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

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

Operator labor $141,667Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years.

Outside Consultants $26,667Annual outside consultant cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years.
**Total Direct Costs (DC)** $168,333
**Indirect Annual Costs (IAC)**

Laboratory Equipment1 

# $10,490The laboratory equipment cost of $50,000 was amortized over 6 years at an interest rate of 7%.
Re-tooling1 

# $25,175The re-tooling cost of $120,000 was amortized over 6 years at an interest rate of 7%.

Other Capital Costs1, 2 

# $51,400Other 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%.
**Total Indirect Costs (IAC)** $87,065

**Total Annual Cost** $255,399Annual cost for development of 4 model fireboxes. **Total Annual Cost** $63,850Average annual cost per firebox model.

1

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

2

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

# 0.34

Note: Fraction that Capital Cost is of Total Cost =**Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during R&D re-design (2013-2018) and through model lifespan (2019-2038)**

2013 (Step 1

compliance) 2014 2015 2016 2017 2018 (Step 2 compliance) 2019 2020 through

20382 2013 (Step 1 compliance) 2014 2015 2016 2017 2018 (Step 2 compliance) 2019 2020 through

20382 Wood Stoves (R&D)3 34 125 $223,004 $223,004 $223,004 $223,004 $223,004 $223,004 $0 $0 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $7,582,146 $0 $0 Pellet Stoves (R&D, R&R)4,8 29 125 $199,681 $199,681 $199,681 $199,681 $199,681 $199,681 $7,031 $7,031 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $5,790,753 $203,909 $203,909 Pellet Stoves (certification)4 29 125 $2,586 $2,586 $2,586 $2,586 $2,586 $2,586 $8,621 $8,621 $75,000 $75,000 $75,000 $75,000 $75,000 $75,000 $250,000 $250,000 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 3 20 $862,204 $862,204 $436,539 $436,539 $436,539 $436,539 $24,208 $24,208 $2,586,611 $2,586,611 $1,309,618 $1,309,618 $1,309,618 $1,309,618 $72,625 $72,625 $16,034,510$16,034,510 $14,757,517$14,757,517$14,757,517 $14,757,517 $526,534 $526,534 Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 7 50 $917,148 $917,148 $461,079 $461,079 $461,079 $461,079 $33,582 $33,582 $6,420,038 $6,420,038 $3,227,556 $3,227,556 $3,227,556 $3,227,556 $235,073 $235,073 Hydronic Heating Systems (R&D, R&R, cert.)6, 8 30 120 $258,204 $258,204 $258,204 $258,204 $258,204 $258,204 $18,806 $18,806 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $7,746,133 $564,176 $564,176 $14,166,171$14,166,171 $10,973,689$10,973,689$10,973,689 $10,973,689 $799,249 $799,249 MH - large companies (R&D, R&R, cert.)9 2 4 $130,169 $130,169 $130,169 $130,169 $130,169 $130,169 $6,469 $6,469 $260,337 $260,337 $260,337 $260,337 $260,337 $260,337 $12,939 $12,939 MH - large companies (R&R, cert.)9 3 9 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 MH - large companies (R&R, software cert.)7, 9 1 8 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 MH - small companies (R&R, software cert.)7, 9 42 85 $3,852 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $462,616 $417,466 $417,466 $417,466 $417,466 $417,466 $170,067 $170,067 Period Nationwide Cost of the Rule R&D year average (2013-

2018) $27,646,022 $30,663,297$30,618,147 $26,148,672$26,148,672 $26,148,672 $26,148,672$1,495,850$1,495,850 Year 2022 $1,495,850 Cumulative (2013 through 2038) $195,793,135 NSPS Subpart Appliance Type

7For masonry heaters, the cost analysis assumes one round of R&D to meet 0.32 lb/mmBTU standard (no additional stepped standards, although large manufacturers will be required to meet the limit in 2014, while small volume manufacturers will be given a 5 year extension until 2019 to meet the limit). For masonry heater manufacturers using software certification, the analysis assumes the purchased software will be used for certifying all models developed by that manufacturer. Annual Cost of the Rule

6For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively 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 2019. 1Nationwide Annual Cost assumes R&D investment is amortized over 6 years (2013 through 2018). Ongoing certification costs are incurred through 2038 (based on a model brought to market in 2019 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

2Since certification is required every 5 years (except for the software certification option for masonry heaters), it is assumed that certification costs will be spread out so that 1/5 of the models certify each year.

3This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 2 already so that 95% of the models will undergo re-design to meet the Step 2 level. The costs modeled for years 2020 through 2038 exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers who already had to certify and report under the existing NSPS.

4For pellet stoves, the analysis assumes that 30% meet Step 2 already so that 70% of models undergo R&D re-design to meet Step 2. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 2 will certify in an ongoing basis starting in 2013. The analysis reflects the certification costs beginning in 2013 for the 30% of models meeting Step 2, and beginning in 2019 for the remaining 70% of models which underwent R&D re-design.

5Based on conversations with industry (2/2013), single burn rate stoves and forced air furnaces have been undergoing R&D prior to 2013 to develop cleaner models. Because these devices were previously unregulated and may need to transfer technology from adjustable burn rate stoves and hydronic heaters respectively, this analysis conservatively assumes that these efforts will intensify in 2013 and 2014. Therefore estimated R&D costs are doubled in 2013 and 2014 in order to meet the 2014 Step 1 standard while also beginning R&D to develop models to meet the more stringent 2019 Step 2 standard.

8Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart AAA is $440,443, and for Subpart QQQQ is $119,249. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart AAA is estimated to be $75,745, and incurred by laboratories subject to requirements under Subpart QQQQ is estimated to be $50,496.
9Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of the ongoing R&R burden to manufacturers associated with the proposed NSPS. The annual average nationwide R&R burden estimated to manufacturers for Subpart RRRR is $98,788 for small/custom masonry heater manufacturers and $25,929 for large masonry heater manufacturers. These R&R costs do not include the R&R burden to laboratories; the annual average nationwide R&R burden incurred by laboratories subject to requirements under Subpart RRRR is estimated to be $37,872. Average Annual Cost per Manufacturer based on 6-year R&D round (2013-2018) to meet Step 1 and Step 2 limits with ongoing certification costs (through 2038)

# Manufacturers # Models Nationwide Annual Costs1

QQQQ: Central Heaters

RRRR: Masonry Heaters AAA: Room Heaters

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

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

**Tons/appl 2014** 

**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 27.6 50,427 0.1383 2.76 2104008510 351,023 2,624,115Furnace: indoor, cordwood Primary PM2.5 27.6 36,213 0.1032 6.9 0.0060Baseline woodstove weighted average (Tons/appl)

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

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

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 761 486 467 476 486 495 505 515 526 Single Burn Rate Stoves 1,295 827 794 810 826 843 860 877 895 Pellet Stoves 277 177 170 173 177 180 184 187 191 Furnace: indoor, cordwood 4,230 2,703 2,595 2,647 2,699 2,753 2,809 2,865 2,922 Hydronic Heating Systems 1,851 1,183 1,136 1,158 1,182 1,205 1,229 1,254 1,279 Total **8,414 5,376**  **5,161 5,265**  **5,370 5,477**  **5,587 5,699**  **5,812 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) CE based on

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

Emissions (tons) NSPS PM2.5

Emissions (tons) Emission

Reduction (tons) 20133 $5,466,157$16,034,510$3,908,837 20144 $5,466,157$16,034,510$3,908,837 1,549 935 614 $6,370 1,549 935 614 20154 $5,030,830$14,757,517$3,908,837 1,580 954 626 $6,245 3,129 1,889 1,240 20164 $5,030,830$14,757,517$3,908,837 1,611 973 638 $6,123 4,740 2,862 1,878 20174 $5,030,830$14,757,517$3,908,837 1,644 992 651 $6,003 6,384 3,854 2,529 20184 $5,030,830$14,757,517$3,908,837 1,677 1,012 664 $5,885 8,060 4,867 3,193 2019 $0 $526,534 $3,908,837 1,710 374 1,336 $2,927 9,770 5,241 4,529 2020 $0 $526,534 $3,908,837 1,744 382 1,362 $2,869 11,514 5,623 5,891 2021 $0 $526,534 $3,908,837 1,779 390 1,390 $2,813 13,294 6,013 7,281 2022 $0 $526,534 $3,908,837 1,815 397 1,417 $2,758 15,108 6,410 8,698 2023 $0 $526,534 $3,908,837 1,851 405 1,446 $2,704 16,959 6,815 10,144 2024 $0 $526,534 $3,908,837 1,888 413 1,475 $2,651 18,847 7,229 11,618 2025 $0 $526,534 $3,908,837 1,926 422 1,504 $2,599 20,773 7,651 13,122 2026 $0 $526,534 $3,908,837 1,964 430 1,534 $2,548 22,737 8,081 14,657 2027 $0 $526,534 $3,908,837 2,004 439 1,565 $2,498 24,741 8,519 16,221 2028 $0 $526,534 $3,908,837 2,044 448 1,596 $2,449 26,785 8,967 17,818 2029 $0 $526,534 $3,908,837 2,085 456 1,628 $2,401 28,869 9,423 19,446 2030 $0 $526,534 $3,908,837 2,126 466 1,661 $2,354 30,995 9,889 21,106 2031 $0 $526,534 $3,908,837 2,169 475 1,694 $2,308 33,164 10,364 22,800 2032 $0 $526,534 $3,908,837 2,212 484 1,728 $2,262 35,376 10,848 24,528 2033 $0 $526,534 $3,908,837 2,256 494 1,762 $2,218 37,632 11,342 26,290 2034 $0 $526,534 $3,908,837 2,301 504 1,798 $2,175 38,385 10,911 27,474 2035 $0 $526,534 $3,908,837 2,348 514 1,833 $2,132 39,153 10,471 28,681 2036 $0 $526,534 $3,908,837 2,394 524 1,870 $2,090 39,936 10,023 29,913 2037 $0 $526,534 $3,908,837 2,442 535 1,908 $2,049 40,735 9,565 31,169 2038 $0 $526,534 $3,908,837 2,491 546 1,946 $2,009 41,549 9,098 32,451 2039 39,839 8,724 31,115 2040 38,095 8,342 29,753 2041 36,316 7,952 28,364 2042 34,501 7,555 26,946 2043 32,650 7,150 25,501 2044 30,762 6,736 24,026 2045 28,836 6,315 22,522 2046 26,872 5,884 20,988 2047 24,869 5,446 19,423 2048 22,825 4,998 17,827 2049 20,740 4,542 16,199 2050 18,614 4,076 14,538 2051 16,445 3,601 12,844 2052 14,233 3,117 11,117 2053 11,977 2,623 9,354 2054 9,675 2,119 7,557 2055 7,328 1,605 5,723 2056 4,934 1,080 3,853 2057 2,491 546 1,946

$101,629,772 362,045 $281 **DRAFT 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 proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves and pellet stoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard from 2014 through 2018. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2019. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date. Cumulative Emission Reduction over 20-year stove lifespan Emission Reduction, cumulative per year Annual SnapshotsBaseline 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) 20133 $2,584,750$7,582,146 $1,749,726 20144 $2,584,750$7,582,146 $1,749,726 505 505 0 N/A 505 505 0 20154 $2,584,750$7,582,146 $1,749,726 515 515 0 N/A 1,021 1,021 0 20164 $2,584,750$7,582,146 $1,749,726 526 526 0 N/A 1,546 1,546 0 20174 $2,584,750$7,582,146 $1,749,726 536 536 0 N/A 2,082 2,082 0 20184 $2,584,750$7,582,146 $1,749,726 547 547 0 N/A 2,629 2,629 0 2019 $0 $0 $1,749,726 558 202 356 $4,914 3,187 2,831 356 2020 $0 $0 $1,749,726 569 206 363 $4,818 3,756 3,037 719 2021 $0 $0 $1,749,726 580 210 370 $4,723 4,336 3,247 1,090 2022 $0 $0 $1,749,726 592 214 378 $4,631 4,928 3,461 1,468 2023 $0 $0 $1,749,726 604 218 385 $4,540 5,532 3,679 1,853 2024 $0 $0 $1,749,726 616 223 393 $4,451 6,148 3,902 2,246 2025 $0 $0 $1,749,726 628 227 401 $4,363 6,776 4,129 2,647 2026 $0 $0 $1,749,726 641 232 409 $4,278 7,417 4,361 3,056 2027 $0 $0 $1,749,726 654 236 417 $4,194 8,071 4,597 3,473 2028 $0 $0 $1,749,726 667 241 426 $4,112 8,737 4,838 3,899 2029 $0 $0 $1,749,726 680 246 434 $4,031 9,417 5,084 4,333 2030 $0 $0 $1,749,726 694 251 443 $3,952 10,111 5,335 4,776 2031 $0 $0 $1,749,726 707 256 452 $3,875 10,818 5,591 5,227 2032 $0 $0 $1,749,726 722 261 461 $3,799 11,540 5,852 5,688 2033 $0 $0 $1,749,726 736 266 470 $3,724 12,276 6,118 6,158 2034 $0 $0 $1,749,726 751 272 479 $3,651 12,522 5,885 6,637 2035 $0 $0 $1,749,726 766 277 489 $3,580 12,772 5,646 7,126 2036 $0 $0 $1,749,726 781 283 499 $3,509 13,027 5,403 7,624 2037 $0 $0 $1,749,726 797 288 509 $3,441 13,288 5,155 8,133 2038 $0 $0 $1,749,726 813 294 519 $3,373 13,554 4,902 8,652 2039 12,996 4,700 8,295 2040 12,427 4,495 7,932 2041 11,847 4,285 7,562 2042 11,255 4,071 7,184 2043 10,651 3,852 6,799 2044 10,035 3,629 6,405 2045 9,407 3,402 6,004 2046 8,766 3,170 5,595 2047 8,112 2,934 5,178 2048 7,446 2,693 4,753 2049 6,766 2,447 4,319 2050 6,072 2,196 3,876 2051 5,365 1,940 3,424 2052 4,643 1,679 2,964 2053 3,907 1,413 2,494 2054 3,156 1,142 2,015 2055 2,390 865 1,526 2056 1,609 582 1,027 2057 813 294 519

$45,492,874 96,523 $471

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

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

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For woodstoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Cumulative Emission Reduction over 20-year stove lifespan Nationwide cumulative cost5 **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Wood Stoves**

Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)Baseline 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) 20133 $1,999,632$5,865,753 $1,702,796 20144 $1,999,632$5,865,753 $1,702,796 184 184 0 N/A 184 184 0 20154 $1,999,632$5,865,753 $1,702,796 187 187 0 N/A 371 371 0 20164 $1,999,632$5,865,753 $1,702,796 191 191 0 N/A 563 563 0 20174 $1,999,632$5,865,753 $1,702,796 195 195 0 N/A 758 758 0 20184 $1,999,632$5,865,753 $1,702,796 199 199 0 N/A 957 957 0 2019 $0 $453,909 $1,702,796 203 95 108 $15,771 1,160 1,052 108 2020 $0 $453,909 $1,702,796 207 97 110 $15,462 1,367 1,148 218 2021 $0 $453,909 $1,702,796 211 99 112 $15,159 1,578 1,247 330 2022 $0 $453,909 $1,702,796 215 101 115 $14,861 1,793 1,348 445 2023 $0 $453,909 $1,702,796 220 103 117 $14,570 2,013 1,451 562 2024 $0 $453,909 $1,702,796 224 105 119 $14,284 2,237 1,556 681 2025 $0 $453,909 $1,702,796 229 107 122 $14,004 2,465 1,663 803 2026 $0 $453,909 $1,702,796 233 109 124 $13,730 2,699 1,772 927 2027 $0 $453,909 $1,702,796 238 111 127 $13,460 2,936 1,883 1,053 2028 $0 $453,909 $1,702,796 243 114 129 $13,196 3,179 1,997 1,182 2029 $0 $453,909 $1,702,796 247 116 132 $12,938 3,426 2,112 1,314 2030 $0 $453,909 $1,702,796 252 118 134 $12,684 3,679 2,231 1,448 2031 $0 $453,909 $1,702,796 257 120 137 $12,435 3,936 2,351 1,585 2032 $0 $453,909 $1,702,796 263 123 140 $12,191 4,199 2,474 1,725 2033 $0 $453,909 $1,702,796 268 125 142 $11,952 4,466 2,599 1,867 2034 $0 $453,909 $1,702,796 273 128 145 $11,718 4,556 2,543 2,012 2035 $0 $453,909 $1,702,796 279 130 148 $11,488 4,647 2,486 2,161 2036 $0 $453,909 $1,702,796 284 133 151 $11,263 4,740 2,428 2,312 2037 $0 $453,909 $1,702,796 290 136 154 $11,042 4,835 2,368 2,466 2038 $0 $453,909 $1,702,796 296 138 157 $10,826 4,931 2,308 2,623 2039 4,728 2,213 2,515 2040 4,521 2,116 2,405 2041 4,310 2,017 2,293 2042 4,095 1,916 2,178 2043 3,875 1,814 2,062 2044 3,651 1,709 1,942 2045 3,422 1,602 1,821 2046 3,189 1,493 1,697 2047 2,951 1,381 1,570 2048 2,709 1,268 1,441 2049 2,462 1,152 1,310 2050 2,209 1,034 1,175 2051 1,952 913 1,038 2052 1,689 791 899 2053 1,421 665 756 2054 1,148 537 611 2055 870 407 463 2056 586 274 312 2057 296 138 157

$44,272,694 29,269 $1,513

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. For pellet stoves, estimates conservatively assume that most models already meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 standard during 2014 through 2018. Therefore no emission reductions are estimated until Step 2 in 2019.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** **emissions from Pellet Stoves**

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

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

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline 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) 20133 

### $881,775 $2,586,611 $456,316 20144 

### $881,775 $2,586,611 $456,316 860 246 614 $744 860 246 614 2015 $446,448 $1,309,618 $456,316 877 251 626 $729 1,737 497 1,240 2016 $446,448 $1,309,618 $456,316 895 256 638 $715 2,631 753 1,878 2017 $446,448 $1,309,618 $456,316 912 261 651 $701 3,544 1,014 2,529 2018 $446,448 $1,309,618 $456,316 931 266 664 $687 4,474 1,281 3,193 20194 

### $0 $72,625 $456,316 949 78 872 $524 5,424 1,359 4,065 2020 $0 $72,625 $456,316 968 79 889 $513 6,392 1,438 4,954 2021 $0 $72,625 $456,316 988 81 907 $503 7,379 1,519 5,861 2022 $0 $72,625 $456,316 1,007 82 925 $493 8,387 1,601 6,786 2023 $0 $72,625 $456,316 1,027 84 943 $484 9,414 1,685 7,729 2024 $0 $72,625 $456,316 1,048 86 962 $474 10,462 1,771 8,691 2025 $0 $72,625 $456,316 1,069 88 981 $465 11,531 1,859 9,673 2026 $0 $72,625 $456,316 1,090 89 1,001 $456 12,622 1,948 10,674 2027 $0 $72,625 $456,316 1,112 91 1,021 $447 13,734 2,039 11,695 2028 $0 $72,625 $456,316 1,134 93 1,042 $438 14,868 2,132 12,736 2029 $0 $72,625 $456,316 1,157 95 1,062 $430 16,025 2,227 13,799 2030 $0 $72,625 $456,316 1,180 97 1,084 $421 17,206 2,323 14,882 2031 $0 $72,625 $456,316 1,204 99 1,105 $413 18,410 2,422 15,988 2032 $0 $72,625 $456,316 1,228 101 1,127 $405 19,638 2,522 17,115 2033 $0 $72,625 $456,316 1,253 103 1,150 $397 20,890 2,625 18,265 2034 $0 $72,625 $456,316 1,278 105 1,173 $389 21,308 2,483 18,824 2035 $0 $72,625 $456,316 1,303 107 1,196 $381 21,734 2,339 19,395 2036 $0 $72,625 $456,316 1,329 109 1,220 $374 22,169 2,192 19,977 2037 $0 $72,625 $456,316 1,356 111 1,245 $367 22,612 2,042 20,570 2038 $0 $72,625 $456,316 1,383 113 1,270 $359 23,064 1,888 21,176 2039 22,115 1,811 20,304 2040 21,147 1,731 19,415 2041 20,159 1,651 18,509 2042 19,152 1,568 17,584 2043 18,124 1,484 16,640 2044 17,076 1,398 15,678 2045 16,007 1,311 14,697 2046 14,917 1,221 13,696 2047 13,805 1,130 12,674 2048 12,670 1,037 11,633 2049 11,513 943 10,571 2050 10,333 846 9,487 2051 9,129 747 8,382 2052 7,901 647 7,254 2053 6,649 544 6,104 2054 5,371 440 4,931 2055 4,068 333 3,735 2056 2,739 224 2,514 2057 1,383 113 1,270

$11,864,204 236,254 $50

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** 

### emissions from Single Burn Rate Stoves

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 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 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

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

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $4,829,241$14,166,171$3,392,772 20144 $4,829,241$14,166,171$3,392,772 4,038 825 3,213 $1,056 4,038 825 3,213 2015 $3,740,925$10,973,689$3,392,772 4,119 842 3,277 $1,035 8,157 1,667 6,490 2016 $3,740,925$10,973,689$3,392,772 4,201 858 3,343 $1,015 12,358 2,525 9,833 2017 $3,740,925$10,973,689$3,392,772 4,285 876 3,410 $995 16,643 3,401 13,242 2018 $3,740,925$10,973,689$3,392,772 4,371 893 3,478 $976 21,014 4,294 16,720 20194 $0 $799,249 $3,392,772 4,458 89 4,369 $777 25,472 4,383 21,089 2020 $0 $799,249 $3,392,772 4,547 91 4,456 $761 30,019 4,474 25,545 2021 $0 $799,249 $3,392,772 4,638 93 4,546 $746 34,658 4,567 30,091 2022 $0 $799,249 $3,392,772 4,731 95 4,636 $732 39,389 4,661 34,727 2023 $0 $799,249 $3,392,772 4,826 97 4,729 $717 44,214 4,758 39,457 2024 $0 $799,249 $3,392,772 4,922 98 4,824 $703 49,137 4,856 44,280 2025 $0 $799,249 $3,392,772 5,021 100 4,920 $690 54,157 4,957 49,201 2026 $0 $799,249 $3,392,772 5,121 102 5,019 $676 59,278 5,059 54,219 2027 $0 $799,249 $3,392,772 5,224 104 5,119 $663 64,502 5,164 59,338 2028 $0 $799,249 $3,392,772 5,328 107 5,221 $650 69,830 5,270 64,560 2029 $0 $799,249 $3,392,772 5,435 109 5,326 $637 75,264 5,379 69,886 2030 $0 $799,249 $3,392,772 5,543 111 5,432 $625 80,808 5,490 75,318 2031 $0 $799,249 $3,392,772 5,654 113 5,541 $612 86,462 5,603 80,859 2032 $0 $799,249 $3,392,772 5,767 115 5,652 $600 92,229 5,718 86,511 2033 $0 $799,249 $3,392,772 5,883 118 5,765 $589 98,111 5,836 92,276 2034 $0 $799,249 $3,392,772 6,000 120 5,880 $577 100,074 5,131 94,943 2035 $0 $799,249 $3,392,772 6,120 122 5,998 $566 102,075 4,411 97,664 2036 $0 $799,249 $3,392,772 6,243 125 6,118 $555 104,117 3,678 100,439 2037 $0 $799,249 $3,392,772 6,367 127 6,240 $544 106,199 2,930 103,269 2038 $0 $799,249 $3,392,772 6,495 130 6,365 $533 108,323 2,166 106,156 2039 103,865 2,077 101,787 2040 99,317 1,986 97,331 2041 94,679 1,894 92,785 2042 89,948 1,799 88,149 2043 85,122 1,702 83,420 2044 80,200 1,604 78,596 2045 75,179 1,504 73,676 2046 70,058 1,401 68,657 2047 64,835 1,297 63,538 2048 59,507 1,190 58,317 2049 54,072 1,081 52,991 2050 48,529 971 47,558 2051 42,875 857 42,017 2052 37,108 742 36,365 2053 31,225 625 30,601 2054 25,225 504 24,720 2055 19,105 382 18,723 2056 12,862 257 12,605 2057 6,495 130 6,365

$88,212,079 1,184,357 $74 Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **DRAFT 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 proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. 1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-year model design lifespan used in this analysis.
2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDPpredicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conferenceboard.org/data/globaloutlook.cfm).

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

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton) Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline 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) 20133 

### $2,188,588$6,420,038 $1,171,222 20144 

### $2,188,588$6,420,038 $1,171,222 2,809 702 2,106 $556 2,809 702 2,106 2015 $1,100,272$3,227,556 $1,171,222 2,865 716 2,149 $545 5,673 1,418 4,255 2016 $1,100,272$3,227,556 $1,171,222 2,922 731 2,192 $534 8,595 2,149 6,446 2017 $1,100,272$3,227,556 $1,171,222 2,980 745 2,235 $524 11,576 2,894 8,682 2018 $1,100,272$3,227,556 $1,171,222 3,040 760 2,280 $514 14,616 3,654 10,962 20194 

### $0 $235,073 $1,171,222 3,101 62 3,039 $385 17,717 3,716 14,001 2020 $0 $235,073 $1,171,222 3,163 63 3,100 $378 20,880 3,779 17,100 2021 $0 $235,073 $1,171,222 3,226 65 3,162 $370 24,106 3,844 20,262 2022 $0 $235,073 $1,171,222 3,291 66 3,225 $363 27,396 3,910 23,487 2023 $0 $235,073 $1,171,222 3,356 67 3,289 $356 30,753 3,977 26,776 2024 $0 $235,073 $1,171,222 3,424 68 3,355 $349 34,177 4,045 30,131 2025 $0 $235,073 $1,171,222 3,492 70 3,422 $342 37,669 4,115 33,554 2026 $0 $235,073 $1,171,222 3,562 71 3,491 $336 41,231 4,186 37,044 2027 $0 $235,073 $1,171,222 3,633 73 3,561 $329 44,864 4,259 40,605 2028 $0 $235,073 $1,171,222 3,706 74 3,632 $322 48,570 4,333 44,236 2029 $0 $235,073 $1,171,222 3,780 76 3,704 $316 52,349 4,409 47,941 2030 $0 $235,073 $1,171,222 3,856 77 3,778 $310 56,205 4,486 51,719 2031 $0 $235,073 $1,171,222 3,933 79 3,854 $304 60,138 4,564 55,573 2032 $0 $235,073 $1,171,222 4,011 80 3,931 $298 64,149 4,645 59,504 2033 $0 $235,073 $1,171,222 4,092 82 4,010 $292 68,241 4,726 63,514 2034 $0 $235,073 $1,171,222 4,173 83 4,090 $286 69,605 4,108 65,498 2035 $0 $235,073 $1,171,222 4,257 85 4,172 $281 70,997 3,477 67,521 2036 $0 $235,073 $1,171,222 4,342 87 4,255 $275 72,417 2,833 69,584 2037 $0 $235,073 $1,171,222 4,429 89 4,340 $270 73,866 2,177 71,689 2038 $0 $235,073 $1,171,222 4,517 90 4,427 $265 75,343 1,507 73,836 2039 72,242 1,445 70,797 2040 69,079 1,382 67,698 2041 65,853 1,317 64,536 2042 62,562 1,251 61,311 2043 59,206 1,184 58,022 2044 55,782 1,116 54,667 2045 52,290 1,046 51,244 2046 48,728 975 47,754 2047 45,095 902 44,193 2048 41,389 828 40,562 2049 37,609 752 36,857 2050 33,754 675 33,079 2051 29,821 596 29,225 2052 25,810 516 25,294 2053 21,718 434 21,284 2054 17,545 351 17,194 2055 13,288 266 13,022 2056 8,946 179 8,767 2057 4,517 90 4,427

$30,451,763 823,770 $37

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** 

### emissions from Forced Air Furnaces

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 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 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

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

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per year

### Baseline 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) 20133 

### $2,640,653$7,746,133 $2,221,551 20144 

### $2,640,653$7,746,133 $2,221,551 1,229 123 1,106 $2,008 1,229 123 1,106 2015 $2,640,653$7,746,133 $2,221,551 1,254 125 1,129 $1,968 2,483 248 2,235 2016 $2,640,653$7,746,133 $2,221,551 1,279 128 1,151 $1,930 3,762 376 3,386 2017 $2,640,653$7,746,133 $2,221,551 1,305 130 1,174 $1,892 5,067 507 4,560 2018 $2,640,653$7,746,133 $2,221,551 1,331 133 1,198 $1,855 6,398 640 5,758 20194 

### $0 $564,176 $2,221,551 1,357 27 1,330 $1,670 7,755 667 7,088 2020 $0 $564,176 $2,221,551 1,384 28 1,357 $1,637 9,140 695 8,445 2021 $0 $564,176 $2,221,551 1,412 28 1,384 $1,605 10,552 723 9,829 2022 $0 $564,176 $2,221,551 1,440 29 1,412 $1,574 11,992 752 11,241 2023 $0 $564,176 $2,221,551 1,469 29 1,440 $1,543 13,461 781 12,680 2024 $0 $564,176 $2,221,551 1,499 30 1,469 $1,513 14,960 811 14,149 2025 $0 $564,176 $2,221,551 1,529 31 1,498 $1,483 16,489 842 15,647 2026 $0 $564,176 $2,221,551 1,559 31 1,528 $1,454 18,048 873 17,175 2027 $0 $564,176 $2,221,551 1,590 32 1,559 $1,425 19,638 905 18,734 2028 $0 $564,176 $2,221,551 1,622 32 1,590 $1,397 21,260 937 20,323 2029 $0 $564,176 $2,221,551 1,655 33 1,621 $1,370 22,915 970 21,945 2030 $0 $564,176 $2,221,551 1,688 34 1,654 $1,343 24,603 1,004 23,599 2031 $0 $564,176 $2,221,551 1,721 34 1,687 $1,317 26,324 1,038 25,286 2032 $0 $564,176 $2,221,551 1,756 35 1,721 $1,291 28,080 1,073 27,006 2033 $0 $564,176 $2,221,551 1,791 36 1,755 $1,266 29,871 1,109 28,762 2034 $0 $564,176 $2,221,551 1,827 37 1,790 $1,241 30,468 1,023 29,445 2035 $0 $564,176 $2,221,551 1,863 37 1,826 $1,217 31,078 935 30,143 2036 $0 $564,176 $2,221,551 1,901 38 1,863 $1,193 31,699 845 30,854 2037 $0 $564,176 $2,221,551 1,939 39 1,900 $1,169 32,333 753 31,580 2038 $0 $564,176 $2,221,551 1,977 40 1,938 $1,146 32,980 660 32,320 2039 31,622 632 30,990 2040 30,238 605 29,633 2041 28,826 577 28,249 2042 27,385 548 26,838 2043 25,916 518 25,398 2044 24,418 488 23,929 2045 22,889 458 22,431 2046 21,330 427 20,903 2047 19,739 395 19,345 2048 18,117 362 17,755 2049 16,463 329 16,133 2050 14,775 296 14,480 2051 13,054 261 12,793 2052 11,298 226 11,072 2053 9,507 190 9,317 2054 7,680 154 7,526 2055 5,817 116 5,700 2056 3,916 78 3,838 2057 1,977 40 1,938

$57,760,316 360,587 $160

4

### Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 in 2019.

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **DRAFT Cost Effectiveness (CE) based on annual and cumulative PM 2.5** 

### emissions from Hydronic Heating Systems

1

### Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 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 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
3

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

Capital CostsNationwide

Annual Cost1

### Nationwide

Average Annual Cost Annual Snapshots Emission Reduction, cumulative per yearBaseline 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) 20133 $10,295,398$30,200,681$7,301,610 20144 $10,295,398$30,200,681$7,301,610 5,587 1,760 3,827 $1,908 5,587 1,760 3,827 2015 $8,771,756$25,731,206$7,301,610 5,699 1,795 3,903 $1,871 11,285 3,556 7,730 2016 $8,771,756$25,731,206$7,301,610 5,812 1,831 3,981 $1,834 17,098 5,387 11,711 2017 $8,771,756$25,731,206$7,301,610 5,929 1,868 4,061 $1,798 23,026 7,255 15,771 2018 $8,771,756$25,731,206$7,301,610 6,047 1,905 4,142 $1,763 29,074 9,161 19,913 20194 $0 $1,325,783 $7,301,610 6,168 464 5,705 $1,280 35,242 9,624 25,618 2020 $0 $1,325,783 $7,301,610 6,292 473 5,819 $1,255 41,534 10,097 31,437 2021 $0 $1,325,783 $7,301,610 6,417 482 5,935 $1,230 47,951 10,579 37,372 2022 $0 $1,325,783 $7,301,610 6,546 492 6,054 $1,206 54,497 11,071 43,425 2023 $0 $1,325,783 $7,301,610 6,677 502 6,175 $1,182 61,174 11,573 49,600 2024 $0 $1,325,783 $7,301,610 6,810 512 6,298 $1,159 67,984 12,085 55,899 2025 $0 $1,325,783 $7,301,610 6,946 522 6,424 $1,137 74,930 12,607 62,323 2026 $0 $1,325,783 $7,301,610 7,085 533 6,553 $1,114 82,016 13,140 68,876 2027 $0 $1,325,783 $7,301,610 7,227 543 6,684 $1,092 89,243 13,683 75,560 2028 $0 $1,325,783 $7,301,610 7,372 554 6,818 $1,071 96,614 14,237 82,377 2029 $0 $1,325,783 $7,301,610 7,519 565 6,954 $1,050 104,133 14,802 89,331 2030 $0 $1,325,783 $7,301,610 7,669 576 7,093 $1,029 111,803 15,379 96,424 2031 $0 $1,325,783 $7,301,610 7,823 588 7,235 $1,009 119,626 15,967 103,659 2032 $0 $1,325,783 $7,301,610 7,979 600 7,380 $989 127,605 16,566 111,039 2033 $0 $1,325,783 $7,301,610 8,139 612 7,527 $970 135,744 17,178 118,566 2034 $0 $1,325,783 $7,301,610 8,302 624 7,678 $951 138,459 16,042 122,417 2035 $0 $1,325,783 $7,301,610 8,468 636 7,831 $932 141,228 14,883 126,345 2036 $0 $1,325,783 $7,301,610 8,637 649 7,988 $914 144,052 13,701 130,352 2037 $0 $1,325,783 $7,301,610 8,810 662 8,148 $896 146,933 12,495 134,439 2038 $0 $1,325,783 $7,301,610 8,986 675 8,311 $879 149,872 11,265 138,607 2039 143,704 10,801 132,903 2040 137,412 10,328 127,084 2041 130,995 9,846 121,149 2042 124,449 9,354 115,095 2043 117,772 8,852 108,920 2044 110,962 8,340 102,622 2045 104,016 7,818 96,198 2046 96,930 7,286 89,645 2047 89,703 6,742 82,961 2048 82,332 6,188 76,143 2049 74,812 5,623 69,189 2050 67,143 5,047 62,096 2051 59,320 4,459 54,862 2052 51,341 3,859 47,482 2053 43,202 3,247 39,955 2054 34,900 2,623 32,277 2055 26,433 1,987 24,446 2056 17,796 1,338 16,458 2057 8,986 675 8,311

$189,841,851 1,546,402 $123

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2038. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2038 will be emitting through 2057. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2010 $ and are based on a 6-year amortization period of R&D costs at a 7% interest rate (during 2013-2018 ), plus annual certification and reporting & recordkeeping costs (ongoing through 2038). Years2039 through 2057 are past the 20-year model design lifespan used in this analysis.

2Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2038, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
32013 costs assume manufacturers will begin R&D phase and begin certifying models in anticipation of the 2014 rule compliance date. Emissions in 2013, however, are not included in this analysis because it is prior to the rule compliance date.

4Estimated emissions assume Step 1 standard becomes applicable in 2014 and Step 2 standard in 2019. No emission reductions are estimated to result from woodstoves and pellet stoves until 2019, although emission reductions are estimated for all other devices starting in 2014 . **DRAFT 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 stove lifespan (per ton) Emission Reduction, cumulative per year

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