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 79,945 82,344 84,814 87,358 89,979 92,678

Single Burn Rate 

Stoves 40,000 25,560 24,538 25,274 26,032 26,813 27,617 28,446 29,299

Pellet Stoves 130,381 83,313 79,981 82,380 84,852 87,397 90,019 92,720 95,501

Furnace: indoor, 

cordwood 41,000 26,199 25,151 25,906 26,683 27,483 28,308 29,157 30,032

Hydronic Heating 

Systems 13,385 8,553 8,211 8,457 13,100 13,493 13,898 14,315 14,744

2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 563 360 345 356 366 377 389 400 412

Single Burn Rate 

Stoves 1,295 827 794 818 843 868 894 921 948

Pellet Stoves 83 53 51 52 54 56 57 59 61

Furnace: indoor, 

cordwood 9,808 6,267 6,017 6,197 6,383 6,575 6,772 6,975 7,184

Hydronic Heating 

Systems 3,520 2,250 2,160 2,224 3,446 3,549 3,655 3,765 3,878

Total 15,269 9,757 9,367 9,648 11,092 11,424 11,767 12,120 12,484

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 $1,209,971 400 400 0 N/A 400 400 0

2016 $3,024,928 $1,209,971 412 412 0 N/A 813 813 0

2017 $3,024,928 $1,209,971 425 425 0 N/A 1,238 1,238 0

2018 $3,024,928 $1,209,971 445 445 0 N/A 1,683 1,683 0

2019 $3,024,928 $1,209,971 458 458 0 N/A 2,141 2,141 0

2020 4$3,024,928 $1,209,971 472 264 208 $5,817 2,613 2,405 208

2021 $0 $1,209,971 486 272 214 $5,648 3,099 2,677 422

2022 $0 $1,209,971 501 280 221 $5,483 3,600 2,957 643

2023 $0 $1,209,971 516 289 227 $5,324 4,116 3,246 870

2024 $0 $1,209,971 531 297 234 $5,169 4,648 3,543 1,104

2025 $0 $1,209,971 547 306 241 $5,018 5,195 3,849 1,345

2026 $0 $1,209,971 564 315 248 $4,872 5,759 4,165 1,594

2027 $0 $1,209,971 581 325 256 $4,730 6,339 4,490 1,850

2028 $0 $1,209,971 598 335 263 $4,592 6,937 4,824 2,113

2029 $0 $1,209,971 616 345 271 $4,459 7,553 5,169 2,384

2030 7,553 5,169 2,384

2031 7,553 5,169 2,384

2032 7,553 5,169 2,384

2033 7,553 5,169 2,384

2034 7,553 5,169 2,384

2035 7,153 4,768 2,384

2036 6,740 4,356 2,384

2037 6,316 3,931 2,384

2038 5,871 3,486 2,384

2039 5,412 3,028 2,384

2040 4,940 2,764 2,176

2041 4,454 2,492 1,962

2042 3,953 2,211 1,742

2043 3,437 1,923 1,514

2044 2,906 1,626 1,280

2045 2,358 1,319 1,039

2046 1,795 1,004 791

2047 1,214 679 535

2048 616 345 271

$18,149,566 37,539 $483

 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 

3% 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 59 59 0 N/A 59 59 0

2016 $1,484,192 $857,473 61 61 0 N/A 120 120 0

2017 $1,484,192 $857,473 63 63 0 N/A 183 183 0

2018 $1,564,285 $857,473 65 65 0 N/A 247 247 0

2019 $1,564,285 $857,473 66 66 0 N/A 314 314 0

2020 4$1,564,285 $857,473 68 30 38 $22,543 382 344 38

2021 $412,963 $857,473 71 31 39 $21,886 453 375 77

2022 $412,963 $857,473 73 32 40 $21,249 525 408 118

2023 $412,963 $857,473 75 33 42 $20,630 600 441 159

2024 $412,963 $857,473 77 34 43 $20,029 677 475 202

2025 $412,963 $857,473 79 35 44 $19,446 756 510 246

2026 $412,963 $857,473 82 36 45 $18,879 838 547 291

2027 $412,963 $857,473 84 37 47 $18,329 922 584 338

2028 $412,963 $857,473 87 39 48 $17,795 1,009 623 386

2029 $412,963 $857,473 89 40 50 $17,277 1,098 662 436

2030 1,098 662 436

2031 1,098 662 436

2032 1,098 662 436

2033 1,098 662 436

2034 1,098 662 436

2035 1,039 603 436

2036 979 543 436

2037 916 480 436

2038 851 415 436

2039 785 349 436

2040 716 318 398

2041 646 287 359

2042 573 255 318

2043 498 222 277

2044 421 187 234

2045 342 152 190

2046 260 116 145

2047 176 78 98

2048 89 40 50

$12,862,099 6,865 $1,874

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 3% 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 $387,171 921 264 657 $589 921 264 657

2016 $1,057,518 $387,171 948 272 677 $572 1,869 535 1,334

2017 $1,057,518 $387,171 977 280 697 $555 2,846 815 2,031

2018 $680,112 $387,171 1,006 288 718 $539 3,852 1,103 2,749

2019 $680,112 $387,171 1,036 297 740 $523 4,889 1,399 3,489

2020 4$680,112 $387,171 1,067 136 932 $416 5,956 1,535 4,421

2021 $66,074 $387,171 1,099 140 960 $403 7,056 1,675 5,380

2022 $66,074 $387,171 1,132 144 988 $392 8,188 1,819 6,369

2023 $66,074 $387,171 1,166 148 1,018 $380 9,355 1,968 7,387

2024 $66,074 $387,171 1,201 153 1,049 $369 10,556 2,121 8,435

2025 $66,074 $387,171 1,237 157 1,080 $358 11,793 2,278 9,515

2026 $66,074 $387,171 1,275 162 1,112 $348 13,068 2,440 10,628

2027 $66,074 $387,171 1,313 167 1,146 $338 14,381 2,607 11,774

2028 $66,074 $387,171 1,352 172 1,180 $328 15,733 2,779 12,954

2029 $66,074 $387,171 1,393 177 1,216 $319 17,126 2,956 14,169

2030 17,126 2,956 14,169

2031 17,126 2,956 14,169

2032 17,126 2,956 14,169

2033 17,126 2,956 14,169

2034 17,126 2,956 14,169

2035 16,205 2,693 13,512

2036 15,257 2,421 12,835

2037 14,280 2,142 12,138

2038 13,274 1,854 11,420

2039 12,237 1,557 10,680

2040 11,170 1,421 9,749

2041 10,070 1,281 8,789

2042 8,938 1,137 7,801

2043 7,771 989 6,783

2044 6,570 836 5,734

2045 5,332 678 4,654

2046 4,058 516 3,542

2047 2,745 349 2,396

2048 1,393 177 1,216

$5,807,558 196,264 $30

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 3% 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 1,380 723 657 $3,735 1,380 723 657

2016 $5,566,638 $2,454,615 1,422 745 677 $3,626 2,802 1,468 1,334

2017 $5,566,638 $2,454,615 1,464 767 697 $3,521 4,266 2,235 2,031

2018 $5,269,325 $2,454,615 1,516 798 718 $3,418 5,782 3,033 2,749

2019 $5,269,325 $2,454,615 1,561 822 740 $3,318 7,343 3,854 3,489

2020 4$5,269,325 $2,454,615 1,608 430 1,178 $2,084 8,951 4,284 4,667

2021 $479,037 $2,454,615 1,656 443 1,213 $2,024 10,608 4,728 5,880

2022 $479,037 $2,454,615 1,706 457 1,249 $1,965 12,314 5,184 7,129

2023 $479,037 $2,454,615 1,757 470 1,287 $1,907 14,071 5,655 8,416

2024 $479,037 $2,454,615 1,810 484 1,325 $1,852 15,881 6,139 9,742

2025 $479,037 $2,454,615 1,864 499 1,365 $1,798 17,745 6,638 11,107

2026 $479,037 $2,454,615 1,920 514 1,406 $1,746 19,665 7,152 12,513

2027 $479,037 $2,454,615 1,978 529 1,448 $1,695 21,643 7,681 13,961

2028 $479,037 $2,454,615 2,037 545 1,492 $1,645 23,680 8,226 15,453

2029 $479,037 $2,454,615 2,098 562 1,537 $1,597 25,778 8,788 16,990

2030 25,778 8,788 16,990

2031 25,778 8,788 16,990

2032 25,778 8,788 16,990

2033 25,778 8,788 16,990

2034 25,778 8,788 16,990

2035 24,397 8,065 16,333

2036 22,976 7,320 15,656

2037 21,511 6,553 14,959

2038 19,996 5,755 14,240

2039 18,434 4,934 13,501

2040 16,826 4,503 12,323

2041 15,170 4,060 11,110

2042 13,464 3,603 9,861

2043 11,707 3,133 8,574

2044 9,897 2,649 7,248

2045 8,033 2,150 5,883

2046 6,113 1,636 4,477

2047 4,135 1,107 3,028

2048 2,098 562 1,537

$36,819,222 240,668 $153

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 

3% 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 6,975 6,975 0 N/A 6,975 6,975 0

2016 4$20,905,663 $6,299,286 7,184 5,837 1,347 $4,676 14,159 12,812 1,347

2017 4$12,576,770 $6,299,286 7,400 1,850 5,550 $1,135 21,559 14,662 6,897

2018 $12,593,240 $6,299,286 7,622 1,905 5,716 $1,102 29,180 16,567 12,613

2019 $12,593,240 $6,299,286 7,850 1,963 5,888 $1,070 37,031 18,530 18,501

2020 4$12,593,240 $6,299,286 8,086 253 7,833 $804 45,117 18,783 26,334

2021 $257,941 $6,299,286 8,328 260 8,068 $781 53,445 19,043 34,402

2022 $257,941 $6,299,286 8,578 268 8,310 $758 62,023 19,311 42,712

2023 $257,941 $6,299,286 8,836 276 8,560 $736 70,859 19,587 51,272

2024 $257,941 $6,299,286 9,101 284 8,816 $715 79,960 19,872 60,088

2025 $257,941 $6,299,286 9,374 293 9,081 $694 89,333 20,164 69,169

2026 $257,941 $6,299,286 9,655 302 9,353 $673 98,988 20,466 78,522

2027 $257,941 $6,299,286 9,945 311 9,634 $654 108,933 20,777 88,156

2028 $257,941 $6,299,286 10,243 320 9,923 $635 119,176 21,097 98,079

2029 $257,941 $6,299,286 10,550 330 10,221 $616 129,726 21,427 108,299

2030 129,726 21,427 108,299

2031 129,726 21,427 108,299

2032 129,726 21,427 108,299

2033 129,726 21,427 108,299

2034 129,726 21,427 108,299

2035 122,751 14,452 108,299

2036 115,567 8,615 106,952

2037 108,167 6,765 101,402

2038 100,546 4,859 95,686

2039 92,695 2,897 89,798

2040 84,609 2,644 81,965

2041 76,281 2,384 73,897

2042 67,703 2,116 65,587

2043 58,867 1,840 57,027

2044 49,766 1,555 48,211

2045 40,393 1,262 39,130

2046 30,738 961 29,777

2047 20,793 650 20,143

2048 10,550 330 10,221

$94,489,287 1,577,893 $60

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 3% 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 3,765 376 3,388 $3,046 3,765 376 3,388

2016 $24,855,398 $10,321,500.34 3,878 388 3,490 $2,957 7,643 764 6,879

2017 $24,855,398 $10,321,500.34 3,994 399 3,595 $2,871 11,637 1,164 10,474

2018 $24,894,927 $10,321,500.34 4,114 411 3,703 $2,788 15,751 1,575 14,176

2019 $24,894,927 $10,321,500.34 4,238 424 3,814 $2,706 19,989 1,999 17,990

2020 4$24,894,927 $10,321,500.34 4,365 136 4,228 $2,441 24,354 2,135 22,218

2021 $619,059 $10,321,500.34 4,496 140 4,355 $2,370 28,849 2,276 26,573

2022 $619,059 $10,321,500.34 4,630 145 4,486 $2,301 33,480 2,420 31,059

2023 $619,059 $10,321,500.34 4,769 149 4,620 $2,234 38,249 2,570 35,679

2024 $619,059 $10,321,500.34 4,912 154 4,759 $2,169 43,161 2,723 40,438

2025 $619,059 $10,321,500.34 5,060 158 4,902 $2,106 48,221 2,881 45,340

2026 $619,059 $10,321,500.34 5,212 163 5,049 $2,044 53,433 3,044 50,389

2027 $619,059 $10,321,500.34 5,368 168 5,200 $1,985 58,801 3,212 55,589

2028 $619,059 $10,321,500.34 5,529 173 5,356 $1,927 64,330 3,385 60,945

2029 $619,059 $10,321,500.34 5,695 178 5,517 $1,871 70,025 3,563 66,462

2030 70,025 3,563 66,462

2031 70,025 3,563 66,462

2032 70,025 3,563 66,462

2033 70,025 3,563 66,462

2034 70,025 3,563 66,462

2035 66,260 3,186 63,074

2036 62,382 2,798 59,584

2037 58,388 2,399 55,989

2038 54,273 1,987 52,286

2039 50,036 1,564 48,472

2040 45,671 1,427 44,244

2041 41,176 1,287 39,889

2042 36,545 1,142 35,403

2043 31,776 993 30,783

2044 26,863 839 26,024

2045 21,804 681 21,122

2046 16,592 518 16,073

2047 3

11,224 351 10,873

2048 3

5,695 178 5,517

$154,822,505 908,107 $170

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 

3% 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 10,740 7,351 3,388 $4,905 10,740 7,351 3,388

2016 4$45,761,061 $16,620,786 11,062 6,225 4,837 $3,436 21,802 13,576 8,226

2017 4$37,432,168 $16,620,786 11,394 2,249 9,145 $1,818 33,196 15,826 17,370

2018 $37,488,168 $16,620,786 11,736 2,317 9,419 $1,765 44,932 18,143 26,789

2019 $37,488,168 $16,620,786 12,088 2,386 9,702 $1,713 57,020 20,529 36,491

2020 4$37,488,168 $16,620,786 12,451 389 12,061 $1,378 69,470 20,918 48,552

2021 $877,000 $16,620,786 12,824 401 12,423 $1,338 82,294 21,319 60,976

2022 $877,000 $16,620,786 13,209 413 12,796 $1,299 95,503 21,731 73,771

2023 $877,000 $16,620,786 13,605 425 13,180 $1,261 109,108 22,157 86,951

2024 $877,000 $16,620,786 14,013 438 13,575 $1,224 123,121 22,595 100,527

2025 $877,000 $16,620,786 14,434 451 13,983 $1,189 137,555 23,046 114,509

2026 $877,000 $16,620,786 14,867 465 14,402 $1,154 152,421 23,510 128,911

2027 $877,000 $16,620,786 15,313 479 14,834 $1,120 167,734 23,989 143,745

2028 $877,000 $16,620,786 15,772 493 15,279 $1,088 183,506 24,482 159,024

2029 $877,000 $16,620,786 16,245 508 15,737 $1,056 199,751 24,989 174,762

2030 199,751 24,989 174,762

2031 199,751 24,989 174,762

2032 199,751 24,989 174,762

2033 199,751 24,989 174,762

2034 199,751 24,989 174,762

2035 189,011 17,638 171,373

2036 177,949 11,413 166,536

2037 166,555 9,164 157,391

2038 154,819 6,847 147,972

2039 142,731 4,460 138,271

2040 130,281 4,071 126,209

2041 117,457 3,671 113,786

2042 104,248 3,258 100,990

2043 90,643 2,833 87,810

2044 76,630 2,395 74,235

2045 62,196 1,944 60,253

2046 47,330 1,479 45,851

2047 3

32,017 1,001 31,016

2048 3

16,245 508 15,737

$249,311,792 2,486,001 $100

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 

3% 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 12,120 8,075 4,046 $4,715 12,120 8,075 4,046

2016 4$51,327,699 $19,075,401 12,484 6,970 5,514 $3,459 24,604 15,044 9,560

2017 4$42,998,805 $19,075,401 12,858 3,016 9,842 $1,938 37,462 18,061 19,402

2018 $42,757,493 $19,075,401 13,252 3,114 10,137 $1,882 50,714 21,175 29,539

2019 $42,757,493 $19,075,401 13,649 3,208 10,441 $1,827 64,363 24,383 39,980

2020 4$42,757,493 $19,075,401 14,059 819 13,239 $1,441 78,421 25,202 53,219

2021 $1,356,037 $19,075,401 14,480 844 13,636 $1,399 92,902 26,046 66,855

2022 $1,356,037 $19,075,401 14,915 869 14,045 $1,358 107,817 26,916 80,901

2023 $1,356,037 $19,075,401 15,362 895 14,467 $1,319 123,179 27,811 95,367

2024 $1,356,037 $19,075,401 15,823 922 14,901 $1,280 139,002 28,734 110,268

2025 $1,356,037 $19,075,401 16,298 950 15,348 $1,243 155,299 29,683 125,616

2026 $1,356,037 $19,075,401 16,787 978 15,808 $1,207 172,086 30,662 141,424

2027 $1,356,037 $19,075,401 17,290 1,008 16,282 $1,172 189,376 31,670 157,707

2028 $1,356,037 $19,075,401 17,809 1,038 16,771 $1,137 207,185 32,708 174,477

2029 $1,356,037 $19,075,401 18,343 1,069 17,274 $1,104 225,529 33,777 191,751

2030 225,529 33,777 191,751

2031 225,529 33,777 191,751

2032 225,529 33,777 191,751

2033 225,529 33,777 191,751

2034 225,529 33,777 191,751

2035 213,408 25,703 187,706

2036 200,925 18,733 182,192

2037 188,066 15,716 172,350

2038 174,815 12,602 162,213

2039 161,166 9,394 151,772

2040 147,107 8,575 138,532

2041 132,627 7,731 124,896

2042 117,712 6,861 110,851

2043 102,350 5,966 96,384

2044 86,527 5,043 81,483

2045 70,229 4,094 66,136

2046 53,442 3,115 50,327

2047 3 36,152 2,107 34,045

2048 318,343 1,069 17,274

$286,131,014 2,726,669 $105

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 3% 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.