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

DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation

R&D Annual Cost Summary

Development of 4 Model Fireboxes

Round One 

6-year R&D 

Period

Direct Annual Costs (DAC)

Operator labor $141,667

Outside Consultants $26,667

Total Direct Costs (DC) $168,333

Indirect Annual Costs (IAC)

Laboratory Equipment1, 2 $10,490

Re-tooling1$25,175

Other Capital Costs1, 3 $51,400

Total Indirect Costs (IAC) $87,065

Round One

Total Annual Cost $255,399

Total Annual Cost $63,850

0.34

Note: Fraction that Capital Cost is of Total 

Cost =

3 To conservatively estimate the additional cost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib 

was increased by $15,000 and the testing services estimate of $100,000 based on crib only (which covered not only emissions testing but a

efficiency and safety testing) was increased by $50,000. 

1

An amortization period of 6 years for laboratory equipment, retooling and other capital costs was chosen based on industry's estimate th

approximately 6 years of R&D are required to bring a product to market .

2

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

Round Two 6-

year R&D 

Period

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates 

of Residential Wood Heating Appliances", spread over 6 years. $141,667

Annual outside consultant cost from Table 3 of the memorandum "Unit 

Cost Estimates of Residential Wood Heating Appliances", spread over 6 

years. $26,667

$168,333

The laboratory equipment cost of $50,000 was amortized over 6 years at 

an interest rate of 7%. $0

The re-tooling cost of $120,000 was amortized over 6 years at an interest 

rate of 7%. $25,175

Other capital costs include costs for prototypes ($25,000), test fuel 

($30,000+$15,000), testing services ($100,000+$50,000), and marketing 

($25,000) and were amortized over 6 years at an interest rate of 7%. $51,400

$76,575

Round Two 2

Annual cost for development of 4 model fireboxes. $244,909

Average annual cost per firebox model. $61,227

ost to test with both cord wood and crib wood, the test fuel estimate of $30,000 based on crib only 

vices estimate of $100,000 based on crib only (which covered not only emissions testing but also 

tory equipment, retooling and other capital costs was chosen based on industry's estimate that 

o bring a product to market .

can be used for round two R&D, so the round two costs exclude the lab equipment cost.
Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods 

2013

Wood Stoves (R&D)334 125 $223,004

Pellet Stoves (R&D, R&R)4, 8 29 125 $199,681

Pellet Stoves (certification)429 125 $2,586

Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $862,204

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $917,148

Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $258,204

MH - large companies (R&D, R&R, cert.)92 4 $130,169

MH - large companies (R&R, cert.)93 9 $9,704

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

MH - small companies (R&R, software cert.)7, 9 42 85 $3,852

9

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of t

manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the 

# Manufacturers # Models

Average Annual Cost per Manufa

QQQQ: Central Heaters

RRRR: Masonry Heaters

AAA: Room Heaters

NSPS Subpart

7 For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, alt

software certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer.

Appliance Type

8

 Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of t

nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by l

Annual Cost of the Rule

6

 For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small perce

1 Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 201

2

 Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certificat

3

 This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% 

who already had to certify and report under the existing NSPS.

4

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round on

5

Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 t

are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more st
Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

(Step 1 

compliance) 

2014 2015 2016

(Step 2 

compliance) 

2017 2018 2019 2020

$223,004 $223,004 $223,004 $394,080 $394,080 $171,076 $171,076

$199,681 $199,681 $199,681 $347,471 $347,471 $154,821 $154,821

$2,586 $2,586 $2,586 $2,586 $2,586 $3,793 $3,793

$862,204 $436,539 $436,539 $763,085 $763,085 $340,087 $340,087

$917,148 $461,079 $461,079 $810,949 $810,949 $360,594 $360,594

$258,204 $258,204 $258,204 $454,131 $454,131 $201,933 $201,933

$130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469

$9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704

$10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328

$2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802

are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burd

&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimate

erage Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level 

certification costs (through 2041)

dditional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 

veloped by that manufacturer.

are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burd

o be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496.

assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another 

h 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 wit

rs), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

onservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require an

 undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The 

ndergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from 

op models to meet the more stringent 2017 Step 2 and 2022 Step 3 standards.
2021

(Step 3 

compliance) 

2022

2023 

through 

2041 22013 2014 2015 2016 2017

$171,076 $171,076 $0 7,582,146 7,582,146 7,582,146 7,582,146 13,398,730

$154,821 $154,821 $7,031 5,790,753 5,790,753 5,790,753 5,790,753 10,076,657

$3,793 $3,793 $8,621 75,000 75,000 75,000 75,000 75,000

$340,087 $340,087 $24,208 2,586,611 2,586,611 1,309,618 1,309,618 2,289,254

16,034,510 16,034,510 14,757,517 14,757,517 25,839,640

$360,594 $360,594 $33,582 6,420,038 6,420,038 3,227,556 3,227,556 5,676,644

$201,933 $201,933 $18,806 7,746,133 7,746,133 7,746,133 7,746,133 13,623,945

$14,166,171 $14,166,171 $10,973,689 $10,973,689 $19,300,588

$6,469 $6,469 $6,469 $260,337 $260,337 $260,337 $260,337 $260,337

$9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112

$10,328 $10,328 $10,328 $11,378 $10,328 $10,328 $10,328 $10,328

$2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688

$462,616 $417,466 $417,466 $417,466 $417,466

$30,663,297 $30,618,147 $26,148,672 $26,148,672 $45,557,694

e annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater 

ements under Subpart RRRR is estimated to be $37,872.

7-2022) to meet Step 3 level with ongoing 

Nationwide Annual Cost

volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using 

e annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs 

n round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs.

 a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

e, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing repo

budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoin

 may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis conservatively assumes that these ef
2018 2019 2020 2021 2022

2023 through 

2041 2 

13,398,730 5,816,584 5,816,584 5,816,584 5,816,584 $0

10,076,657 4,489,813 4,489,813 4,489,813 4,489,813 $203,909

75,000 110,000 110,000 110,000 110,000 $250,000

2,289,254 1,020,261 1,020,261 1,020,261 1,020,261 $72,625

25,839,640 11,436,657 11,436,657 11,436,657 11,436,657 $526,534

5,676,644 2,524,161 2,524,161 2,524,161 2,524,161 $235,073

13,623,945 6,057,987 6,057,987 6,057,987 6,057,987 $564,176

$19,300,588 $8,582,148 $8,582,148 $8,582,148 $8,582,148 $799,249

$260,337 $12,939 $12,939 $12,939 $12,939 $12,939

$29,112 $29,112 $29,112 $29,112 $29,112 $29,112

$10,328 $10,328 $10,328 $10,328 $10,328 $10,328

$117,688 $117,688 $117,688 $117,688 $117,688 $117,688

$417,466 $170,067 $170,067 $170,067 $170,067 $170,067

$45,557,694 $20,188,873 $20,188,873 $20,188,873 $20,188,873 $1,495,850

Nationwide Annual Costs1

QQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average 

costs under the existing NSPS.

fication costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers 

t Step 3 will certify in an ongoing basis starting in 2013. 

ervatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs 
Period Nationwide Cost of the Rule

Year 2022 $20,188,873

Year 2023 & following $1,495,850

Cumulative 

(2013 through 2033) $313,870,820
SCC

Appliance 

Population Total Tons Burned Emission Inventory Category Pollutant

Baseline 

Emission 

factor 

(lb/ton)

Baseline 

Emissions 

(tons)

Baseline 

Tons/appl

Step 1 

Emission 

Factor

2104008220 1,303,142 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Volatile Organic Compounds 12 7,357 0.0056 12

2104008230 427,224 416,187 Woodstove: fireplace inserts; EPA certified; catalytic Volatile Organic Compounds 15 3,121 0.0073 15

2104008320 873,357 1,540,026 Woodstove: freestanding, EPA certified, non-catalytic Volatile Organic Compounds 12 9,240 0.0106 12

2104008330 374,154 775,602 Woodstove: freestanding, EPA certified, catalytic Volatile Organic Compounds 15 5,817 0.0155 15

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Volatile Organic Compounds 0.041 24 0.0000 0.041

2,206,470 4,668,250 Single Burn Rate Stoves Volatile Organic Compounds 53 123,709 0.0561 12

2104008610 364,560 3,654,153 Hydronic heater: outdoor Volatile Organic Compounds 11.7 21,377 0.0586 1.17

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Volatile Organic Compounds 11.7 15,351 0.0437 2.925

0.0086 Baseline woodstove weighted average (Tons/appl)
2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 126,527 80,851 77,617 79,169 80,752 82,367 84,015 85,695 87,409

Single Burn Rate 

Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,091 27,633

Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,305 90,072

Furnace: indoor, 

cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,769 28,324

Hydronic Heating 

Systems 13,385 8,553 8,211 8,375 8,543 8,713 8,888 9,065 9,247

2008 2009 2010 2011 2012 2013 2014 2015 2016

Wood Stoves 1,085 693 666 679 692 706 720 735 750

Single Burn Rate 

Stoves 2,243 1,433 1,376 1,403 1,431 1,460 1,489 1,519 1,549

Pellet Stoves 4 2 2 2 2 2 2 3 3

Furnace: indoor, 

cordwood 1,793 1,146 1,100 1,122 1,144 1,167 1,191 1,214 1,239

Hydronic Heating 

Systems 785 502 481 491 501 511 521 532 542

Total 5,909 3,776 3,625 3,697 3,771 3,847 3,924 4,002 4,082

Table 4. Estimated Annual Shipped Units

Table 5. Estimated VOC Emissions (Tons) -- Baseline
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions 

(tons)

NSPS VOC 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$5,466,157 $16,034,510 $5,828,073

2014 4$5,466,157 $16,034,510 $5,828,073 2,212 1,060 1,152 $5,059 2,212 1,060 1,152

2015 4$5,030,830 $14,757,517 $5,828,073 2,256 1,081 1,175 $4,960 4,468 2,141 2,327

2016 4$5,030,830 $14,757,517 $5,828,073 2,301 1,103 1,199 $4,863 6,770 3,244 3,526

2017 $8,808,721 $25,839,640 $5,828,073 2,347 740 1,607 $3,626 9,117 3,984 5,133

2018 $8,808,721 $25,839,640 $5,828,073 2,394 755 1,640 $3,555 11,512 4,739 6,772

2019 $3,898,751 $11,436,657 $5,828,073 2,442 770 1,672 $3,485 13,954 5,509 8,445

2020 $3,898,751 $11,436,657 $5,828,073 2,491 785 1,706 $3,417 16,445 6,294 10,150

2021 $3,898,751 $11,436,657 $5,828,073 2,541 801 1,740 $3,350 18,986 7,096 11,890

2022 $3,898,751 $11,436,657 $5,828,073 2,592 425 2,167 $2,690 21,578 7,520 14,057

2023 $0 $526,534 $5,828,073 2,644 433 2,210 $2,637 24,221 7,954 16,267

2024 $0 $526,534 $5,828,073 2,696 442 2,254 $2,585 26,918 8,396 18,522

2025 $0 $526,534 $5,828,073 2,750 451 2,299 $2,534 29,668 8,847 20,821

2026 $0 $526,534 $5,828,073 2,805 460 2,345 $2,485 32,473 9,307 23,167

2027 $0 $526,534 $5,828,073 2,862 469 2,392 $2,436 35,335 9,776 25,559

2028 $0 $526,534 $5,828,073 2,919 478 2,440 $2,388 38,254 10,254 27,999

2029 $0 $526,534 $5,828,073 2,977 488 2,489 $2,341 41,231 10,742 30,488

2030 $0 $526,534 $5,828,073 3,037 498 2,539 $2,296 44,267 11,240 33,027

2031 $0 $526,534 $5,828,073 3,097 508 2,590 $2,251 47,365 11,748 35,617

2032 $0 $526,534 $5,828,073 3,159 518 2,641 $2,206 50,524 12,266 38,258

2033 $0 $526,534 $5,828,073 3,223 528 2,694 $2,163 53,747 12,794 40,953

2034 $0 $526,534 $5,828,073 3,287 539 2,748 $2,121 54,822 12,273 42,549

2035 $0 $526,534 $5,828,073 3,353 550 2,803 $2,079 55,918 11,741 44,177

2036 $0 $526,534 $5,828,073 3,420 561 2,859 $2,038 57,036 11,199 45,837

2037 $0 $526,534 $5,828,073 3,488 572 2,916 $1,998 58,177 11,031 47,146

2038 $0 $526,534 $5,828,073 3,558 583 2,975 $1,959 59,341 10,859 48,481

2039 $0 $526,534 $5,828,073 3,629 595 3,034 $1,921 60,528 10,684 49,843

2040 $0 $526,534 $5,828,073 3,702 607 3,095 $1,883 61,738 10,506 51,232

2041 $0 $526,534 $5,828,073 3,776 619 3,157 $1,846 62,973 10,324 52,649

2042 60,381 9,899 50,482

2043 57,737 9,465 48,272

2044 55,041 9,023 46,018

2045 52,291 8,572 43,718

2046 49,485 8,113 41,373

2047 46,624 7,643 38,980

2048 43,705 7,165 36,540

2049 40,728 6,677 34,051

2050 37,691 6,179 31,512

2051 34,594 5,671 28,923

2052 31,435 5,153 26,281

2053 28,212 4,625 23,587

2054 24,925 4,086 20,839

2055 21,572 3,537 18,036

2056 18,153 2,976 15,177

2057 14,664 2,404 12,260

2058 11,106 1,821 9,286

2059 7,477 1,226 6,252

2060 3,776 619 3,157

$169,014,114 587,392 $288

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

3

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

because it is prior to the rule compliance date.

Cumulative Emission Reduction 

over 20-year stove lifespan 

Annual Snapshots Emission Reduction, cumulative per year

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Room Heaters (Wood Stoves, Pellet Stoves, and Single Burn Rate Stoves)

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves and pellet stoves, estimates conservatively assume that 

most models meet Step 1 and that manufacturers will certify and sell existing models meeting Step 1 from 2014 through 2016. Therefore no emission reductions are estimated to result from woodstoves 

and pellet stoves until Step 2 in 2017.
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,584,750 $7,582,146 $2,772,151

2014 4

$2,584,750 $7,582,146 $2,772,151 720 720 0 N/A 720 720 0

2015 4

$2,584,750 $7,582,146 $2,772,151 735 735 0 N/A 1,455 1,455 0

2016 4

$2,584,750 $7,582,146 $2,772,151 750 750 0 N/A 2,205 2,205 0

2017 $4,567,621 $13,398,730 $2,772,151 765 541 224 $12,397 2,969 2,746 224

2018 $4,567,621 $13,398,730 $2,772,151 780 552 228 $12,154 3,749 3,297 452

2019 $1,982,871 $5,816,584 $2,772,151 795 563 233 $11,916 4,545 3,860 684

2020 $1,982,871 $5,816,584 $2,772,151 811 574 237 $11,682 5,356 4,434 922

2021 $1,982,871 $5,816,584 $2,772,151 828 586 242 $11,453 6,183 5,020 1,164

2022 $1,982,871 $5,816,584 $2,772,151 844 311 534 $5,196 7,028 5,330 1,697

2023 $0 $0 $2,772,151 861 317 544 $5,094 7,889 5,647 2,241

2024 $0 $0 $2,772,151 878 323 555 $4,994 8,767 5,970 2,797

2025 $0 $0 $2,772,151 896 330 566 $4,896 9,663 6,300 3,363

2026 $0 $0 $2,772,151 914 336 578 $4,800 10,576 6,636 3,940

2027 $0 $0 $2,772,151 932 343 589 $4,706 11,508 6,979 4,529

2028 $0 $0 $2,772,151 951 350 601 $4,614 12,459 7,329 5,130

2029 $0 $0 $2,772,151 970 357 613 $4,523 13,428 7,685 5,743

2030 $0 $0 $2,772,151 989 364 625 $4,434 14,417 8,049 6,368

2031 $0 $0 $2,772,151 1,009 371 638 $4,347 15,426 8,420 7,006

2032 $0 $0 $2,772,151 1,029 379 650 $4,262 16,455 8,799 7,656

2033 $0 $0 $2,772,151 1,050 386 663 $4,179 17,505 9,185 8,320

2034 $0 $0 $2,772,151 1,071 394 677 $4,097 17,855 8,858 8,996

2035 $0 $0 $2,772,151 1,092 402 690 $4,016 18,212 8,525 9,687

2036 $0 $0 $2,772,151 1,114 410 704 $3,938 18,576 8,186 10,391

2037 $0 $0 $2,772,151 1,136 418 718 $3,860 18,948 8,063 10,885

2038 $0 $0 $2,772,151 1,159 426 732 $3,785 19,327 7,937 11,390

2039 $0 $0 $2,772,151 1,182 435 747 $3,711 19,713 7,809 11,904

2040 $0 $0 $2,772,151 1,206 444 762 $3,638 20,107 7,679 12,429

2041 $0 $0 $2,772,151 1,230 452 777 $3,566 20,510 7,546 12,964

2042 19,665 7,235 12,430

2043 18,805 6,918 11,886

2044 17,926 6,595 11,331

2045 17,031 6,266 10,765

2046 16,117 5,930 10,187

2047 15,185 5,587 9,598

2048 14,234 5,237 8,997

2049 13,265 4,880 8,384

2050 12,276 4,516 7,759

2051 11,267 4,145 7,122

2052 10,238 3,767 6,471

2053 9,188 3,380 5,808

2054 8,118 2,987 5,131

2055 7,026 2,585 4,441

2056 5,912 2,175 3,737

2057 4,776 1,757 3,019

2058 3,617 1,331 2,286

2059 2,435 896 1,539

2060 1,230 452 777

$80,392,378 144,635 $556

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Wood Stoves

Year

Annual 

Capital Costs

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 stove 

lifespan (per ton)

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

because it is prior to the rule compliance date.

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves, estimates conservatively assume that most models 

meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year stove lifespan 5 
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction (tons)

2013 3$1,999,632 $5,865,753 $2,441,029

2014 4$1,999,632 $5,865,753 $2,441,029 2 2 0 N/A 2 2 0

2015 4$1,999,632 $5,865,753 $2,441,029 3 3 0 N/A 5 5 0

2016 4$1,999,632 $5,865,753 $2,441,029 3 3 0 N/A 8 8 0

2017 $3,460,695 $10,151,657 $2,441,029 3 2 0 $9,339,363 10 10 0

2018 $3,460,695 $10,151,657 $2,441,029 3 2 0 $9,156,238 13 12 1

2019 $1,568,074 $4,599,813 $2,441,029 3 2 0 $8,976,704 16 15 1

2020 $1,568,074 $4,599,813 $2,441,029 3 2 0 $8,800,690 18 17 1

2021 $1,568,074 $4,599,813 $2,441,029 3 3 0 $8,628,128 21 20 1

2022 $1,568,074 $4,599,813 $2,441,029 3 1 2 $1,590,028 24 21 3

2023 $0 $453,909 $2,441,029 3 1 2 $1,558,851 27 23 4

2024 $0 $453,909 $2,441,029 3 1 2 $1,528,285 30 24 6

2025 $0 $453,909 $2,441,029 3 1 2 $1,498,319 33 25 8

2026 $0 $453,909 $2,441,029 3 1 2 $1,468,940 36 27 9

2027 $0 $453,909 $2,441,029 3 1 2 $1,440,137 39 28 11

2028 $0 $453,909 $2,441,029 3 2 2 $1,411,899 43 30 13

2029 $0 $453,909 $2,441,029 3 2 2 $1,384,215 46 31 15

2030 $0 $453,909 $2,441,029 3 2 2 $1,357,074 49 33 16

2031 $0 $453,909 $2,441,029 3 2 2 $1,330,464 53 35 18

2032 $0 $453,909 $2,441,029 4 2 2 $1,304,377 56 36 20

2033 $0 $453,909 $2,441,029 4 2 2 $1,278,801 60 38 22

2034 $0 $453,909 $2,441,029 4 2 2 $1,253,726 61 37 24

2035 $0 $453,909 $2,441,029 4 2 2 $1,229,143 62 36 26

2036 $0 $453,909 $2,441,029 4 2 2 $1,205,043 64 36 28

2037 $0 $453,909 $2,441,029 4 2 2 $1,181,414 65 35 30

2038 $0 $453,909 $2,441,029 4 2 2 $1,158,249 66 35 32

2039 $0 $453,909 $2,441,029 4 2 2 $1,135,538 67 34 33

2040 $0 $453,909 $2,441,029 4 2 2 $1,113,273 69 33 35

2041 $0 $453,909 $2,441,029 4 2 2 $1,091,444 70 33 37

2042 67 31 36

2043 64 30 34

2044 61 29 33

2045 58 27 31

2046 55 26 29

2047 52 24 28

2048 49 23 26

2049 45 21 24

2050 42 20 22

2051 39 18 20

2052 35 16 19

2053 31 15 17

2054 28 13 15

2055 24 11 13

2056 20 9 11

2057 16 8 9

2058 12 6 7

2059 8 4 4

2060 4 2 2

$70,789,844 416 $170,101

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Pellet Stoves

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

it is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For pellet stoves, estimates conservatively assume that most models meet 

the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction (tons)

2013 3$881,775 $2,586,611 $614,893

2014 4$881,775 $2,586,611 $614,893 1,489 337 1,152 $534 1,489 337 1,152

2015 $446,448 $1,309,618 $614,893 1,519 344 1,175 $523 3,008 681 2,327

2016 $446,448 $1,309,618 $614,893 1,549 351 1,199 $513 4,557 1,032 3,526

2017 4$780,405 $2,289,254 $614,893 1,580 197 1,383 $444 6,138 1,229 4,909

2018 $780,405 $2,289,254 $614,893 1,612 201 1,411 $436 7,750 1,429 6,320

2019 $347,806 $1,020,261 $614,893 1,644 205 1,439 $427 9,394 1,634 7,760

2020 $347,806 $1,020,261 $614,893 1,677 209 1,468 $419 11,071 1,843 9,228

2021 $347,806 $1,020,261 $614,893 1,711 213 1,498 $411 12,781 2,056 10,725

2022 4$347,806 $1,020,261 $614,893 1,745 113 1,632 $377 14,526 2,169 12,357

2023 $0 $72,625 $614,893 1,780 115 1,664 $369 16,306 2,284 14,021

2024 $0 $72,625 $614,893 1,815 118 1,698 $362 18,121 2,402 15,719

2025 $0 $72,625 $614,893 1,852 120 1,732 $355 19,972 2,522 17,451

2026 $0 $72,625 $614,893 1,889 122 1,766 $348 21,861 2,644 19,217

2027 $0 $72,625 $614,893 1,926 125 1,802 $341 23,787 2,769 21,019

2028 $0 $72,625 $614,893 1,965 127 1,838 $335 25,752 2,896 22,856

2029 $0 $72,625 $614,893 2,004 130 1,874 $328 27,756 3,026 24,731

2030 $0 $72,625 $614,893 2,044 132 1,912 $322 29,801 3,158 26,643

2031 $0 $72,625 $614,893 2,085 135 1,950 $315 31,886 3,293 28,593

2032 $0 $72,625 $614,893 2,127 138 1,989 $309 34,013 3,431 30,582

2033 $0 $72,625 $614,893 2,169 140 2,029 $303 36,182 3,571 32,611

2034 $0 $72,625 $614,893 2,213 143 2,069 $297 36,906 3,377 33,528

2035 $0 $72,625 $614,893 2,257 146 2,111 $291 37,644 3,180 34,464

2036 $0 $72,625 $614,893 2,302 149 2,153 $286 38,397 2,978 35,419

2037 $0 $72,625 $614,893 2,348 152 2,196 $280 39,165 2,933 36,231

2038 $0 $72,625 $614,893 2,395 155 2,240 $274 39,948 2,888 37,060

2039 $0 $72,625 $614,893 2,443 158 2,285 $269 40,747 2,841 37,906

2040 $0 $72,625 $614,893 2,492 161 2,331 $264 41,562 2,794 38,768

2041 $0 $72,625 $614,893 2,542 165 2,377 $259 42,393 2,745 39,648

2042 40,648 2,632 38,016

2043 38,869 2,517 36,352

2044 37,053 2,399 34,654

2045 35,202 2,279 32,922

2046 33,313 2,157 31,156

2047 31,387 2,032 29,354

2048 29,422 1,905 27,517

2049 27,418 1,775 25,642

2050 25,374 1,643 23,731

2051 23,288 1,508 21,780

2052 21,162 1,370 19,791

2053 18,992 1,230 17,762

2054 16,779 1,087 15,693

2055 14,522 940 13,582

2056 12,220 791 11,429

2057 9,872 639 9,233

2058 7,477 484 6,993

2059 5,034 326 4,708

2060 2,542 165 2,377

$17,831,892 442,341 $40

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Single Burn Rate Stoves

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), 

plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted 

by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to 

bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

CE based on total cost 

& cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3$4,829,241 $14,166,171 $4,772,249

2014 4$4,829,241 $14,166,171 $4,772,249 1,712 350 1,362 $3,504 1,712 350 1,362

2015 $3,740,925 $10,973,689 $4,772,249 1,746 357 1,389 $3,435 3,458 707 2,751

2016 $3,740,925 $10,973,689 $4,772,249 1,781 364 1,417 $3,368 5,239 1,070 4,168

2017 4$6,579,561 $19,300,588 $4,772,249 1,817 91 1,726 $2,765 7,055 1,161 5,894

2018 $6,579,561 $19,300,588 $4,772,249 1,853 93 1,760 $2,711 8,908 1,254 7,654

2019 $2,925,650 $8,582,148 $4,772,249 1,890 94 1,795 $2,658 10,798 1,348 9,449

2020 $2,925,650 $8,582,148 $4,772,249 1,928 96 1,831 $2,606 12,726 1,445 11,281

2021 $2,925,650 $8,582,148 $4,772,249 1,966 98 1,868 $2,555 14,692 1,543 13,149

2022 4$2,925,650 $8,582,148 $4,772,249 2,006 40 1,965 $2,428 16,697 1,583 15,114

2023 $0 $799,249 $4,772,249 2,046 41 2,005 $2,380 18,743 1,624 17,119

2024 $0 $799,249 $4,772,249 2,087 42 2,045 $2,334 20,830 1,666 19,164

2025 $0 $799,249 $4,772,249 2,128 43 2,086 $2,288 22,958 1,708 21,250

2026 $0 $799,249 $4,772,249 2,171 43 2,127 $2,243 25,129 1,752 23,377

2027 $0 $799,249 $4,772,249 2,214 44 2,170 $2,199 27,343 1,796 25,547

2028 $0 $799,249 $4,772,249 2,259 45 2,213 $2,156 29,602 1,841 27,760

2029 $0 $799,249 $4,772,249 2,304 46 2,258 $2,114 31,906 1,887 30,018

2030 $0 $799,249 $4,772,249 2,350 47 2,303 $2,072 34,255 1,934 32,321

2031 $0 $799,249 $4,772,249 2,397 48 2,349 $2,032 36,652 1,982 34,670

2032 $0 $799,249 $4,772,249 2,445 49 2,396 $1,992 39,097 2,031 37,066

2033 $0 $799,249 $4,772,249 2,494 50 2,444 $1,953 41,591 2,081 39,510

2034 $0 $799,249 $4,772,249 2,544 51 2,493 $1,915 42,422 1,782 40,640

2035 $0 $799,249 $4,772,249 2,594 52 2,543 $1,877 43,271 1,477 41,794

2036 $0 $799,249 $4,772,249 2,646 53 2,593 $1,840 44,136 1,166 42,970

2037 $0 $799,249 $4,772,249 2,699 54 2,645 $1,804 45,019 1,129 43,890

2038 $0 $799,249 $4,772,249 2,753 55 2,698 $1,769 45,919 1,092 44,828

2039 $0 $799,249 $4,772,249 2,808 56 2,752 $1,734 46,838 1,054 45,784

2040 $0 $799,249 $4,772,249 2,864 57 2,807 $1,700 47,775 1,014 46,760

2041 $0 $799,249 $4,772,249 2,922 58 2,863 $1,667 48,730 975 47,756

2042 46,725 934 45,790

2043 44,679 894 43,785

2044 42,592 852 41,740

2045 40,464 809 39,655

2046 38,293 766 37,527

2047 36,079 722 35,357

2048 33,820 676 33,144

2049 31,516 630 30,886

2050 29,167 583 28,583

2051 26,770 535 26,234

2052 24,325 486 23,838

2053 21,831 437 21,395

2054 19,288 386 18,902

2055 16,693 334 16,359

2056 14,047 281 13,766

2057 11,348 227 11,121

2058 8,594 172 8,423

2059 5,786 116 5,670

2060 2,922 58 2,863

$138,395,222 532,795 $260

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems)

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm). 

3

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

because it is prior to the rule compliance date.

4

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

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)
Baseline VOC 

Emissions2 (tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,188,588 $6,420,038 $1,559,018

2014 4

$2,188,588 $6,420,038 $1,559,018 1,191 298 893 $1,746 1,191 298 893

2015 $1,100,272 $3,227,556 $1,559,018 1,214 304 911 $1,712 2,405 601 1,804

2016 $1,100,272 $3,227,556 $1,559,018 1,239 310 929 $1,678 3,644 911 2,733

2017 4

$1,935,165 $5,676,644 $1,559,018 1,263 63 1,200 $1,299 4,907 974 3,933

2018 $1,935,165 $5,676,644 $1,559,018 1,289 64 1,224 $1,273 6,196 1,039 5,157

2019 $860,485 $2,524,161 $1,559,018 1,315 66 1,249 $1,248 7,510 1,104 6,406

2020 $860,485 $2,524,161 $1,559,018 1,341 67 1,274 $1,224 8,851 1,171 7,680

2021 $860,485 $2,524,161 $1,559,018 1,368 68 1,299 $1,200 10,219 1,240 8,979

2022 4

$860,485 $2,524,161 $1,559,018 1,395 28 1,367 $1,140 11,614 1,268 10,346

2023 $0 $235,073 $1,559,018 1,423 28 1,394 $1,118 13,037 1,296 11,741

2024 $0 $235,073 $1,559,018 1,451 29 1,422 $1,096 14,488 1,325 13,163

2025 $0 $235,073 $1,559,018 1,480 30 1,451 $1,075 15,968 1,355 14,614

2026 $0 $235,073 $1,559,018 1,510 30 1,480 $1,054 17,478 1,385 16,093

2027 $0 $235,073 $1,559,018 1,540 31 1,509 $1,033 19,018 1,416 17,603

2028 $0 $235,073 $1,559,018 1,571 31 1,540 $1,013 20,589 1,447 19,142

2029 $0 $235,073 $1,559,018 1,602 32 1,570 $993 22,192 1,479 20,712

2030 $0 $235,073 $1,559,018 1,634 33 1,602 $973 23,826 1,512 22,314

2031 $0 $235,073 $1,559,018 1,667 33 1,634 $954 25,493 1,545 23,948

2032 $0 $235,073 $1,559,018 1,700 34 1,666 $936 27,194 1,579 25,614

2033 $0 $235,073 $1,559,018 1,734 35 1,700 $917 28,928 1,614 27,314

2034 $0 $235,073 $1,559,018 1,769 35 1,734 $899 29,507 1,352 28,155

2035 $0 $235,073 $1,559,018 1,805 36 1,768 $882 30,097 1,084 29,013

2036 $0 $235,073 $1,559,018 1,841 37 1,804 $864 30,699 811 29,887

2037 $0 $235,073 $1,559,018 1,877 38 1,840 $847 31,313 786 30,527

2038 $0 $235,073 $1,559,018 1,915 38 1,877 $831 31,939 759 31,179

2039 $0 $235,073 $1,559,018 1,953 39 1,914 $814 32,578 733 31,845

2040 $0 $235,073 $1,559,018 1,992 40 1,952 $798 33,229 706 32,524

2041 $0 $235,073 $1,559,018 2,032 41 1,992 $783 33,894 678 33,216

2042 32,499 650 31,849

2043 31,076 622 30,454

2044 29,625 592 29,032

2045 28,144 563 27,581

2046 26,634 533 26,102

2047 25,094 502 24,592

2048 23,523 470 23,053

2049 21,921 438 21,483

2050 20,287 406 19,881

2051 18,619 372 18,247

2052 16,919 338 16,581

2053 15,185 304 14,881

2054 13,415 268 13,147

2055 11,611 232 11,379

2056 9,770 195 9,575

2057 7,893 158 7,735

2058 5,978 120 5,858

2059 4,025 80 3,944

2060 2,032 41 1,992

$45,211,511 370,581 $122

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Forced Air Furnaces

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), 

plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to 

bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

CE based on total cost 

& cumulative emission 

reduction over 20-year 

stove lifespan (per 

ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,640,653 $7,746,133 $3,213,231

2014 4

$2,640,653 $7,746,133 $3,213,231 521 52 469 $6,851 521 52 469

2015 $2,640,653 $7,746,133 $3,213,231 532 53 478 $6,716 1,053 105 947

2016 $2,640,653 $7,746,133 $3,213,231 542 54 488 $6,585 1,595 159 1,435

2017 4

$4,644,396 $13,623,945 $3,213,231 553 28 525 $6,116 2,148 187 1,961

2018 $4,644,396 $13,623,945 $3,213,231 564 28 536 $5,996 2,712 215 2,497

2019 $2,065,165 $6,057,987 $3,213,231 575 29 547 $5,878 3,287 244 3,043

2020 $2,065,165 $6,057,987 $3,213,231 587 29 558 $5,763 3,874 273 3,601

2021 $2,065,165 $6,057,987 $3,213,231 599 30 569 $5,650 4,473 303 4,170

2022 4 $2,065,165 $6,057,987 $3,213,231 611 12 598 $5,370 5,084 316 4,768

2023 $0 $564,176 $3,213,231 623 12 610 $5,264 5,706 328 5,378

2024 $0 $564,176 $3,213,231 635 13 623 $5,161 6,342 341 6,001

2025 $0 $564,176 $3,213,231 648 13 635 $5,060 6,990 354 6,636

2026 $0 $564,176 $3,213,231 661 13 648 $4,961 7,651 367 7,284

2027 $0 $564,176 $3,213,231 674 13 661 $4,864 8,325 380 7,944

2028 $0 $564,176 $3,213,231 688 14 674 $4,768 9,013 394 8,618

2029 $0 $564,176 $3,213,231 701 14 687 $4,675 9,714 408 9,306

2030 $0 $564,176 $3,213,231 715 14 701 $4,583 10,429 423 10,007

2031 $0 $564,176 $3,213,231 730 15 715 $4,493 11,159 437 10,722

2032 $0 $564,176 $3,213,231 744 15 729 $4,405 11,903 452 11,451

2033 $0 $564,176 $3,213,231 759 15 744 $4,319 12,663 467 12,195

2034 $0 $564,176 $3,213,231 774 15 759 $4,234 12,916 431 12,485

2035 $0 $564,176 $3,213,231 790 16 774 $4,151 13,174 393 12,781

2036 $0 $564,176 $3,213,231 806 16 790 $4,070 13,438 355 13,083

2037 $0 $564,176 $3,213,231 822 16 805 $3,990 13,706 344 13,363

2038 $0 $564,176 $3,213,231 838 17 821 $3,912 13,981 332 13,648

2039 $0 $564,176 $3,213,231 855 17 838 $3,835 14,260 321 13,939

2040 $0 $564,176 $3,213,231 872 17 855 $3,760 14,545 309 14,237

2041 $0 $564,176 $3,213,231 890 18 872 $3,686 14,836 297 14,540

2042 14,226 285 13,941

2043 13,603 272 13,331

2044 12,968 259 12,708

2045 12,320 246 12,073

2046 11,659 233 11,425

2047 10,984 220 10,765

2048 10,297 206 10,091

2049 9,595 192 9,404

2050 8,880 178 8,702

2051 8,150 163 7,987

2052 7,406 148 7,258

2053 6,647 133 6,514

2054 5,872 117 5,755

2055 5,082 102 4,981

2056 4,277 86 4,191

2057 3,455 69 3,386

2058 2,617 52 2,564

2059 1,762 35 1,726

2060 890 18 872

$93,183,711 162,214 $574

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Hydronic Heating Systems

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

because it is prior to the rule compliance date.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year

4

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping 

costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 
Baseline VOC 

Emissions2 

(tons)

NSPS VOC 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline VOC 

Emissions (tons)

NSPS VOC 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3$10,295,398 $30,200,681 $10,600,322

2014 4$10,295,398 $30,200,681 $10,600,322 3,924 1,410 2,514 $4,217 3,924 1,410 2,514

2015 $8,771,756 $25,731,206 $10,600,322 4,002 1,438 2,564 $4,134 7,926 2,848 5,078

2016 $8,771,756 $25,731,206 $10,600,322 4,082 1,467 2,616 $4,053 12,008 4,315 7,694

2017 4$15,388,282 $45,140,228 $10,600,322 4,164 831 3,333 $3,180 16,172 5,146 11,027

2018 $15,388,282 $45,140,228 $10,600,322 4,247 848 3,400 $3,118 20,419 5,993 14,426

2019 $6,824,401 $20,018,806 $10,600,322 4,332 864 3,468 $3,057 24,752 6,857 17,894

2020 $6,824,401 $20,018,806 $10,600,322 4,419 882 3,537 $2,997 29,170 7,739 21,431

2021 $6,824,401 $20,018,806 $10,600,322 4,507 899 3,608 $2,938 33,678 8,639 25,039

2022 4$6,824,401 $20,018,806 $10,600,322 4,597 465 4,132 $2,565 38,275 9,104 29,171

2023 $0 $1,325,783 $10,600,322 4,689 474 4,215 $2,515 42,964 9,578 33,386

2024 $0 $1,325,783 $10,600,322 4,783 484 4,299 $2,466 47,747 10,062 37,686

2025 $0 $1,325,783 $10,600,322 4,879 493 4,385 $2,417 52,626 10,555 42,071

2026 $0 $1,325,783 $10,600,322 4,976 503 4,473 $2,370 57,602 11,058 46,544

2027 $0 $1,325,783 $10,600,322 5,076 513 4,562 $2,323 62,678 11,572 51,106

2028 $0 $1,325,783 $10,600,322 5,177 524 4,654 $2,278 67,855 12,096 55,760

2029 $0 $1,325,783 $10,600,322 5,281 534 4,747 $2,233 73,136 12,630 60,507

2030 $0 $1,325,783 $10,600,322 5,387 545 4,842 $2,189 78,523 13,174 65,348

2031 $0 $1,325,783 $10,600,322 5,494 556 4,939 $2,146 84,017 13,730 70,287

2032 $0 $1,325,783 $10,600,322 5,604 567 5,037 $2,104 89,621 14,297 75,324

2033 $0 $1,325,783 $10,600,322 5,716 578 5,138 $2,063 95,337 14,875 80,462

2034 $0 $1,325,783 $10,600,322 5,831 590 5,241 $2,023 97,244 14,055 83,189

2035 $0 $1,325,783 $10,600,322 5,947 602 5,346 $1,983 99,189 13,219 85,970

2036 $0 $1,325,783 $10,600,322 6,066 614 5,453 $1,944 101,173 12,365 88,807

2037 $0 $1,325,783 $10,600,322 6,187 626 5,562 $1,906 103,196 12,160 91,036

2038 $0 $1,325,783 $10,600,322 6,311 638 5,673 $1,869 105,260 11,951 93,309

2039 $0 $1,325,783 $10,600,322 6,437 651 5,786 $1,832 107,365 11,738 95,628

2040 $0 $1,325,783 $10,600,322 6,566 664 5,902 $1,796 109,513 11,520 97,992

2041 $0 $1,325,783 $10,600,322 6,697 677 6,020 $1,761 111,703 11,298 100,405

2042 107,106 10,833 96,272

2043 102,416 10,359 92,057

2044 97,633 9,875 87,758

2045 92,755 9,382 83,373

2046 87,778 8,878 78,900

2047 82,702 8,365 74,337

2048 77,525 7,841 69,684

2049 72,244 7,307 64,937

2050 66,858 6,762 60,095

2051 61,364 6,207 55,157

2052 55,759 5,640 50,120

2053 50,043 5,062 44,982

2054 44,213 4,472 39,741

2055 38,266 3,870 34,395

2056 32,199 3,257 28,943

2057 26,012 2,631 23,381

2058 19,701 1,993 17,708

2059 13,264 1,342 11,922

2060 6,697 677 6,020

$307,409,335 1,120,187 $274

DRAFT Cost Effectiveness (CE) based on annual and cumulative VOC emissions from Central Heaters (Forced Air Furnaces and Hydronic Heating Systems) and Room Heaters (Wood Stoves, Pellet 

Stoves, and Single Burn Rate Stoves)

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

lifespan (per ton)

Emission Reduction, cumulative per year

Nationwide cumulative cost5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs 

to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.

Year

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots

1

 Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 7% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two 

R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years 2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

 Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP 

predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm). 

3

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

because it is prior to the rule compliance date.

4

 Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. No emission reductions are estimated for woodstoves and pellet stoves 

until 2017, although emission reductions are estimated for all other devices starting in 2014.