20174 

### $688,129 $2,200,178 $592,857 1,580 197 1,383 $429 6,138 1,229 4,909 2018 $688,129 $2,200,178 $592,857 1,612 201 1,411 $420 7,750 1,429 6,320 2019 $307,591 $983,471 $592,857 1,644 205 1,439 $412 9,394 1,634 7,760 2020 $307,591 $983,471 $592,857 1,677 209 1,468 $404 11,071 1,843 9,228 2021 $307,591 $983,471 $592,857 1,711 213 1,498 $396 12,781 2,056 10,725 20224 

### $307,591 $983,471 $592,857 1,745 113 1,632 $363 14,526 2,169 12,357 2023 $0 $72,625 $592,857 1,780 115 1,664 $356 16,306 2,284 14,021 2024 $0 $72,625 $592,857 1,815 118 1,698 $349 18,121 2,402 15,719 2025 $0 $72,625 $592,857 1,852 120 1,732 $342 19,972 2,522 17,451 2026 $0 $72,625 $592,857 1,889 122 1,766 $336 21,861 2,644 19,217 2027 $0 $72,625 $592,857 1,926 125 1,802 $329 23,787 2,769 21,019 2028 $0 $72,625 $592,857 1,965 127 1,838 $323 25,752 2,896 22,856 2029 $0 $72,625 $592,857 2,004 130 1,874 $316 27,756 3,026 24,731 2030 $0 $72,625 $592,857 2,044 132 1,912 $310 29,801 3,158 26,643 2031 $0 $72,625 $592,857 2,085 135 1,950 $304 31,886 3,293 28,593 2032 $0 $72,625 $592,857 2,127 138 1,989 $298 34,013 3,431 30,582 2033 $0 $72,625 $592,857 2,169 140 2,029 $292 36,182 3,571 32,611 2034 $0 $72,625 $592,857 2,213 143 2,069 $286 36,906 3,377 33,528 2035 $0 $72,625 $592,857 2,257 146 2,111 $281 37,644 3,180 34,464 2036 $0 $72,625 $592,857 2,302 149 2,153 $275 38,397 2,978 35,419 2037 $0 $72,625 $592,857 2,348 152 2,196 $270 39,165 2,933 36,231 2038 $0 $72,625 $592,857 2,395 155 2,240 $265 39,948 2,888 37,060 2039 $0 $72,625 $592,857 2,443 158 2,285 $259 40,747 2,841 37,906 2040 $0 $72,625 $592,857 2,492 161 2,331 $254 41,562 2,794 38,768 2041 $0 $72,625 $592,857 2,542 165 2,377 $249 42,393 2,745 39,648 2042 40,648 2,632 38,016 2043 38,869 2,517 36,352 2044 37,053 2,399 34,654 2045 35,202 2,279 32,922 2046 33,313 2,157 31,156 2047 31,387 2,032 29,354 2048 29,422 1,905 27,517 2049 27,418 1,775 25,642 2050 25,374 1,643 23,731 2051 23,288 1,508 21,780 2052 21,162 1,370 19,791 2053 18,992 1,230 17,762 2054 16,779 1,087 15,693 2055 14,522 940 13,582 2056 12,220 791 11,429 2057 9,872 639 9,233 2058 7,477 484 6,993 2059 5,034 326 4,708 2060 2,542 165 2,377

$17,192,863 442,341 $39

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Single Burn Rate Stoves**

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $4,250,734$13,591,020$4,606,583 20144 $4,250,734$13,591,020$4,606,583 1,712 350 1,362 $3,382 1,712 350 1,362 2015 $3,293,135$10,529,254$4,606,583 1,746 357 1,389 $3,316 3,458 707 2,751 2016 $3,293,135$10,529,254$4,606,583 1,781 364 1,417 $3,251 5,239 1,070 4,168 20174 $5,799,656$18,543,442$4,606,583 1,817 91 1,726 $2,669 7,055 1,161 5,894 2018 $5,799,656$18,543,442$4,606,583 1,853 93 1,760 $2,617 8,908 1,254 7,654 2019 $2,586,353$8,269,437 $4,606,583 1,890 94 1,795 $2,566 10,798 1,348 9,449 2020 $2,586,353$8,269,437 $4,606,583 1,928 96 1,831 $2,515 12,726 1,445 11,281 2021 $2,586,353$8,269,437 $4,606,583 1,966 98 1,868 $2,466 14,692 1,543 13,149 20224 $2,586,353$8,269,437 $4,606,583 2,006 40 1,965 $2,344 16,697 1,583 15,114 2023 $0 $799,249 $4,606,583 2,046 41 2,005 $2,298 18,743 1,624 17,119 2024 $0 $799,249 $4,606,583 2,087 42 2,045 $2,253 20,830 1,666 19,164 2025 $0 $799,249 $4,606,583 2,128 43 2,086 $2,209 22,958 1,708 21,250 2026 $0 $799,249 $4,606,583 2,171 43 2,127 $2,165 25,129 1,752 23,377 2027 $0 $799,249 $4,606,583 2,214 44 2,170 $2,123 27,343 1,796 25,547 2028 $0 $799,249 $4,606,583 2,259 45 2,213 $2,081 29,602 1,841 27,760 2029 $0 $799,249 $4,606,583 2,304 46 2,258 $2,040 31,906 1,887 30,018 2030 $0 $799,249 $4,606,583 2,350 47 2,303 $2,000 34,255 1,934 32,321 2031 $0 $799,249 $4,606,583 2,397 48 2,349 $1,961 36,652 1,982 34,670 2032 $0 $799,249 $4,606,583 2,445 49 2,396 $1,923 39,097 2,031 37,066 2033 $0 $799,249 $4,606,583 2,494 50 2,444 $1,885 41,591 2,081 39,510 2034 $0 $799,249 $4,606,583 2,544 51 2,493 $1,848 42,422 1,782 40,640 2035 $0 $799,249 $4,606,583 2,594 52 2,543 $1,812 43,271 1,477 41,794 2036 $0 $799,249 $4,606,583 2,646 53 2,593 $1,776 44,136 1,166 42,970 2037 $0 $799,249 $4,606,583 2,699 54 2,645 $1,741 45,019 1,129 43,890 2038 $0 $799,249 $4,606,583 2,753 55 2,698 $1,707 45,919 1,092 44,828 2039 $0 $799,249 $4,606,583 2,808 56 2,752 $1,674 46,838 1,054 45,784 2040 $0 $799,249 $4,606,583 2,864 57 2,807 $1,641 47,775 1,014 46,760 2041 $0 $799,249 $4,606,583 2,922 58 2,863 $1,609 48,730 975 47,756 2042 46,725 934 45,790 2043 44,679 894 43,785 2044 42,592 852 41,740 2045 40,464 809 39,655 2046 38,293 766 37,527 2047 36,079 722 35,357 2048 33,820 676 33,144 2049 31,516 630 30,886 2050 29,167 583 28,583 2051 26,770 535 26,234 2052 24,325 486 23,838 2053 21,831 437 21,395 2054 19,288 386 18,902 2055 16,693 334 16,359 2056 14,047 281 13,766 2057 11,348 227 11,121 2058 8,594 172 8,423 2059 5,786 116 5,670 2060 2,922 58 2,863

$133,590,914 532,795 $251 Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)**

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. 1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton) Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### 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) 20133 

### $1,926,169$6,158,606 $1,503,929 20144 

### $1,926,169$6,158,606 $1,503,929 1,191 298 893 $1,684 1,191 298 893 2015 $968,569 $3,096,839 $1,503,929 1,214 304 911 $1,651 2,405 601 1,804 2016 $968,569 $3,096,839 $1,503,929 1,239 310 929 $1,619 3,644 911 2,733 20174 

### $1,705,781$5,453,954 $1,503,929 1,263 63 1,200 $1,253 4,907 974 3,933 2018 $1,705,781$5,453,954 $1,503,929 1,289 64 1,224 $1,228 6,196 1,039 5,157 2019 $760,692 $2,432,187 $1,503,929 1,315 66 1,249 $1,204 7,510 1,104 6,406 2020 $760,692 $2,432,187 $1,503,929 1,341 67 1,274 $1,181 8,851 1,171 7,680 2021 $760,692 $2,432,187 $1,503,929 1,368 68 1,299 $1,158 10,219 1,240 8,979 20224 

### $760,692 $2,432,187 $1,503,929 1,395 28 1,367 $1,100 11,614 1,268 10,346 2023 $0 $235,073 $1,503,929 1,423 28 1,394 $1,079 13,037 1,296 11,741 2024 $0 $235,073 $1,503,929 1,451 29 1,422 $1,057 14,488 1,325 13,163 2025 $0 $235,073 $1,503,929 1,480 30 1,451 $1,037 15,968 1,355 14,614 2026 $0 $235,073 $1,503,929 1,510 30 1,480 $1,016 17,478 1,385 16,093 2027 $0 $235,073 $1,503,929 1,540 31 1,509 $996 19,018 1,416 17,603 2028 $0 $235,073 $1,503,929 1,571 31 1,540 $977 20,589 1,447 19,142 2029 $0 $235,073 $1,503,929 1,602 32 1,570 $958 22,192 1,479 20,712 2030 $0 $235,073 $1,503,929 1,634 33 1,602 $939 23,826 1,512 22,314 2031 $0 $235,073 $1,503,929 1,667 33 1,634 $921 25,493 1,545 23,948 2032 $0 $235,073 $1,503,929 1,700 34 1,666 $902 27,194 1,579 25,614 2033 $0 $235,073 $1,503,929 1,734 35 1,700 $885 28,928 1,614 27,314 2034 $0 $235,073 $1,503,929 1,769 35 1,734 $867 29,507 1,352 28,155 2035 $0 $235,073 $1,503,929 1,805 36 1,768 $850 30,097 1,084 29,013 2036 $0 $235,073 $1,503,929 1,841 37 1,804 $834 30,699 811 29,887 2037 $0 $235,073 $1,503,929 1,877 38 1,840 $817 31,313 786 30,527 2038 $0 $235,073 $1,503,929 1,915 38 1,877 $801 31,939 759 31,179 2039 $0 $235,073 $1,503,929 1,953 39 1,914 $786 32,578 733 31,845 2040 $0 $235,073 $1,503,929 1,992 40 1,952 $770 33,229 706 32,524 2041 $0 $235,073 $1,503,929 2,032 41 1,992 $755 33,894 678 33,216 2042 32,499 650 31,849 2043 31,076 622 30,454 2044 29,625 592 29,032 2045 28,144 563 27,581 2046 26,634 533 26,102 2047 25,094 502 24,592 2048 23,523 470 23,053 2049 21,921 438 21,483 2050 20,287 406 19,881 2051 18,619 372 18,247 2052 16,919 338 16,581 2053 15,185 304 14,881 2054 13,415 268 13,147 2055 11,611 232 11,379 2056 9,770 195 9,575 2057 7,893 158 7,735 2058 5,978 120 5,858 2059 4,025 80 3,944 2060 2,032 41 1,992

$43,613,939 370,581 $118

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Forced Air Furnaces**

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### 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) 20133 

### $2,324,566$7,432,415 $3,102,654 20144 

### $2,324,566$7,432,415 $3,102,654 521 52 469 $6,615 521 52 469 2015 $2,324,566$7,432,415 $3,102,654 532 53 478 $6,485 1,053 105 947 2016 $2,324,566$7,432,415 $3,102,654 542 54 488 $6,358 1,595 159 1,435 20174 

### $4,093,875$13,089,489$3,102,654 553 28 525 $5,905 2,148 187 1,961 2018 $4,093,875$13,089,489$3,102,654 564 28 536 $5,790 2,712 215 2,497 2019 $1,825,661$5,837,250 $3,102,654 575 29 547 $5,676 3,287 244 3,043 2020 $1,825,661$5,837,250 $3,102,654 587 29 558 $5,565 3,874 273 3,601 2021 $1,825,661$5,837,250 $3,102,654 599 30 569 $5,456 4,473 303 4,170 20224 

### $1,825,661$5,837,250 $3,102,654 611 12 598 $5,185 5,084 316 4,768 2023 $0 $564,176 $3,102,654 623 12 610 $5,083 5,706 328 5,378 2024 $0 $564,176 $3,102,654 635 13 623 $4,984 6,342 341 6,001 2025 $0 $564,176 $3,102,654 648 13 635 $4,886 6,990 354 6,636 2026 $0 $564,176 $3,102,654 661 13 648 $4,790 7,651 367 7,284 2027 $0 $564,176 $3,102,654 674 13 661 $4,696 8,325 380 7,944 2028 $0 $564,176 $3,102,654 688 14 674 $4,604 9,013 394 8,618 2029 $0 $564,176 $3,102,654 701 14 687 $4,514 9,714 408 9,306 2030 $0 $564,176 $3,102,654 715 14 701 $4,425 10,429 423 10,007 2031 $0 $564,176 $3,102,654 730 15 715 $4,339 11,159 437 10,722 2032 $0 $564,176 $3,102,654 744 15 729 $4,253 11,903 452 11,451 2033 $0 $564,176 $3,102,654 759 15 744 $4,170 12,663 467 12,195 2034 $0 $564,176 $3,102,654 774 15 759 $4,088 12,916 431 12,485 2035 $0 $564,176 $3,102,654 790 16 774 $4,008 13,174 393 12,781 2036 $0 $564,176 $3,102,654 806 16 790 $3,930 13,438 355 13,083 2037 $0 $564,176 $3,102,654 822 16 805 $3,852 13,706 344 13,363 2038 $0 $564,176 $3,102,654 838 17 821 $3,777 13,981 332 13,648 2039 $0 $564,176 $3,102,654 855 17 838 $3,703 14,260 321 13,939 2040 $0 $564,176 $3,102,654 872 17 855 $3,630 14,545 309 14,237 2041 $0 $564,176 $3,102,654 890 18 872 $3,559 14,836 297 14,540 2042 14,226 285 13,941 2043 13,603 272 13,331 2044 12,968 259 12,708 2045 12,320 246 12,073 2046 11,659 233 11,425 2047 10,984 220 10,765 2048 10,297 206 10,091 2049 9,595 192 9,404 2050 8,880 178 8,702 2051 8,150 163 7,987 2052 7,406 148 7,258 2053 6,647 133 6,514 2054 5,872 117 5,755 2055 5,082 102 4,981 2056 4,277 86 4,191 2057 3,455 69 3,386 2058 2,617 52 2,564 2059 1,762 35 1,726 2060 890 18 872

$89,976,975 162,214 $555

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Hydronic Heating Systems**

1

### Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
3

### 2013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Year Annual

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $9,064,348$28,981,753$10,222,566 20144 $9,064,348$28,981,753$10,222,566 3,924 1,410 2,514 $4,066 3,924 1,410 2,514 2015 $7,723,708$24,695,280$10,222,566 4,002 1,438 2,564 $3,987 7,926 2,848 5,078 2016 $7,723,708$24,695,280$10,222,566 4,082 1,467 2,616 $3,908 12,008 4,315 7,694 20174$13,566,115$43,375,410$10,222,566 4,164 831 3,333 $3,067 16,172 5,146 11,027 2018 $13,566,115$43,375,410$10,222,566 4,247 848 3,400 $3,007 20,419 5,993 14,426 2019 $6,033,123$19,289,913$10,222,566 4,332 864 3,468 $2,948 24,752 6,857 17,894 2020 $6,033,123$19,289,913$10,222,566 4,419 882 3,537 $2,890 29,170 7,739 21,431 2021 $6,033,123$19,289,913$10,222,566 4,507 899 3,608 $2,833 33,678 8,639 25,039 20224 $6,033,123$19,289,913$10,222,566 4,597 465 4,132 $2,474 38,275 9,104 29,171 2023 $0 $1,325,783$10,222,566 4,689 474 4,215 $2,425 42,964 9,578 33,386 2024 $0 $1,325,783$10,222,566 4,783 484 4,299 $2,378 47,747 10,062 37,686 2025 $0 $1,325,783$10,222,566 4,879 493 4,385 $2,331 52,626 10,555 42,071 2026 $0 $1,325,783$10,222,566 4,976 503 4,473 $2,285 57,602 11,058 46,544 2027 $0 $1,325,783$10,222,566 5,076 513 4,562 $2,241 62,678 11,572 51,106 2028 $0 $1,325,783$10,222,566 5,177 524 4,654 $2,197 67,855 12,096 55,760 2029 $0 $1,325,783$10,222,566 5,281 534 4,747 $2,154 73,136 12,630 60,507 2030 $0 $1,325,783$10,222,566 5,387 545 4,842 $2,111 78,523 13,174 65,348 2031 $0 $1,325,783$10,222,566 5,494 556 4,939 $2,070 84,017 13,730 70,287 2032 $0 $1,325,783$10,222,566 5,604 567 5,037 $2,029 89,621 14,297 75,324 2033 $0 $1,325,783$10,222,566 5,716 578 5,138 $1,990 95,337 14,875 80,462 2034 $0 $1,325,783$10,222,566 5,831 590 5,241 $1,951 97,244 14,055 83,189 2035 $0 $1,325,783$10,222,566 5,947 602 5,346 $1,912 99,189 13,219 85,970 2036 $0 $1,325,783$10,222,566 6,066 614 5,453 $1,875 101,173 12,365 88,807 2037 $0 $1,325,783$10,222,566 6,187 626 5,562 $1,838 103,196 12,160 91,036 2038 $0 $1,325,783$10,222,566 6,311 638 5,673 $1,802 105,260 11,951 93,309 2039 $0 $1,325,783$10,222,566 6,437 651 5,786 $1,767 107,365 11,738 95,628 2040 $0 $1,325,783$10,222,566 6,566 664 5,902 $1,732 109,513 11,520 97,992 2041 $0 $1,325,783$10,222,566 6,697 677 6,020 $1,698 111,703 11,298 100,405 2042 107,106 10,833 96,272 2043 102,416 10,359 92,057 2044 97,633 9,875 87,758 2045 92,755 9,382 83,373 2046 87,778 8,878 78,900 2047 82,702 8,365 74,337 2048 77,525 7,841 69,684 2049 72,244 7,307 64,937 2050 66,858 6,762 60,095 2051 61,364 6,207 55,157 2052 55,759 5,640 50,120 2053 50,043 5,062 44,982 2054 44,213 4,472 39,741 2055 38,266 3,870 34,395 2056 32,199 3,257 28,943 2057 26,012 2,631 23,381 2058 19,701 1,993 17,708 2059 13,264 1,342 11,922 2060 6,697 677 6,020

$296,454,422 1,120,187 $265

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. No emission reductions are estimated for woodstoves and pellet stoves until 2017, although emission reductions are estimated for all other devices starting in 2014. **DRAFT 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 stove lifespan (per ton) Emission Reduction, cumulative per year

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