Residential Biomass Combustion NSPS: 

Cost Impact Analysis Approach 

July 26, 2010
Example Wood Stove NSPS Timeline

2

6/11 Propose

Estimated 111,300 to 

be shipped

85% of units = WA std

Up to 15% of 

units/models begin 

retooling

7/12 Final

Manufactured units 

must meet WA std

85% of units = 2012 

std—no impact

X1% of models revised 

to = 2012 std, X2% 

cont. retooling

Y% of models 

discontinued, Z% of 

companies stop 

producing

1/13

Last date to sell 1988 

NPSP units

X3% of models 

retooling to meet 

2014 std

7/14

All manufactured 

models/units meet 

2014 std

Y1% of models 

discontinued, Z2% of 

companies stop 

producing

7/15

Last date to sell 2012 

units

7/16 – 7/17

5

th year impact in 7/17
Overall Cost Model

• Use model unit approach (low, average and high cost 

units) to determine impacts on different price points

• Determine cost to manufacturer/model to develop 

and certify new model line x number of models 

certified

• Determine cost to manufacturer/unit to make a 

certified unit x number of units made

• Determine cost to consumer to buy a new certified 

unit

3
Freestanding Wood Heater Cost Model

• Identify the number of companies and the associated 

models that would have to make changes to meet 

the 2012/2014 standards

• Develop model lines to use in the cost model

• Estimate costs to certify model lines

• Estimate costs of new models/units

• Determine cost of revised NSPS (cost to develop, 

produce, and certify new units) relative to existing 

NSPS.

4
Freestanding Wood Heater Cost 

Model: Cost Inputs

• Number of companies that have models that do not 

meet standards in 2012/2014 and number of models 

affected

• Number of models/company and number of 

stoves/model

• Percentage of companies/models that will 

redesign/retool

– Factors that would influence decision to drop a model line

– Time needed to make emissions reductions changes vs. other model line 

changes

• Cost to redesign/retool to meet new emission 

limit(s)/model

– Likely technologies/approaches

5
Freestanding Wood Heater Cost 

Model: Cost Inputs (cont.)

• Costs to test stoves (NSPS vs. safety)/model

• Production cost vs. wholesale cost vs. retail 

cost/stove

• Cost increases anticipated to produce stove to meet 

the new emission limit(s)/stove

• Any changes in warranty costs/durability anticipated

6
Freestanding Wood Heater Cost 

Model: Cost Inputs (cont.)

• Likelihood and amount of price increase to 

retailer/consumer

• Changes in installation costs

• Changes in operating costs

– More efficient heating (less wood burned)?

– Maintenance costs (replacement parts)

7
Fireplace Insert Cost Model

• Same general approach to cost impacts as wood 

stoves

• Distinguish between pellet (wood and other 

biomass) and cordwood units

• Identify differences in technology/construction that 

might lead to different magnitude of cost impacts

8
Pellet Stove Cost Model

• Same general approach to wood stoves

• Identify models that are not certified but would 

meet 2012/2014 emission limits

• Identify models that could not meet emission limits 

and estimate percentage that would stop 

production/shut down

• Determine if costs impacts differ for wood pellets vs. 

other pellet types

9
Hydronic Heater Cost Model

• Similar approach to wood stoves

• Consider impact of voluntary program and existing 

state regulations to determine number of models 

affected

• Review costs to develop hydronic heaters that satisfy 

the voluntary program criteria 

• Include cost of heat storage?

• Collect information on European units that would 

meet standard

10
Fireplace Cost Model

• Similar approach to wood stoves for factory built units

• Distinguish between low-mass fireplaces and masonry 

fireplaces

• Consider impact of voluntary program and existing state

regulations to determine number of models affected

• Review costs to develop fireplaces that satisfy the voluntary 

program criteria 

• Additional impacts on installers (masons)

• Consider impact on cost and performance of consumer addons (grates, catalyst retrofit)?

11
Coal Stove/Cook Stove Cost Model

• Limited data collected on size of market, number of 

models, costs

• Initiate data gathering

• Anticipate that if an acceptable definition of a true 

cook stove is implemented, the only impacted units 

would be those room heaters claiming to also be 

cook stoves and thus exempt from the NSPS

12
Masonry Heater Cost Model

• Less than 1,000 units sold per year

• Consider impact of design standard vs. certification

13
Boilers and Forced Air Furnace Cost 

Model

• Virtually no data collected on size of market, number 

of models, costs

• Initiate data gathering

14
Other Cost Impacts

• Costs to manufacturers to implement an ISO 

certification process

• Costs to labs to become ISO certified

• Costs to pellet fuel manufacturers to implement 

pellet fuel standards if not implemented 

independently of NSPS

15