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 $141,667

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

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

Outside Consultants $26,667

Annual 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$10,490

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

an interest rate of 7%. 

Re-tooling1$25,175

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

rate of 7%.

Other Capital Costs1, 2 $51,400

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%. 

Total Indirect Costs (IAC) $87,065

Total Annual Cost $255,399 Annual cost for development of 4 model fireboxes.

Total Annual Cost $63,850 Average 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 

203822013

(Step 1 

compliance) 

2014 2015 2016 2017 2018

(Step 2 

compliance) 

2019

2020 through 

20382

Wood Stoves (R&D)334 125 $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)429 125 $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.)92 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.)93 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

7 For 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

6

 For 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.

1 Nationwide 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.

2

 Since 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.

3

 This 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.

4

For 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.

5

Based 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.

8

 Reporting 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.

9

 Reporting 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 1,226,184 Woodstove: fireplace inserts; EPA certified; non-catalytic Carbon Monoxide 140.8 86,323 0.0662 140.8

2104008230 427,224 416,187 Woodstove: fireplace inserts; EPA certified; catalytic Carbon Monoxide 104.4 21,725 0.0509 104.4

2104008320 873,357 1,540,026 Woodstove: freestanding, EPA certified, non-catalytic Carbon Monoxide 140.8 108,418 0.1241 140.8

2104008330 374,154 775,602 Woodstove: freestanding, EPA certified, catalytic Carbon Monoxide 104.4 40,486 0.1082 104.4

2104008400 846,931 1,175,337 Woodstove: pellet-fired, general Carbon Monoxide 15.9 9,344 0.0110 15.9

2,206,470 4,668,250 Single Burn Rate Stoves Carbon Monoxide 230.8 538,716 0.2442 140.8

2104008610 364,560 3,654,153 Hydronic heater: outdoor Carbon Monoxide 184 336,182 0.9222 18.4

2104008510 351,023 2,624,115 Furnace: indoor, cordwood Carbon Monoxide 184 241,419 0.6878 46

0.0863 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 10,918 6,976 6,697 6,831 6,968 7,107 7,249 7,394 7,542

Single Burn Rate 

Stoves 9,766 6,241 5,991 6,111 6,233 6,358 6,485 6,614 6,747

Pellet Stoves 1,438 919 882 900 918 936 955 974 994

Furnace: indoor, 

cordwood 28,198 18,019 17,298 17,644 17,997 18,357 18,724 19,098 19,480

Hydronic Heating 

Systems 12,343 7,887 7,572 7,723 7,878 8,035 8,196 8,360 8,527

Total 62,663 40,042 38,440 39,209 39,993 40,793 41,609 42,441 43,290

Table 4. Estimated Annual Shipped Units

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

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions 

(tons)

NSPS CO 

Emissions 

(tons)

Emission 

Reduction 

(tons)

2013 3$5,466,157 $16,034,510 $3,908,837

2014 4$5,466,157 $16,034,510 $3,908,837 14,689 12,161 2,529 $1,546 14,689 12,161 2,529

2015 4$5,030,830 $14,757,517 $3,908,837 14,983 12,404 2,579 $1,515 29,672 24,564 5,108

2016 4$5,030,830 $14,757,517 $3,908,837 15,283 12,652 2,631 $1,486 44,955 37,216 7,739

2017 4$5,030,830 $14,757,517 $3,908,837 15,588 12,905 2,684 $1,457 60,544 50,121 10,422

2018 4$5,030,830 $14,757,517 $3,908,837 15,900 13,163 2,737 $1,428 76,444 63,284 13,160

2019 $0 $526,534 $3,908,837 16,218 4,485 11,733 $333 92,662 67,770 24,892

2020 $0 $526,534 $3,908,837 16,543 4,575 11,968 $327 109,205 72,345 36,860

2021 $0 $526,534 $3,908,837 16,873 4,667 12,207 $320 126,078 77,011 49,067

2022 $0 $526,534 $3,908,837 17,211 4,760 12,451 $314 143,289 81,771 61,518

2023 $0 $526,534 $3,908,837 17,555 4,855 12,700 $308 160,844 86,626 74,218

2024 $0 $526,534 $3,908,837 17,906 4,952 12,954 $302 178,750 91,578 87,172

2025 $0 $526,534 $3,908,837 18,264 5,051 13,213 $296 197,014 96,629 100,385

2026 $0 $526,534 $3,908,837 18,630 5,152 13,477 $290 215,644 101,781 113,863

2027 $0 $526,534 $3,908,837 19,002 5,255 13,747 $284 234,646 107,037 127,610

2028 $0 $526,534 $3,908,837 19,382 5,360 14,022 $279 254,028 112,397 141,631

2029 $0 $526,534 $3,908,837 19,770 5,468 14,302 $273 273,798 117,865 155,934

2030 $0 $526,534 $3,908,837 20,165 5,577 14,588 $268 293,964 123,441 170,522

2031 $0 $526,534 $3,908,837 20,569 5,688 14,880 $263 314,532 129,130 185,402

2032 $0 $526,534 $3,908,837 20,980 5,802 15,178 $258 335,512 134,932 200,580

2033 $0 $526,534 $3,908,837 21,400 5,918 15,481 $252 356,912 140,850 216,061

2034 $0 $526,534 $3,908,837 21,828 6,037 15,791 $248 364,050 134,726 229,324

2035 $0 $526,534 $3,908,837 22,264 6,157 16,107 $243 371,331 128,480 242,851

2036 $0 $526,534 $3,908,837 22,709 6,281 16,429 $238 378,758 122,109 256,649

2037 $0 $526,534 $3,908,837 23,164 6,406 16,757 $233 386,333 115,610 270,723

2038 $0 $526,534 $3,908,837 23,627 6,534 17,093 $229 394,059 108,981 285,078

2039 377,841 104,496 273,345

2040 361,299 99,921 261,378

2041 344,425 95,254 249,171

2042 327,214 90,494 236,720

2043 309,659 85,639 224,020

2044 291,753 80,687 211,066

2045 273,489 75,636 197,853

2046 254,859 70,484 184,375

2047 235,857 65,229 170,628

2048 216,475 59,868 156,607

2049 196,705 54,401 142,304

2050 176,540 48,824 127,716

2051 155,971 43,135 112,836

2052 134,991 37,333 97,658

2053 113,591 31,415 82,177

2054 91,764 25,378 66,386

2055 69,500 19,221 50,279

2056 46,790 12,940 33,850

2057 23,627 6,534 17,093

$101,629,772 3,180,539 $32

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

Nationwide cumulative cost5 

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

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). Years 2039 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.conferenceboard.org/data/globaloutlook.cfm). 

4

 Estimated 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)

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
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions 

(tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$2,584,750 $7,582,146 $1,749,726

2014 4

$2,584,750 $7,582,146 $1,749,726 7,249 7,249 0 N/A 7,249 7,249 0

2015 4

$2,584,750 $7,582,146 $1,749,726 7,394 7,394 0 N/A 14,644 14,644 0

2016 4

$2,584,750 $7,582,146 $1,749,726 7,542 7,542 0 N/A 22,186 22,186 0

2017 4

$2,584,750 $7,582,146 $1,749,726 7,693 7,693 0 N/A 29,879 29,879 0

2018 4

$2,584,750 $7,582,146 $1,749,726 7,847 7,847 0 N/A 37,726 37,726 0

2019 $0 $0 $1,749,726 8,004 2,743 5,261 $333 45,730 40,469 5,261

2020 $0 $0 $1,749,726 8,164 2,797 5,367 $326 53,894 43,266 10,628

2021 $0 $0 $1,749,726 8,327 2,853 5,474 $320 62,221 46,120 16,102

2022 $0 $0 $1,749,726 8,494 2,910 5,583 $313 70,715 49,030 21,685

2023 $0 $0 $1,749,726 8,664 2,969 5,695 $307 79,379 51,999 27,380

2024 $0 $0 $1,749,726 8,837 3,028 5,809 $301 88,216 55,027 33,189

2025 $0 $0 $1,749,726 9,014 3,089 5,925 $295 97,230 58,115 39,114

2026 $0 $0 $1,749,726 9,194 3,150 6,044 $290 106,424 61,266 45,158

2027 $0 $0 $1,749,726 9,378 3,213 6,165 $284 115,801 64,479 51,322

2028 $0 $0 $1,749,726 9,565 3,278 6,288 $278 125,367 67,757 57,610

2029 $0 $0 $1,749,726 9,757 3,343 6,414 $273 135,124 71,100 64,024

2030 $0 $0 $1,749,726 9,952 3,410 6,542 $267 145,076 74,510 70,566

2031 $0 $0 $1,749,726 10,151 3,478 6,673 $262 155,226 77,988 77,238

2032 $0 $0 $1,749,726 10,354 3,548 6,806 $257 165,580 81,536 84,044

2033 $0 $0 $1,749,726 10,561 3,619 6,942 $252 176,141 85,155 90,987

2034 $0 $0 $1,749,726 10,772 3,691 7,081 $247 179,664 81,596 98,068

2035 $0 $0 $1,749,726 10,988 3,765 7,223 $242 183,257 77,967 105,290

2036 $0 $0 $1,749,726 11,207 3,840 7,367 $238 186,923 74,265 112,658

2037 $0 $0 $1,749,726 11,432 3,917 7,514 $233 190,661 70,489 120,172

2038 $0 $0 $1,749,726 11,660 3,995 7,665 $228 194,474 66,637 127,837

2039 186,470 63,895 122,576

2040 178,306 61,097 117,209

2041 169,979 58,244 111,735

2042 161,485 55,334 106,152

2043 152,822 52,365 100,457

2044 143,985 49,337 94,648

2045 134,971 46,248 88,723

2046 125,777 43,098 82,679

2047 116,399 39,885 76,514

2048 106,834 36,607 70,227

2049 97,077 33,264 63,813

2050 87,125 29,854 57,271

2051 76,974 26,375 50,599

2052 66,620 22,828 43,792

2053 56,059 19,209 36,850

2054 45,287 15,518 29,769

2055 34,299 11,753 22,546

2056 23,092 7,912 15,179

2057 11,660 3,995 7,665

$45,492,874 1,426,240 $32

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). Years 2039 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.

4

 Estimated 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.

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.

Cumulative Emission Reduction 

Nationwide cumulative cost over 20-year stove lifespan 5 

DRAFT Cost Effectiveness (CE) based on annual and cumulative CO 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)
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions 

(tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction (tons)

2013 3

$1,999,632 $5,865,753 $1,702,796

2014 4

$1,999,632 $5,865,753 $1,702,796 955 955 0 N/A 955 955 0

2015 4

$1,999,632 $5,865,753 $1,702,796 974 974 0 N/A 1,929 1,929 0

2016 4

$1,999,632 $5,865,753 $1,702,796 994 994 0 N/A 2,923 2,923 0

2017 4

$1,999,632 $5,865,753 $1,702,796 1,014 1,014 0 N/A 3,937 3,937 0

2018 4

$1,999,632 $5,865,753 $1,702,796 1,034 1,034 0 N/A 4,971 4,971 0

2019 $0 $453,909 $1,702,796 1,055 494 561 $3,035 6,025 5,464 561

2020 $0 $453,909 $1,702,796 1,076 503 572 $2,976 7,101 5,968 1,133

2021 $0 $453,909 $1,702,796 1,097 513 584 $2,917 8,198 6,481 1,717

2022 $0 $453,909 $1,702,796 1,119 524 595 $2,860 9,317 7,005 2,312

2023 $0 $453,909 $1,702,796 1,141 534 607 $2,804 10,459 7,539 2,920

2024 $0 $453,909 $1,702,796 1,164 545 619 $2,749 11,623 8,084 3,539

2025 $0 $453,909 $1,702,796 1,188 556 632 $2,695 12,810 8,640 4,171

2026 $0 $453,909 $1,702,796 1,211 567 644 $2,642 14,022 9,207 4,815

2027 $0 $453,909 $1,702,796 1,236 578 657 $2,590 15,257 9,785 5,473

2028 $0 $453,909 $1,702,796 1,260 590 670 $2,540 16,518 10,375 6,143

2029 $0 $453,909 $1,702,796 1,285 602 684 $2,490 17,803 10,976 6,827

2030 $0 $453,909 $1,702,796 1,311 614 698 $2,441 19,114 11,590 7,524

2031 $0 $453,909 $1,702,796 1,337 626 712 $2,393 20,452 12,216 8,236

2032 $0 $453,909 $1,702,796 1,364 638 726 $2,346 21,816 12,854 8,962

2033 $0 $453,909 $1,702,796 1,391 651 740 $2,300 23,207 13,505 9,702

2034 $0 $453,909 $1,702,796 1,419 664 755 $2,255 23,672 13,215 10,457

2035 $0 $453,909 $1,702,796 1,448 678 770 $2,211 24,145 12,918 11,227

2036 $0 $453,909 $1,702,796 1,477 691 786 $2,168 24,628 12,615 12,013

2037 $0 $453,909 $1,702,796 1,506 705 801 $2,125 25,121 12,306 12,814

2038 $0 $453,909 $1,702,796 1,536 719 817 $2,083 25,623 11,992 13,631

2039 24,568 11,498 13,070

2040 23,493 10,995 12,498

2041 22,396 10,481 11,914

2042 21,276 9,957 11,319

2043 20,135 9,423 10,712

2044 18,971 8,878 10,092

2045 17,783 8,322 9,461

2046 16,572 7,756 8,816

2047 15,336 7,177 8,159

2048 14,076 6,587 7,488

2049 12,790 5,986 6,804

2050 11,479 5,372 6,107

2051 10,142 4,746 5,395

2052 8,778 4,108 4,670

2053 7,386 3,457 3,929

2054 5,967 2,792 3,174

2055 4,519 2,115 2,404

2056 3,042 1,424 1,619

2057 1,536 719 817

$44,272,694 152,082 $291

4

 Estimated 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.

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 CO emissions from Pellet 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). Years 2039 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions (tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction (tons)

2013 3$881,775 $2,586,611 $456,316

2014 4$881,775 $2,586,611 $456,316 6,485 3,956 2,529 $180 6,485 3,956 2,529

2015 $446,448 $1,309,618 $456,316 6,614 4,035 2,579 $177 13,099 7,991 5,108

2016 $446,448 $1,309,618 $456,316 6,747 4,116 2,631 $173 19,846 12,107 7,739

2017 $446,448 $1,309,618 $456,316 6,882 4,198 2,684 $170 26,728 16,305 10,422

2018 $446,448 $1,309,618 $456,316 7,019 4,282 2,737 $167 33,747 20,587 13,160

2019 4$0 $72,625 $456,316 7,160 1,249 5,911 $77 40,907 21,837 19,070

2020 $0 $72,625 $456,316 7,303 1,274 6,029 $76 48,210 23,111 25,099

2021 $0 $72,625 $456,316 7,449 1,300 6,149 $74 55,659 24,410 31,248

2022 $0 $72,625 $456,316 7,598 1,326 6,272 $73 63,257 25,736 37,520

2023 $0 $72,625 $456,316 7,750 1,352 6,398 $71 71,006 27,088 43,918

2024 $0 $72,625 $456,316 7,905 1,379 6,526 $70 78,911 28,467 50,444

2025 $0 $72,625 $456,316 8,063 1,407 6,656 $69 86,974 29,874 57,100

2026 $0 $72,625 $456,316 8,224 1,435 6,789 $67 95,199 31,309 63,889

2027 $0 $72,625 $456,316 8,389 1,464 6,925 $66 103,587 32,773 70,815

2028 $0 $72,625 $456,316 8,557 1,493 7,064 $65 112,144 34,266 77,878

2029 $0 $72,625 $456,316 8,728 1,523 7,205 $63 120,872 35,788 85,083

2030 $0 $72,625 $456,316 8,902 1,553 7,349 $62 129,774 37,342 92,432

2031 $0 $72,625 $456,316 9,080 1,584 7,496 $61 138,854 38,926 99,928

2032 $0 $72,625 $456,316 9,262 1,616 7,646 $60 148,116 40,542 107,574

2033 $0 $72,625 $456,316 9,447 1,648 7,799 $59 157,563 42,190 115,373

2034 $0 $72,625 $456,316 9,636 1,681 7,955 $57 160,714 39,915 120,799

2035 $0 $72,625 $456,316 9,829 1,715 8,114 $56 163,928 37,595 126,333

2036 $0 $72,625 $456,316 10,025 1,749 8,276 $55 167,207 35,228 131,979

2037 $0 $72,625 $456,316 10,226 1,784 8,442 $54 170,551 32,814 137,737

2038 $0 $72,625 $456,316 10,430 1,820 8,611 $53 173,962 30,352 143,610

2039 166,802 29,103 137,700

2040 159,500 27,829 131,671

2041 152,051 26,529 125,522

2042 144,453 25,203 119,249

2043 136,703 23,851 112,852

2044 128,798 22,472 106,326

2045 120,735 21,065 99,670

2046 112,511 19,630 92,880

2047 104,122 18,167 85,955

2048 95,565 16,674 78,892

2049 86,838 15,151 71,687

2050 77,935 13,598 64,338

2051 68,855 12,014 56,842

2052 59,593 10,398 49,196

2053 50,146 8,749 41,397

2054 40,510 7,068 33,442

2055 30,682 5,353 25,328

2056 20,656 3,604 17,052

2057 10,430 1,820 8,611

$11,864,204 1,602,218 $7

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 CO 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). Years 2039 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions 

(tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

$4,829,241 $14,166,171 $3,392,772

2014 4

$4,829,241 $14,166,171 $3,392,772 26,920 5,501 21,419 $158 26,920 5,501 21,419

2015 $3,740,925 $10,973,689 $3,392,772 27,458 5,611 21,847 $155 54,378 11,111 43,267

2016 $3,740,925 $10,973,689 $3,392,772 28,007 5,723 22,284 $152 82,385 16,834 65,551

2017 $3,740,925 $10,973,689 $3,392,772 28,567 5,837 22,730 $149 110,952 22,671 88,281

2018 $3,740,925 $10,973,689 $3,392,772 29,139 5,954 23,185 $146 140,091 28,625 111,466

2019 4

$0 $799,249 $3,392,772 29,721 594 29,127 $116 169,812 29,219 140,593

2020 $0 $799,249 $3,392,772 30,316 606 29,710 $114 200,128 29,826 170,302

2021 $0 $799,249 $3,392,772 30,922 618 30,304 $112 231,050 30,444 200,606

2022 $0 $799,249 $3,392,772 31,541 631 30,910 $110 262,591 31,075 231,516

2023 $0 $799,249 $3,392,772 32,171 643 31,528 $108 294,762 31,718 263,044

2024 $0 $799,249 $3,392,772 32,815 656 32,159 $106 327,577 32,375 295,202

2025 $0 $799,249 $3,392,772 33,471 669 32,802 $103 361,048 33,044 328,004

2026 $0 $799,249 $3,392,772 34,141 683 33,458 $101 395,189 33,727 361,462

2027 $0 $799,249 $3,392,772 34,823 696 34,127 $99 430,012 34,423 395,589

2028 $0 $799,249 $3,392,772 35,520 710 34,809 $97 465,532 35,134 430,398

2029 $0 $799,249 $3,392,772 36,230 725 35,506 $96 501,762 35,858 465,904

2030 $0 $799,249 $3,392,772 36,955 739 36,216 $94 538,717 36,597 502,120

2031 $0 $799,249 $3,392,772 37,694 754 36,940 $92 576,411 37,351 539,060

2032 $0 $799,249 $3,392,772 38,448 769 37,679 $90 614,859 38,120 576,739

2033 $0 $799,249 $3,392,772 39,217 784 38,432 $88 654,076 38,905 615,171

2034 $0 $799,249 $3,392,772 40,001 800 39,201 $87 667,157 34,204 632,953

2035 $0 $799,249 $3,392,772 40,801 816 39,985 $85 680,500 29,410 651,091

2036 $0 $799,249 $3,392,772 41,617 832 40,785 $83 694,110 24,519 669,591

2037 $0 $799,249 $3,392,772 42,450 849 41,601 $82 707,993 19,531 688,462

2038 $0 $799,249 $3,392,772 43,298 866 42,433 $80 722,152 14,443 707,709

2039 692,431 13,849 678,582

2040 662,115 13,242 648,873

2041 631,193 12,624 618,569

2042 599,652 11,993 587,659

2043 567,481 11,350 556,131

2044 534,666 10,693 523,973

2045 501,195 10,024 491,171

2046 467,054 9,341 457,713

2047 432,231 8,645 423,586

2048 396,711 7,934 388,777

2049 360,481 7,210 353,271

2050 323,526 6,471 317,055

2051 285,832 5,717 280,115

2052 247,384 4,948 242,437

2053 208,167 4,163 204,004

2054 168,166 3,363 164,803

2055 127,365 2,547 124,818

2056 85,748 1,715 84,033

2057 43,298 866 42,433

Nationwide cumulative cost $88,212,079 7,895,713 $11 5 

Cumulative Emission Reduction 

over 20-year stove lifespan 

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

5

 The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D re-design to meet the 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.

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). Years 2039 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.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 and Step 2 standard in 2019. 

CE based on total 

cost & cumulative 

emission reduction 

over 20-year stove 

Year lifespan (per ton)

Annual 

Capital Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline CO 

Emissions2 (tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions (tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

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

2014 4

$2,188,588 $6,420,038 $1,171,222 18,724 4,681 14,043 $83 18,724 4,681 14,043

2015 $1,100,272 $3,227,556 $1,171,222 19,098 4,775 14,324 $82 37,822 9,455 28,366

2016 $1,100,272 $3,227,556 $1,171,222 19,480 4,870 14,610 $80 57,302 14,326 42,977

2017 $1,100,272 $3,227,556 $1,171,222 19,870 4,967 14,902 $79 77,172 19,293 57,879

2018 $1,100,272 $3,227,556 $1,171,222 20,267 5,067 15,200 $77 97,439 24,360 73,079

2019 4

$0 $235,073 $1,171,222 20,672 413 20,259 $58 118,111 24,773 93,338

2020 $0 $235,073 $1,171,222 21,086 422 20,664 $57 139,197 25,195 114,002

2021 $0 $235,073 $1,171,222 21,508 430 21,078 $56 160,705 25,625 135,080

2022 $0 $235,073 $1,171,222 21,938 439 21,499 $54 182,643 26,064 156,579

2023 $0 $235,073 $1,171,222 22,377 448 21,929 $53 205,019 26,511 178,508

2024 $0 $235,073 $1,171,222 22,824 456 22,368 $52 227,843 26,968 200,876

2025 $0 $235,073 $1,171,222 23,281 466 22,815 $51 251,124 27,433 223,691

2026 $0 $235,073 $1,171,222 23,746 475 23,271 $50 274,870 27,908 246,962

2027 $0 $235,073 $1,171,222 24,221 484 23,737 $49 299,091 28,393 270,699

2028 $0 $235,073 $1,171,222 24,706 494 24,211 $48 323,797 28,887 294,910

2029 $0 $235,073 $1,171,222 25,200 504 24,696 $47 348,997 29,391 319,606

2030 $0 $235,073 $1,171,222 25,704 514 25,190 $46 374,700 29,905 344,795

2031 $0 $235,073 $1,171,222 26,218 524 25,693 $46 400,918 30,429 370,489

2032 $0 $235,073 $1,171,222 26,742 535 26,207 $45 427,660 30,964 396,696

2033 $0 $235,073 $1,171,222 27,277 546 26,731 $44 454,937 31,510 423,427

2034 $0 $235,073 $1,171,222 27,822 556 27,266 $43 464,036 27,385 436,650

2035 $0 $235,073 $1,171,222 28,379 568 27,811 $42 473,316 23,178 450,138

2036 $0 $235,073 $1,171,222 28,946 579 28,368 $41 482,783 18,887 463,895

2037 $0 $235,073 $1,171,222 29,525 591 28,935 $40 492,438 14,510 477,928

2038 $0 $235,073 $1,171,222 30,116 602 29,514 $40 502,287 10,046 492,241

2039 481,615 9,632 471,982

2040 460,529 9,211 451,318

2041 439,021 8,780 430,241

2042 417,083 8,342 408,741

2043 394,707 7,894 386,812

2044 371,882 7,438 364,445

2045 348,602 6,972 341,630

2046 324,856 6,497 318,359

2047 300,635 6,013 294,622

2048 275,929 5,519 270,410

2049 250,729 5,015 245,715

2050 225,026 4,501 220,525

2051 198,808 3,976 194,832

2052 172,066 3,441 168,625

2053 144,789 2,896 141,893

2054 116,967 2,339 114,627

2055 88,588 1,772 86,816

2056 59,641 1,193 58,448

2057 30,116 602 29,514

$30,451,763 5,491,797 $6

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 CO 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). Years 2039 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average Annual 

Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions (tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3

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

2014 4

$2,640,653 $7,746,133 $2,221,551 8,196 820 7,376 $301 8,196 820 7,376

2015 $2,640,653 $7,746,133 $2,221,551 8,360 836 7,524 $295 16,556 1,656 14,900

2016 $2,640,653 $7,746,133 $2,221,551 8,527 853 7,674 $289 25,083 2,508 22,574

2017 $2,640,653 $7,746,133 $2,221,551 8,698 870 7,828 $284 33,780 3,378 30,402

2018 $2,640,653 $7,746,133 $2,221,551 8,872 887 7,984 $278 42,652 4,265 38,387

2019 4

$0 $564,176 $2,221,551 9,049 181 8,868 $251 51,701 4,446 47,255

2020 $0 $564,176 $2,221,551 9,230 185 9,045 $246 60,931 4,631 56,300

2021 $0 $564,176 $2,221,551 9,415 188 9,226 $241 70,345 4,819 65,526

2022 $0 $564,176 $2,221,551 9,603 192 9,411 $236 79,948 5,011 74,937

2023 $0 $564,176 $2,221,551 9,795 196 9,599 $231 89,743 5,207 84,536

2024 $0 $564,176 $2,221,551 9,991 200 9,791 $227 99,734 5,407 94,327

2025 $0 $564,176 $2,221,551 10,191 204 9,987 $222 109,924 5,611 104,314

2026 $0 $564,176 $2,221,551 10,394 208 10,186 $218 120,319 5,819 114,500

2027 $0 $564,176 $2,221,551 10,602 212 10,390 $214 130,921 6,031 124,890

2028 $0 $564,176 $2,221,551 10,814 216 10,598 $210 141,735 6,247 135,488

2029 $0 $564,176 $2,221,551 11,031 221 10,810 $206 152,766 6,467 146,298

2030 $0 $564,176 $2,221,551 11,251 225 11,026 $201 164,017 6,692 157,324

2031 $0 $564,176 $2,221,551 11,476 230 11,247 $198 175,493 6,922 168,571

2032 $0 $564,176 $2,221,551 11,706 234 11,472 $194 187,199 7,156 180,043

2033 $0 $564,176 $2,221,551 11,940 239 11,701 $190 199,139 7,395 191,744

2034 $0 $564,176 $2,221,551 12,179 244 11,935 $186 203,122 6,819 196,303

2035 $0 $564,176 $2,221,551 12,422 248 12,174 $182 207,184 6,231 200,953

2036 $0 $564,176 $2,221,551 12,671 253 12,417 $179 211,328 5,632 205,696

2037 $0 $564,176 $2,221,551 12,924 258 12,666 $175 215,554 5,021 210,533

2038 $0 $564,176 $2,221,551 13,183 264 12,919 $172 219,865 4,397 215,468

2039 210,816 4,216 206,600

2040 201,587 4,032 197,555

2041 192,172 3,843 188,329

2042 182,569 3,651 178,918

2043 172,774 3,455 169,319

2044 162,784 3,256 159,528

2045 152,593 3,052 149,541

2046 142,199 2,844 139,355

2047 131,596 2,632 128,964

2048 120,782 2,416 118,366

2049 109,751 2,195 107,556

2050 98,500 1,970 96,530

2051 87,024 1,740 85,283

2052 75,318 1,506 73,812

2053 63,378 1,268 62,111

2054 51,200 1,024 50,176

2055 38,777 776 38,002

2056 26,107 522 25,585

2057 13,183 264 12,919

$57,760,316 2,403,916 $24

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 CO 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). Years 2039 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 Costs

Nationwide 

Annual Cost1 

Nationwide 

Average 

Annual Cost 

Annual Snapshots Emission Reduction, cumulative per year
Baseline CO 

Emissions2 

(tons)

NSPS CO 

Emissions2 

(tons)

Emission 

Reduction 

(tons)

CE based on 

nationwide 

average annual 

cost (per ton)

Baseline CO 

Emissions (tons)

NSPS CO 

Emissions (tons)

Emission 

Reduction 

(tons)

2013 3$10,295,398 $30,200,681 $7,301,610

2014 4$10,295,398 $30,200,681 $7,301,610 41,609 17,661 23,948 $305 41,609 17,661 23,948

2015 $8,771,756 $25,731,206 $7,301,610 42,441 18,014 24,427 $299 84,050 35,675 48,375

2016 $8,771,756 $25,731,206 $7,301,610 43,290 18,375 24,915 $293 127,340 54,050 73,290

2017 $8,771,756 $25,731,206 $7,301,610 44,156 18,742 25,414 $287 171,496 72,792 98,704

2018 $8,771,756 $25,731,206 $7,301,610 45,039 19,117 25,922 $282 216,535 91,909 124,625

2019 4$0 $1,325,783 $7,301,610 45,940 5,080 40,860 $179 262,474 96,989 165,485

2020 $0 $1,325,783 $7,301,610 46,858 5,181 41,677 $175 309,333 102,170 207,162

2021 $0 $1,325,783 $7,301,610 47,796 5,285 42,511 $172 357,128 107,455 249,673

2022 $0 $1,325,783 $7,301,610 48,751 5,391 43,361 $168 405,880 112,846 293,034

2023 $0 $1,325,783 $7,301,610 49,727 5,498 44,228 $165 455,606 118,344 337,262

2024 $0 $1,325,783 $7,301,610 50,721 5,608 45,113 $162 506,327 123,953 382,374

2025 $0 $1,325,783 $7,301,610 51,735 5,721 46,015 $159 558,063 129,673 428,389

2026 $0 $1,325,783 $7,301,610 52,770 5,835 46,935 $156 610,833 135,508 475,325

2027 $0 $1,325,783 $7,301,610 53,826 5,952 47,874 $153 664,658 141,460 523,198

2028 $0 $1,325,783 $7,301,610 54,902 6,071 48,831 $150 719,560 147,531 572,030

2029 $0 $1,325,783 $7,301,610 56,000 6,192 49,808 $147 775,561 153,723 621,838

2030 $0 $1,325,783 $7,301,610 57,120 6,316 50,804 $144 832,681 160,039 672,642

2031 $0 $1,325,783 $7,301,610 58,263 6,442 51,820 $141 890,943 166,481 724,462

2032 $0 $1,325,783 $7,301,610 59,428 6,571 52,857 $138 950,371 173,052 777,319

2033 $0 $1,325,783 $7,301,610 60,616 6,703 53,914 $135 1,010,987 179,755 831,232

2034 $0 $1,325,783 $7,301,610 61,829 6,837 54,992 $133 1,031,207 168,931 862,277

2035 $0 $1,325,783 $7,301,610 63,065 6,973 56,092 $130 1,051,831 157,890 893,942

2036 $0 $1,325,783 $7,301,610 64,327 7,113 57,214 $128 1,072,868 146,628 926,240

2037 $0 $1,325,783 $7,301,610 65,613 7,255 58,358 $125 1,094,325 135,141 959,184

2038 $0 $1,325,783 $7,301,610 66,925 7,400 59,525 $123 1,116,212 123,424 992,788

2039 1,070,272 118,344 951,928

2040 1,023,414 113,163 910,251

2041 975,618 107,878 867,740

2042 926,867 102,487 824,379

2043 877,140 96,989 780,151

2044 826,419 91,381 735,039

2045 774,684 85,660 689,024

2046 721,913 79,825 642,089

2047 668,088 73,873 594,215

2048 613,186 67,802 545,383

2049 557,186 61,610 495,575

2050 500,066 55,294 444,771

2051 441,803 48,852 392,951

2052 382,375 42,281 340,094

2053 321,759 35,578 286,181

2054 259,930 28,742 231,189

2055 196,865 21,768 175,097

2056 132,538 14,655 117,883

2057 66,925 7,400 59,525

$189,841,851 11,076,253 $17

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.

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 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). Years 2039 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.

4

 Estimated 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 CO 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