Notes Notes



### Wood stove 7.5 to 4.5 High Low median 2013 dollars High Low median 2013 dollars **Capital Costs Capital Costs**  **R&D/Engineering costs R&D/Engineering costs**  Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 45,500 19,000 32,250 Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 91,000 38,000 64,500
adjust design/test until emission target is met 47,500 30,000 38,750 adjust design/test until emission target is met 95,000 60,000 77,500
construct final prototypes, safety test check. Eng. Drawings/specs, patent application 27,000 17,000 22,000 construct final prototypes, safety test check. Eng. Drawings/specs, patent application 54,000 34,000 44,000 confirm final prototype performance 0 0 0 confirm final prototype performance 0 0 0 **R&D/Engineering Total costs 120,000**  **66,000 93,000**  **R&D/Engineering Total costs 240,000**  **132,000 186,000** 
**Tooling Tooling**  Steel Stove 31,200 9,700 20,450 Steel Stove 31,200 9,700 20,450 Cast Iron Stove 62,000 31,000 46,500 Cast Iron Stove 62,000 31,000 46,500 **Average tooling cost 46,600**  **20,350 33,475**  **Average tooling cost 46,600**  **20,350 33,475** 

**Other Capital Cost components 14,000**  **6,000 10,000** HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above **Other Capital Cost components 14,000**  **6,000 10,000** HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above
**Total Capital Cost per model 180,600**  **92,350 136,475**  **Total Capital Cost per model 300,600**  **158,350 229,475** 
**Fixed Costs per model Fixed Costs per model**  **Certification Certification** 

EPA testing, Confirmation safety testing or full safety testing, shipping of prototype 19,000 14,500 16,750HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs EPA testing, Confirmation safety testing or full safety testing, shipping of prototype 19,000 14,500 16,750HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs Owner's manual, labeling 3,500 1,800 2,650 Owner's manual, labeling 3,500 1,800 2,650

**Roll-out 0**  **0 0** roll-out considered normal business operation and not due to NSPS **Roll-out 0**  **0 0** roll-out considered normal business operation and not due to NSPS
**Total Fixed Capital Cost per model 22,500**  **16,300 19,400**  **Total Fixed Capital Cost per model 22,500**  **16,300 19,400** 
**Total Costs per Model 203,100**  **108,650 155,875**  **Total Costs per Model 323,100**  **174,650 248,875** 

**Annualized capital cost per model** 42,610 22,794 32,702annualized over 6 years at 7% interest (note: NERA annualized over 10 years) **Annualized capital cost per model** 67,785 36,641 52,213annualized over 6 years at 7% interest (note: NERA annualized over 10 years) **Annual cost for development of 4 models** 170,438 91,177 130,808 **Annual cost for development of 4 models** 271,140 146,563 208,852 **Adjustable Burn Rate Stoves, Pellet Stoves & Single Burn Rate** 

**Stoves Single Burn Rate Stoves, first 2**  **years (doubled R&D / Engineering Costs)** 

# Hydronic Heater Uncontrolled to 0.32 High Low median

**Capital Costs R&D/Engineering costs** 

Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 180,000 115,000 147,500 Formulate design changes 4,500 2,500 3,500 Modify prototype 16,000 9,000 12,500 Test/Retest 615,000 410,000 512,500
Construct final prototype, confirm testing, safety testing 133,500 88,500 111,000 Document final changes 8,000 6,000 7,000

**R&D/Engineering total costs 957,000**  **631,000 794,000** 
**Manuracturing/Manufacturing Engineering** Programming and Tooling - Steel parts 22,000 13,000 17,500 Tooling - Refractory 45,000 28,000 36,500 Electronic Control System 10,000 5,000 7,500 Final Production samples/Confirm product. Fitup 25,000 15,000 20,000 Create QA/QC specs 4,000 2,000 3,000 **Manuracturing/Manufacturing Engineering total costs 106,000**  **63,000 84,500** 
**Other Capital Cost components** Purchased parts sourcing 41,000 23,500 32,250 Test first production heaters 200,000 150,000 175,000

Equipment and facilities 75,000 25,000 50,000 **Other Capital Cost components total costs 316,000**  **198,500 257,250** 
**Total Capital Cost per model 1,379,000**  **892,500 1,135,750** 
**Fixed Costs per model Certification**  **Hydronic Heaters & Forced-Air Furnaces** 

# EPA testing, Confirmation safety testing or full safety testing,

shipping of prototype 72,500 36,000 54,250 Owner's manual, labeling 6,500 3,500 5,000 **Certification Total Costs** 79,000 39,500 59,250

**Roll-out 0**  **0 0** 
**Total Fixed Capital Cost per model 79,000**  **39,500 59,250** 
**Total Costs per Model 1,458,000**  **932,000 1,195,000** 

**Annualized capital cost per model 305,882**  **195,530 250,706**  **Annual cost for development of 4 models 1,223,529**  **782,119 1,002,824** 

# Notes

2013 dollars High **Capital Costs R&D/Engineering costs** 

Market research, aesthetic design, initial prototype design/construction/testing, formulate design changes, modify/test prototype 360,000 Formulate design changes 9,000 Modify prototype 32,000 Test/Retest 1,230,000 Construct final prototype, confirm testing, safety testing 267,000 Document final changes 16,000
App. A (NERA) concludes erroneously $887,000 for high cost and $581,000 for low cost. **R&D/Engineering total costs 1,914,000** 
**Manuracturing/Manufacturing Engineering** Programming and Tooling - Steel parts 22,000 Tooling - Refractory 45,000 Electronic Control System 10,000 Final Production samples/Confirm product. Fitup 25,000 Create QA/QC specs 4,000 **Manuracturing/Manufacturing Engineering total costs 106,000** 
**Other Capital Cost components** Purchased parts sourcing 41,000 Test first production heaters 200,000
HPBA costs for equipment and integration not included because these are considered duplicative of R&D costs, above Equipment and facilities 75,000 **Other Capital Cost components total costs 316,000** 
**Total Capital Cost per model 2,336,000** 
**Fixed Costs per model Certification**  **Forced air furnaces, First 2 years (doubled R&D / Engineering** 

# HBPA costs for personal at lab and

travel expenses not accepted as independent third party testing costs EPA testing, Confirmation safety testing or full safety testing, shipping of prototype 72,500 Owner's manual, labeling 6,500 **Certification Total Costs** 79,000

roll-out considered normal business operation and not due to NSPS **Roll-out 0** 
**Total Fixed Capital Cost per model 79,000** 
**Total Costs per Model 2,415,000** 
annualized over 6 years at 7% interest (note: NERA annualized over 10 years)**Annualized capital cost per model 506,657**  **Annual cost for development of 4 models 2,026,627** 

# Notes

Low median 2013 dollars

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

177,000 222,000 12,000 14,000

**1,262,000 1,588,000** App. A (NERA) concludes

erroneously $887,000 for high cost and $581,000 for low cost.

13,000 17,500 28,000 36,500 5,000 7,500 15,000 20,000 2,000 3,000 **63,000 84,500** 

23,500 32,250 150,000 175,000

25,000 50,000HPBA costs for equipment and

integration not included because these are considered duplicative of R&D costs, above **198,500 257,250** 

**1,523,500 1,929,750**  **Forced air furnaces, First 2 years (doubled R&D / Engineering** 

**costs)**

# 36,000 54,250HBPA costs for personal at lab and travel expenses not accepted as independent third party testing costs 3,500 5,000 39,500 59,250

**0 0** roll-out considered normal

business operation and not due to NSPS

**39,500 59,250** 

**1,563,000 1,989,000** 

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

interest (note: NERA annualized over 10 years) **1,311,643 1,669,135** **Table 9. Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2015-2020) and through model lifespan (2020-2029)**

(Step 1 compliance) 2015 2016 2017 2018 2019 (Step 2 compliance) 2020 2021 through

20292 (Step 1

compliance) 2015 2016 2017 2018 2019 (Step 2 compliance) 2020 2021 through

20292 Wood Stoves (R&D)3 34 125 $88,968 $88,968 $88,968 $88,968 $88,968 $88,968 $0 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $3,024,928 $0 Pellet Stoves (R&D, R&R, cert)4,7 29 125 $51,179 $51,179 $51,179 $53,941 $53,941 $53,941 $14,240 $1,484,192 $1,484,192 $1,484,192 $1,564,285 $1,564,285 $1,564,285 $412,963 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 7 3 20 $352,506 $352,506 $352,506 $226,704 $226,704 $226,704 $22,025 $1,057,518 $1,057,518 $1,057,518 $680,112 $680,112 $680,112 $66,074 $5,566,638 $5,566,638 $5,566,638 $5,269,325 $5,269,325 $5,269,325 $479,037 Forced Air Furnaces (R&D, R&R, cert.)5, 6, 7 7 50 $2,986,523 $2,986,523 $1,796,681 $1,799,034 $1,799,034 $1,799,034 $36,849 $20,905,663 $20,905,663 $12,576,770 $12,593,240 $12,593,240 $12,593,240 $257,941 Hydronic Heaters (R&D, R&R, cert.)7,8 30 120 $828,513 $828,513 $828,513 $829,831 $829,831 $829,831 $20,635 $24,855,398 $24,855,398 $24,855,398 $24,894,927 $24,894,927 $24,894,927 $619,059 $45,761,061 $45,761,061 $37,432,168 $37,488,168 $37,488,168 $37,488,168 $877,000

Period Nationwide Cost of the Rule
$51,327,699 $51,327,699 $42,998,805 $42,757,493 $42,757,493 $42,757,493 $1,356,037 R&D year average (2015- 2020) $45,654,447 Post R&D year average

(2021-2029) $1,356,037

Subpart: Years Annual $

AAA: 2015-2017 Laboratories $55,000 Third-Party Certifiers $16,000

AAA: 2018-2020 Laboratories $73,000 Third-Party Certifiers $9,000
QQQQ: 2015-2017 Laboratories $36,000 Third-Party Certifiers $15,000
QQQQ: 2018-2020 Laboratories $49,000 Third-Party Certifiers $5,000 * Reporting and Recordkeeping (R&R) costs for laboratories and certifying entities are not included in this cost analysis but are estimated as follows: 1Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2015 through 2020). Ongoing certification and reporting & recordkeeping costs are incurred through 2029 (based on a model brought to market in 2020 with a lifespan of 10 years). Annual Cost of the Rule

6For single burn rate stoves and forced air furnaces, the analysis assumes that only a small percentage meet Step 2 so that approximately 100% of the models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. 5Based on conversations with industry (e.g., 2/8/13), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2014 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters (respectively) this analysis assumes that these efforts will intensify in 2015 and 2016. Therefore estimated R&D costs are doubled in 2015 and 2016 to reflect model development to meet the more stringent 2020 Step 2 standard. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. 4For pellet stoves, the analysis assumes that 70% meet Step 2 already so that 30% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 70% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2015. The analysis reflects the certification costs beginning in 2015 for the 70% of models meeting Step 2, and beginning in 2020 for the remaining 30% of models which underwent R&D re-design. The analysis also reflects ongoing reporting & recordkeeping costs for 100% of the models beginning in 2015. 3This analysis considers additional costs resulting from the NSPS. For wood stoves, the analysis assumes that 26% meet Step 2 already so that 74% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2021 through 2029 exclude the ongoing certification and reporting & recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing 1988 NSPS. 2Since certification is required every 5 years , it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

7Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are estimates of the ongoing R&R burden to manufacturers associated with the NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is approximately$179,000for years 2015 through 2017 and$352,000for years 2018 through 2020. For Subpart QQQQ, the R&R burden to manufacturers is estimated to be $141,000 for years 2015 through 2017 and $197,00 for years 2018 through 2020. Although the 2018 through 2020 costs are carried forward to 2029 for this analysis, actual R&R costs from 2021 through 2029 may vary slightly. These R&R costs do not include the R&R burden to laboratories and certifying entities, which are calculated separately and provided below.*

8For hydronic heaters, the analysis assumes that 18% of models meet Step 2 already so that 82% must undergo R&D to meet Step 2 in 2020. The R&D budget includes certification costs. Ongoing certification costs for the re-designed models are reflected in this analysis beginning in 2021. Ongoing reporting & recordkeeping for all models are estimated beginning in 2015. Average Annual Cost per Manufacturer based on 6-year R&D round (2015-2020) to meet Step 1 and Step 2 limits with ongoing certification costs (through 2029)

# Manufacturers # Models Nationwide Annual Costs1

QQQQ: Central Heaters AAA: Room Heaters NSPS Subpart Appliance Type

# SCC **Appliance Population** **Total Tons**

**Burned Emission Inventory Category**  **Pollutant Baseline**  **Emission factor**  **(lb/ton) Baseline** 

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

**Tons/appl 2015 Step** 

**1 Emission**  **Factor**

2104008220 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Primary PM2.5 8.76 5,371 0.0041 8.76

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

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

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

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

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

Wood Stoves 126,527 80,851 77,617 79,945 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


### 20154 

### $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 20204 

### $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 PM 2.5** 

### emissions from Wood Stoves

Year3 

### Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020 ). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.
2

### Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 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 over 20-year emitting lifespan Nationwide cumulative cost5

### Baseline PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

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



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $1,484,192 $857,473 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 20204 

### $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 PM 2.5** 

### emissions from Pellet Stoves

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 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. Year3 

### Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4

### Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. For pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2015 through 2019. Therefore no emission reductions are estimated until Step 2 in 2020.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespanBaseline PM2.5 Emissions2 (tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons) CE based on

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

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons) 20154 $1,057,518 $387,171 921 264 657 $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 20204 $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 PM 2.5** **emissions from Single Burn Rate Stoves**

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis.

3These heaters have in-home emitting lifespans of at least 20 years; thus single burn rate stoves shipped in 2029 will be emitting through 2048. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespanBaseline PM2.5 Emissions2(tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

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

Emissions (tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $5,566,638 $2,454,615 1,380 723 657 $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 20204 $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

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters already meeting the Step 2 limit (i.e., 26% of wood stoves and 70% of pellet stoves are estimated to already meet the Step 2 limit). CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

3These heaters have in-home emitting lifespans of at least 20 years; thus room heaters shipped in 2029 will be emitting through 2048. Cumulative Emission Reduction over 20-year emitting lifespan Emission Reduction, cumulative per year Annual Snapshots **Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)**

Nationwide cumulative cost5

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2015 through 2029. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except for an adjustment in year 2018 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis.

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020. In order to not overestimate emission reductions resulting from the rule, for woodstoves and pellet stoves, estimates assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 2015 through 2019. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2020.

### Baseline PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons) CE based on

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



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons) 20154 

### $20,905,663 $6,299,286 6,975 6,975 0 N/A 6,975 6,975 0 20164 

### $20,905,663 $6,299,286 7,184 5,837 1,347 $4,676 14,159 12,812 1,347 20174 

### $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 20204 

### $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 PM 2.5** 

### emissions from Forced Air Furnaces

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 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. Year3 

### Nationwide

Annual Cost1 

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

4

### Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.
5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year emitting lifespan

### Baseline PM2.5 

### Emissions2

### (tons) NSPS PM2.5



### Emissions2 

### (tons) Emission

Reduction (tons)6 

### CE based on

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



### Emissions(tons) NSPS PM2.5



### Emissions (tons) Emission

Reduction (tons)6


### 20154 

### $24,855,398 $10,321,500.34 3,765 376 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 20204 

### $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 20473 

### 11,224 351 10,873 20483 

### 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 PM 2.5** 

### emissions from Hydronic Heating Systems

1

### Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2

### Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 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 lifespanBaseline PM2.5 Emissions2(tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

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

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $45,761,061 $16,620,786 10,740 7,351 3,388 $4,905 10,740 7,351 3,388 20164 $45,761,061 $16,620,786 11,062 6,225 4,837 $3,436 21,802 13,576 8,226 20174 $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 20204 $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 20473 32,017 1,001 31,016 20483 16,245 508 15,737

$249,311,792 2,486,001 $100 Nationwide Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount central heaters already meeting the Step 2 limit (i.e., 18% of hydronic heaters are estimated to already meet the Step 2 limit). Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year emitting lifespan **Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)**

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. 1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except for an adjustment in year 2012 based on an industry projection (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis.

3These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048.

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020. CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton) Year3 Nationwide

Annual Cost1Baseline PM2.5 Emissions2 (tons) NSPS PM2.5

Emissions2 (tons) Emission

Reduction (tons)6 CE based on

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

Emissions(tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons)6
20154 $51,327,699 $19,075,401 12,120 8,075 4,046 $4,715 12,120 8,075 4,046 20164 $51,327,699 $19,075,401 12,484 6,970 5,514 $3,459 24,604 15,044 9,560 20174 $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 20204 $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 20473 36,152 2,107 34,045 20483 18,343 1,069 17,274

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

6In order to not overstate emission reductions caused by the NSPS, emissions are reduced to discount room heaters and central heaters already meeting the Step 2 limit (i.e., 26% of wood stoves, 70% of pellet stoves and 18% of hydronic heaters are estimated to already meet the Step 2 limit). **Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)** 
CE based on total cost & cumulative emission reduction over 20-year emitting lifespan (per ton) Emission Reduction, cumulative per year

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

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these heaters to market from 2014 through 2029. Year3 Nationwide

Annual Cost1 Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2013 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2015-2020), plus annual certification and reporting & recordkeeping costs (ongoing through 2029, representing a 10 year model life). Years2030 through 2048 are past the 10-year model design lifespan used in this analysis.

2Except for adjustments in years 2012 and 2018 based on an industry projections (NERA), estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 3% from 2015 through 2029, for the purposes of a sensitivity analysis.

3These heaters have in-home emitting lifespans of at least 20 years; thus models shipped in 2029 will be emitting through 2048.

4Estimated emissions assume Step 1 standard becomes effective in 2015 and Step 2 standard in 2020 for all appliances, except forced-air furnaces have work practice/operational standards in 2015, Step 1 emission limits for small furnaces in 2016, Step 1 emission limits for large furnaces in 2017 and Step 2 emission limits for all furnaces in 2020.