# 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 Carbon Monoxide 140.8 86,323 0.0662140.8 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Carbon Monoxide 104.4 21,725 0.0509104.4 2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Carbon Monoxide 140.8 108,418 0.1241140.8 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Carbon Monoxide 104.4 40,486 0.1082104.4 2104008400 846,931 1,175,337Woodstove: pellet-fired, general Carbon Monoxide 15.9 9,344 0.0110 15.9 2,206,470 4,668,250Single Burn Rate Stoves Carbon Monoxide 230.8 538,716 0.2442140.8 2104008610 364,560 3,654,153Hydronic heater: outdoor Carbon Monoxide 184 336,182 0.9222 18.4 2104008510 351,023 2,624,115Furnace: indoor, cordwood Carbon Monoxide 184 241,419 0.6878 46 0.0863Baseline 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 82,36784,01585,69587,409 Single Burn Rate Stoves 40,000 25,560 24,538 25,028 25,529 26,03926,56027,09127,633 Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,87686,57488,30590,072 Furnace: indoor, cordwood 41,000 26,199 25,151 25,654 26,167 26,69027,22427,76928,324 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 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 18,72419,09819,480 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) 20133 $5,466,157$16,034,510$3,908,837 20144 $5,466,157$16,034,510$3,908,837 14,689 12,161 2,529 $1,546 14,689 12,161 2,529 20154 $5,030,830$14,757,517$3,908,837 14,983 12,404 2,579 $1,515 29,672 24,564 5,108 20164 $5,030,830$14,757,517$3,908,837 15,283 12,652 2,631 $1,486 44,955 37,216 7,739 20174 $5,030,830$14,757,517$3,908,837 15,588 12,905 2,684 $1,457 60,544 50,121 10,422 20184 $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

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 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) 20133$2,584,750$7,582,146$1,749,726 20144$2,584,750$7,582,146$1,749,726 7,249 7,249 0 N/A 7,249 7,249 0 20154$2,584,750$7,582,146$1,749,726 7,394 7,394 0 N/A 14,644 14,644 0 20164$2,584,750$7,582,146$1,749,726 7,542 7,542 0 N/A 22,186 22,186 0 20174$2,584,750$7,582,146$1,749,726 7,693 7,693 0 N/A 29,879 29,879 0 20184$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

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 CO 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 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) 20133 $1,999,632$5,865,753$1,702,796 20144 $1,999,632$5,865,753$1,702,796 955 955 0 N/A 955 955 0 20154 $1,999,632$5,865,753$1,702,796 974 974 0 N/A 1,929 1,929 0 20164 $1,999,632$5,865,753$1,702,796 994 994 0 N/A 2,923 2,923 0 20174 $1,999,632$5,865,753$1,702,796 1,014 1,014 0 N/A 3,937 3,937 0 20184 $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

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 CO 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 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) 20133 

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

### $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 20194 

### $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). 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 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) 20133 $4,829,241$14,166,171$3,392,772 20144 $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 20194 $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

$88,212,079 7,895,713 $11 Nationwide cumulative cost5 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)**

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 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) 20133 

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

### $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 20194 

### $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). 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 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) 20133 

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

### $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 20194 

### $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). 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 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) 20133$10,295,398$30,200,681$7,301,610 20144$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 20194 $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

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 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