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

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

Operator labor $141,667

Outside Consultants $26,667
**Total Direct Costs (DC)** $168,333
**Indirect Annual Costs (IAC)**

Laboratory Equipment1, 2 

# $9,230
Re-tooling1 

# $22,152

Other Capital Costs1, 3 

# $45,226
**Total Indirect Costs (IAC)** $76,608 **Round One Total Annual Cost**  $244,941 **Total Annual Cost** $61,235

0.31 Note: Fraction that Capital Cost is of Total Cost = 3

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

# It is assumed that the same lab equipment can be used for round two R&D, so the round two costs exclude the lab equipment cost.

# DRAFT Residential Wood Heating Appliances NSPS Annual Cost Calculation

**Round Two 6- year R&D**  **Period**

Annual salary cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $141,667 Annual outside consultant cost from Table 3 of the memorandum "Unit Cost Estimates of Residential Wood Heating Appliances", spread over 6 years. $26,667
$168,333

The laboratory equipment cost of $50,000 was amortized over 6 years at an interest rate of 3%. $0 The re-tooling cost of $120,000 was amortized over 6 years at an interest rate of 3%. $22,152
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 3%. $45,226
$67,378 **Round Two 2**  

# Annual cost for development of 4 model fireboxes. $235,711 Average annual cost per firebox model. $58,928

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 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 .

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

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

2013 Wood Stoves (R&D)3 

# 34 125 $213,873 Pellet Stoves (R&D, R&R)4, 8 

# 29 125 $191,793 Pellet Stoves (certification)4 

# 29 125 $2,586 Single Burn Rate Stoves (R&D, R&R, cert.)5, 6, 8 

# 3 20 $827,346

Forced Air Furnaces (R&D, R&R, cert.)5, 6, 8 

# 7 50 $879,801 Hydronic Heating Systems (R&D, R&R, cert.)6, 8 

# 30 120 $247,747

MH - large companies (R&D, R&R, cert.)9 

# 2 4 $124,940 MH - large companies (R&R, cert.)9 

# 3 9 $9,704 MH - large companies (R&R, software cert.)7, 9 

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

# 42 85 $3,852

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. Appliance Type

8

# Reporting and recordkeeping costs (R&R) are based on the annual average costs derived from the ICR and are conservative estimates of 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. 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 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. 1

# Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

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 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing 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 conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013.

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 2017 Step 2 and 2022 Step 3 standards.

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.# Manufacturers # ModelsAverage Annual Cost per Manufacturer based on initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing

QQQQ: Central Heaters

RRRR: Masonry Heaters AAA: Room Heaters NSPS Subpart

# Table 9. DRAFT Average Annual Cost per Manufacturer & Nationwide Annual Costs during two R&D periods (2013-2018 and 2017-2022) and through model lifespan (2014-2041)

(Step 1 compliance) 2014 2015 2016 (Step 2 compliance) 2017 2018 2019 2020 $213,873 $213,873 $213,873 $378,525 $378,525 $164,651 $164,651 $191,793 $191,793 $191,793 $334,033 $334,033 $149,271 $149,271 $2,586 $2,586 $2,586 $2,586 $2,586 $3,793 $3,793 $827,346 $419,111 $419,111 $733,393 $733,393 $327,824 $327,824
$879,801 $442,406 $442,406 $779,136 $779,136 $347,455 $347,455 $247,747 $247,747 $247,747 $436,316 $436,316 $194,575 $194,575
$124,940 $124,940 $124,940 $124,940 $124,940 $6,469 $6,469 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $9,704 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802 $2,802

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. 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. For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS. 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. This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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 2017 Step 2 and 2022 Step 3 standards.

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 initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing certification costs (through 2041)

# 2021 (Step 3 compliance) 2022 2023

through 20412 

# 2013 2014 2015 2016 2017 $164,651 $164,651 $0 7,271,695 7,271,695 7,271,695 7,271,69512,869,841 $149,271 $149,271 $7,031 5,562,000 5,562,000 5,562,000 5,562,000 9,686,950 $3,793 $3,793 $8,621 75,000 75,000 75,000 75,000 75,000 $327,824 $327,824$24,208 2,482,038 2,482,038 1,257,332 1,257,332 2,200,178 15,390,73315,390,73314,166,02614,166,02624,831,968 $347,455 $347,455$33,582 6,158,606 6,158,606 3,096,839 3,096,839 5,453,954 $194,575 $194,575$18,806 7,432,415 7,432,415 7,432,415 7,432,41513,089,489 $13,591,020$13,591,020$10,529,254$10,529,254$18,543,442 $6,469 $6,469 $6,469 $249,880 $249,880 $249,880 $249,880 $249,880 $9,704 $9,704 $9,704 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328$10,328 $11,378 $10,328 $10,328 $10,328 $10,328 $2,802 $2,802 $2,802 $161,788 $117,688 $117,688 $117,688 $117,688 $452,158 $407,008 $407,008 $407,008 $407,008
$29,433,911$29,388,761$25,102,289$25,102,289$43,782,419

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
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 For single burn rate stoves, forced air furnaces, and hydronic heating systems, the analysis conservatively assumes that only a small percentage meet Step 3 so that approximately 100% of the models undergo re-design in round one, and 80% require another round of R&D to meet Step 3. The R&D budget includes certification costs. Nationwide Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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

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 initial 6-year R&D round (2013-2018) and second R&D round (2017-2022) to meet Step 3 level with ongoing Nationwide Annual Costs

# 2018 2019 2020 2021 2022 2023 through 20412 

# 12,869,841 5,598,146 5,598,146 5,598,146 5,598,146 $0 9,686,950 4,328,859 4,328,859 4,328,859 4,328,859 $203,909 75,000 110,000 110,000 110,000 110,000 $250,000 2,200,178 983,471 983,471 983,471 983,471 $72,625 24,831,96811,020,47611,020,47611,020,47611,020,476 $526,534 5,453,954 2,432,187 2,432,187 2,432,187 2,432,187 $235,073 13,089,489 5,837,250 5,837,250 5,837,250 5,837,250 $564,176 $18,543,442$8,269,437$8,269,437$8,269,437$8,269,437 $799,249 $249,880 $12,939 $12,939 $12,939 $12,939 $12,939 $29,112 $29,112 $29,112 $29,112 $29,112 $29,112 $10,328 $10,328 $10,328 $10,328 $10,328 $10,328 $117,688 $117,688 $117,688 $117,688 $117,688 $117,688 $407,008 $170,067 $170,067 $170,067 $170,067 $170,067
$43,782,419$19,459,980$19,459,980$19,459,980$19,459,980$1,495,850

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 Annual Cost assumes R&D investment is amortized over 6 years (round one from 2013 through 2018 and round two from 2017 through 2022). Ongoing certification costs are incurred through 2041 (based on a model brought to market in 2022 with a lifespan of 20 years), except for woodstoves which already incur certification costs under the existing NSPS.

This analysis considers additional costs resulting from the proposed NSPS. For wood stoves, the analysis conservatively assumes that 5% meet Step 3 already so that 95% of the models will undergo re-design in round one, and 80% of those 95% will require another round of R&D to meet the Step 3 level. The costs exclude the ongoing certification costs and ongoing reporting and recordkeeping costs incurred by wood stove manufacturers

For pellet stoves, the analysis conservatively assumes that 30% meet Step 3 already so that 70% of models undergo re-design in round one, and 80% of those 70% require another round of R&D to meet Step 3. The R&D budget includes certification costs. The analysis also assumes that the 30% of the pellet stove models which already meet Step 3 will certify in an ongoing basis starting in 2013. 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 Nationwide Annual Costs1

# Period Nationwide Cost of the Rule Year 2022 $19,459,980 Year 2023 & following $1,495,850

Cumulative (2013 through 2033) $302,853,163

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

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

**Tons/appl Step 1** 

**Emission Factor**  2104008220 1,303,142 1,226,184Woodstove: fireplace inserts; EPA certified; non-catalytic Carbon Monoxide 140.8 86,323 0.0662 140.8 2104008230 427,224 416,187Woodstove: fireplace inserts; EPA certified; catalytic Carbon Monoxide 104.4 21,725 0.0509 104.4 2104008320 873,357 1,540,026Woodstove: freestanding, EPA certified, non-catalytic Carbon Monoxide 140.8 108,418 0.1241 140.8 2104008330 374,154 775,602Woodstove: freestanding, EPA certified, catalytic Carbon Monoxide 104.4 40,486 0.1082 104.4 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 0.2442 140.8 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 82,367 84,015 85,69587,409 Single Burn Rate Stoves 40,000 25,560 24,538 25,028 25,529 26,039 26,560 27,09127,633 Pellet Stoves 130,381 83,313 79,981 81,581 83,212 84,876 86,574 88,30590,072 Furnace: indoor, cordwood 41,000 26,199 25,151 25,654 26,167 26,690 27,224 27,76928,324 Hydronic Heating Systems 13,385 8,553 8,211 8,375 8,543 8,713 8,888 9,065 9,247

**2008 2009**  **2010 2011**  **2012 2013**  **2014 2015**  **2016** Wood Stoves 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 19,09819,480 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 $4,813,613$15,390,733$5,615,983 20144 $4,813,613$15,390,733$5,615,983 14,689 12,161 2,529 $2,221 14,689 12,161 2,529 20154 $4,430,573$14,166,026$5,615,983 14,983 12,404 2,579 $2,177 29,672 24,564 5,108 20164 $4,430,573$14,166,026$5,615,983 15,283 12,652 2,631 $2,135 44,955 37,216 7,739 2017 $7,766,459$24,831,968$5,615,983 15,588 8,291 7,298 $770 60,544 45,507 15,037 2018 $7,766,459$24,831,968$5,615,983 15,900 8,456 7,444 $754 76,444 53,963 22,480 2019 $3,446,770$11,020,476$5,615,983 16,218 8,626 7,593 $740 92,662 62,589 30,073 2020 $3,446,770$11,020,476$5,615,983 16,543 8,798 7,744 $725 109,205 71,387 37,818 2021 $3,446,770$11,020,476$5,615,983 16,873 8,974 7,899 $711 126,078 80,361 45,717 2022 $3,446,770$11,020,476$5,615,983 17,211 4,760 12,451 $451 143,289 85,121 58,168 2023 $0 $526,534 $5,615,983 17,555 4,855 12,700 $442 160,844 89,976 70,868 2024 $0 $526,534 $5,615,983 17,906 4,952 12,954 $434 178,750 94,928 83,822 2025 $0 $526,534 $5,615,983 18,264 5,051 13,213 $425 197,014 99,979 97,035 2026 $0 $526,534 $5,615,983 18,630 5,152 13,477 $417 215,644 105,131 110,513 2027 $0 $526,534 $5,615,983 19,002 5,255 13,747 $409 234,646 110,387 124,260 2028 $0 $526,534 $5,615,983 19,382 5,360 14,022 $401 254,028 115,747 138,281 2029 $0 $526,534 $5,615,983 19,770 5,468 14,302 $393 273,798 121,215 152,584 2030 $0 $526,534 $5,615,983 20,165 5,577 14,588 $385 293,964 126,792 167,172 2031 $0 $526,534 $5,615,983 20,569 5,688 14,880 $377 314,532 132,480 182,052 2032 $0 $526,534 $5,615,983 20,980 5,802 15,178 $370 335,512 138,282 197,230 2033 $0 $526,534 $5,615,983 21,400 5,918 15,481 $363 356,912 144,200 212,711 2034 $0 $526,534 $5,615,983 21,828 6,037 15,791 $356 364,050 138,076 225,973 2035 $0 $526,534 $5,615,983 22,264 6,157 16,107 $349 371,331 131,830 239,501 2036 $0 $526,534 $5,615,983 22,709 6,281 16,429 $342 378,758 125,459 253,299 2037 $0 $526,534 $5,615,983 23,164 6,406 16,757 $335 386,333 123,574 262,759 2038 $0 $526,534 $5,615,983 23,627 6,534 17,093 $329 394,059 121,652 272,407 2039 $0 $526,534 $5,615,983 24,099 6,665 17,434 $322 401,941 119,691 282,249 2040 $0 $526,534 $5,615,983 24,581 6,798 17,783 $316 409,979 117,691 292,288 2041 $0 $526,534 $5,615,983 25,073 6,934 18,139 $310 418,179 115,652 302,527 2042 400,968 110,892 290,076 2043 383,413 106,037 277,376 2044 365,507 101,085 264,422 2045 347,243 96,033 251,209 2046 328,613 90,881 237,732 2047 309,611 85,626 223,985 2048 290,228 80,266 209,963 2049 270,459 74,798 195,661 2050 250,293 69,221 181,072 2051 229,725 63,533 166,192 2052 208,745 57,730 151,014 2053 187,345 51,812 135,533 2054 165,518 45,776 119,742 2055 143,254 39,618 103,635 2056 120,544 33,338 87,206 2057 97,381 26,932 70,449 2058 73,754 20,397 53,356 2059 49,654 13,732 35,922 2060 25,073 6,934 18,139

$162,863,508 3,375,214 $48 **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 round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves and pellet stoves, estimates conservatively assume that most models meet Step 1 and that manufacturers will certify and sell existing models meeting Step 1 from 2014 through 2016. Therefore no emission reductions are estimated to result from woodstoves and pellet stoves until Step 2 in 2017. 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 $2,274,299$7,271,695 $2,662,726 20144 $2,274,299$7,271,695 $2,662,726 7,249 7,249 0 N/A 7,249 7,249 0 20154 $2,274,299$7,271,695 $2,662,726 7,394 7,394 0 N/A 14,644 14,644 0 20164 $2,274,299$7,271,695 $2,662,726 7,542 7,542 0 N/A 22,186 22,186 0 2017 $4,025,178$12,869,841$2,662,726 7,693 5,069 2,624 $1,015 29,879 27,255 2,624 2018 $4,025,178$12,869,841$2,662,726 7,847 5,171 2,676 $995 37,726 32,426 5,300 2019 $1,750,879$5,598,146 $2,662,726 8,004 5,274 2,730 $975 45,730 37,700 8,030 2020 $1,750,879$5,598,146 $2,662,726 8,164 5,380 2,784 $956 53,894 43,080 10,814 2021 $1,750,879$5,598,146 $2,662,726 8,327 5,487 2,840 $938 62,221 48,567 13,654 2022 $1,750,879$5,598,146 $2,662,726 8,494 2,910 5,583 $477 70,715 51,478 19,237 2023 $0 $0 $2,662,726 8,664 2,969 5,695 $468 79,379 54,446 24,932 2024 $0 $0 $2,662,726 8,837 3,028 5,809 $458 88,216 57,474 30,741 2025 $0 $0 $2,662,726 9,014 3,089 5,925 $449 97,230 60,563 36,667 2026 $0 $0 $2,662,726 9,194 3,150 6,044 $441 106,424 63,713 42,710 2027 $0 $0 $2,662,726 9,378 3,213 6,165 $432 115,801 66,927 48,875 2028 $0 $0 $2,662,726 9,565 3,278 6,288 $423 125,367 70,204 55,162 2029 $0 $0 $2,662,726 9,757 3,343 6,414 $415 135,124 73,548 61,576 2030 $0 $0 $2,662,726 9,952 3,410 6,542 $407 145,076 76,958 68,118 2031 $0 $0 $2,662,726 10,151 3,478 6,673 $399 155,226 80,436 74,790 2032 $0 $0 $2,662,726 10,354 3,548 6,806 $391 165,580 83,984 81,597 2033 $0 $0 $2,662,726 10,561 3,619 6,942 $384 176,141 87,603 88,539 2034 $0 $0 $2,662,726 10,772 3,691 7,081 $376 179,664 84,044 95,620 2035 $0 $0 $2,662,726 10,988 3,765 7,223 $369 183,257 80,415 102,843 2036 $0 $0 $2,662,726 11,207 3,840 7,367 $361 186,923 76,713 110,210 2037 $0 $0 $2,662,726 11,432 3,917 7,514 $354 190,661 75,561 115,101 2038 $0 $0 $2,662,726 11,660 3,995 7,665 $347 194,474 74,385 120,089 2039 $0 $0 $2,662,726 11,893 4,075 7,818 $341 198,364 73,186 125,177 2040 $0 $0 $2,662,726 12,131 4,157 7,974 $334 202,331 71,964 130,368 2041 $0 $0 $2,662,726 12,374 4,240 8,134 $327 206,378 70,716 135,661 2042 197,884 67,806 130,078 2043 189,220 64,837 124,383 2044 180,383 61,809 118,574 2045 171,369 58,720 112,649 2046 162,175 55,570 106,605 2047 152,798 52,357 100,441 2048 143,232 49,079 94,153 2049 133,475 45,736 87,740 2050 123,524 42,326 81,198 2051 113,373 38,848 74,525 2052 103,019 35,300 67,719 2053 92,458 31,681 60,777 2054 81,685 27,990 53,696 2055 70,698 24,225 46,473 2056 59,490 20,385 39,106 2057 48,059 16,468 31,591 2058 36,399 12,472 23,926 2059 24,505 8,397 16,108 2060 12,374 4,240 8,134

$77,219,046 1,513,537 $51

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

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, Step 2 standard in 2017, and Step 3 standard in 2022. For woodstoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Cumulative Emission Reduction 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 $1,763,031$5,637,000 $2,360,400 20144 $1,763,031$5,637,000 $2,360,400 955 955 0 N/A 955 955 0 20154 $1,763,031$5,637,000 $2,360,400 974 974 0 N/A 1,929 1,929 0 20164 $1,763,031$5,637,000 $2,360,400 994 994 0 N/A 2,923 2,923 0 2017 $3,053,152$9,761,950 $2,360,400 1,014 912 101 $23,287 3,937 3,835 101 2018 $3,053,152$9,761,950 $2,360,400 1,034 930 103 $22,831 4,971 4,766 205 2019 $1,388,300$4,438,859 $2,360,400 1,055 949 105 $22,383 6,025 5,715 310 2020 $1,388,300$4,438,859 $2,360,400 1,076 968 108 $21,944 7,101 6,683 418 2021 $1,388,300$4,438,859 $2,360,400 1,097 987 110 $21,514 8,198 7,670 527 2022 $1,388,300$4,438,859 $2,360,400 1,119 524 595 $3,965 9,317 8,194 1,123 2023 $0 $453,909 $2,360,400 1,141 534 607 $3,887 10,459 8,728 1,730 2024 $0 $453,909 $2,360,400 1,164 545 619 $3,811 11,623 9,273 2,350 2025 $0 $453,909 $2,360,400 1,188 556 632 $3,736 12,810 9,829 2,981 2026 $0 $453,909 $2,360,400 1,211 567 644 $3,663 14,022 10,396 3,626 2027 $0 $453,909 $2,360,400 1,236 578 657 $3,591 15,257 10,974 4,283 2028 $0 $453,909 $2,360,400 1,260 590 670 $3,520 16,518 11,564 4,954 2029 $0 $453,909 $2,360,400 1,285 602 684 $3,451 17,803 12,166 5,637 2030 $0 $453,909 $2,360,400 1,311 614 698 $3,384 19,114 12,779 6,335 2031 $0 $453,909 $2,360,400 1,337 626 712 $3,317 20,452 13,405 7,047 2032 $0 $453,909 $2,360,400 1,364 638 726 $3,252 21,816 14,044 7,772 2033 $0 $453,909 $2,360,400 1,391 651 740 $3,189 23,207 14,695 8,513 2034 $0 $453,909 $2,360,400 1,419 664 755 $3,126 23,672 14,404 9,268 2035 $0 $453,909 $2,360,400 1,448 678 770 $3,065 24,145 14,107 10,038 2036 $0 $453,909 $2,360,400 1,477 691 786 $3,005 24,628 13,805 10,823 2037 $0 $453,909 $2,360,400 1,506 705 801 $2,946 25,121 13,597 11,523 2038 $0 $453,909 $2,360,400 1,536 719 817 $2,888 25,623 13,386 12,237 2039 $0 $453,909 $2,360,400 1,567 733 834 $2,831 26,135 13,170 12,965 2040 $0 $453,909 $2,360,400 1,598 748 850 $2,776 26,658 12,950 13,708 2041 $0 $453,909 $2,360,400 1,630 763 867 $2,721 27,191 12,726 14,466 2042 26,072 12,202 13,870 2043 24,931 11,668 13,263 2044 23,766 11,123 12,644 2045 22,579 10,567 12,012 2046 21,367 10,000 11,367 2047 20,132 9,422 10,710 2048 18,872 8,832 10,040 2049 17,586 8,230 9,356 2050 16,275 7,617 8,658 2051 14,937 6,991 7,947 2052 13,573 6,352 7,221 2053 12,182 5,701 6,481 2054 10,762 5,037 5,726 2055 9,315 4,359 4,955 2056 7,838 3,668 4,170 2057 6,332 2,963 3,369 2058 4,796 2,244 2,551 2059 3,229 1,511 1,718 2060 1,630 763 867

$68,451,599 161,390 $424

4Estimated emissions assume Step 1 standard becomes applicable in 2014, Step 2 standard in 2017, and Step 3 standard in 2022. For pellet stoves, estimates conservatively assume that most models meet the Step 1 limit and that manufacturers will certify and sell existing models meeting Step 1 during 2014 through 2016. Therefore no emission reductions are estimated until Step 2 in 2017.

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 Cumulative Emission Reduction over 20-year stove lifespan **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 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

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 

### $776,284$2,482,038 $592,857 20144 

### $776,284$2,482,038 $592,857 6,485 3,956 2,529 $234 6,485 3,956 2,529 2015 $393,244$1,257,332 $592,857 6,614 4,035 2,579 $230 13,099 7,991 5,108 2016 $393,244$1,257,332 $592,857 6,747 4,116 2,631 $225 19,846 12,107 7,739 20174 

### $688,129 $2,200,178 $592,857 6,882 2,309 4,573 $130 26,728 14,416 12,312 2018 $688,129 $2,200,178 $592,857 7,019 2,355 4,664 $127 33,747 16,771 16,976 2019 $307,591 $983,471 $592,857 7,160 2,402 4,757 $125 40,907 19,174 21,733 2020 $307,591 $983,471 $592,857 7,303 2,450 4,853 $122 48,210 21,624 26,586 2021 $307,591 $983,471 $592,857 7,449 2,499 4,950 $120 55,659 24,123 31,535 20224 

### $307,591 $983,471 $592,857 7,598 1,326 6,272 $95 63,257 25,449 37,808 2023 $0 $72,625 $592,857 7,750 1,352 6,398 $93 71,006 26,801 44,205 2024 $0 $72,625 $592,857 7,905 1,379 6,526 $91 78,911 28,180 50,731 2025 $0 $72,625 $592,857 8,063 1,407 6,656 $89 86,974 29,587 57,387 2026 $0 $72,625 $592,857 8,224 1,435 6,789 $87 95,199 31,022 64,177 2027 $0 $72,625 $592,857 8,389 1,464 6,925 $86 103,587 32,486 71,102 2028 $0 $72,625 $592,857 8,557 1,493 7,064 $84 112,144 33,978 78,165 2029 $0 $72,625 $592,857 8,728 1,523 7,205 $82 120,872 35,501 85,370 2030 $0 $72,625 $592,857 8,902 1,553 7,349 $81 129,774 37,054 92,719 2031 $0 $72,625 $592,857 9,080 1,584 7,496 $79 138,854 38,639 100,215 2032 $0 $72,625 $592,857 9,262 1,616 7,646 $78 148,116 40,255 107,861 2033 $0 $72,625 $592,857 9,447 1,648 7,799 $76 157,563 41,903 115,660 2034 $0 $72,625 $592,857 9,636 1,681 7,955 $75 160,714 39,628 121,086 2035 $0 $72,625 $592,857 9,829 1,715 8,114 $73 163,928 37,308 126,621 2036 $0 $72,625 $592,857 10,025 1,749 8,276 $72 167,207 34,941 132,266 2037 $0 $72,625 $592,857 10,226 1,784 8,442 $70 170,551 34,416 136,135 2038 $0 $72,625 $592,857 10,430 1,820 8,611 $69 173,962 33,881 140,081 2039 $0 $72,625 $592,857 10,639 1,856 8,783 $68 177,441 33,335 144,106 2040 $0 $72,625 $592,857 10,852 1,893 8,958 $66 180,990 32,778 148,212 2041 $0 $72,625 $592,857 11,069 1,931 9,138 $65 184,610 32,210 152,400 2042 177,012 30,884 146,128 2043 169,262 29,532 139,730 2044 161,357 28,153 133,204 2045 153,294 26,746 126,548 2046 145,070 25,311 119,759 2047 136,681 23,847 112,834 2048 128,125 22,355 105,770 2049 119,397 20,832 98,565 2050 110,495 19,279 91,216 2051 101,415 17,694 83,720 2052 92,153 16,078 76,074 2053 82,706 14,430 68,276 2054 73,070 12,749 60,321 2055 63,241 11,034 52,207 2056 53,216 9,285 43,931 2057 42,990 7,501 35,489 2058 32,559 5,681 26,879 2059 21,921 3,825 18,096 2060 11,069 1,931 9,138

$17,192,863 1,700,286 $10

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **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 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

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

Capital 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 $4,250,734$13,591,020$4,606,583 20144 $4,250,734$13,591,020$4,606,583 26,920 5,501 21,419 $215 26,920 5,501 21,419 2015 $3,293,135$10,529,254$4,606,583 27,458 5,611 21,847 $211 54,378 11,111 43,267 2016 $3,293,135$10,529,254$4,606,583 28,007 5,723 22,284 $207 82,385 16,834 65,551 20174 $5,799,656$18,543,442$4,606,583 28,567 1,428 27,139 $170 110,952 18,262 92,690 2018 $5,799,656$18,543,442$4,606,583 29,139 1,457 27,682 $166 140,091 19,719 120,372 2019 $2,586,353$8,269,437 $4,606,583 29,721 1,486 28,235 $163 169,812 21,205 148,607 2020 $2,586,353$8,269,437 $4,606,583 30,316 1,516 28,800 $160 200,128 22,721 177,407 2021 $2,586,353$8,269,437 $4,606,583 30,922 1,546 29,376 $157 231,050 24,267 206,783 20224 $2,586,353$8,269,437 $4,606,583 31,541 631 30,910 $149 262,591 24,898 237,693 2023 $0 $799,249 $4,606,583 32,171 643 31,528 $146 294,762 25,541 269,221 2024 $0 $799,249 $4,606,583 32,815 656 32,159 $143 327,577 26,198 301,379 2025 $0 $799,249 $4,606,583 33,471 669 32,802 $140 361,048 26,867 334,181 2026 $0 $799,249 $4,606,583 34,141 683 33,458 $138 395,189 27,550 367,639 2027 $0 $799,249 $4,606,583 34,823 696 34,127 $135 430,012 28,246 401,766 2028 $0 $799,249 $4,606,583 35,520 710 34,809 $132 465,532 28,957 436,575 2029 $0 $799,249 $4,606,583 36,230 725 35,506 $130 501,762 29,681 472,081 2030 $0 $799,249 $4,606,583 36,955 739 36,216 $127 538,717 30,420 508,297 2031 $0 $799,249 $4,606,583 37,694 754 36,940 $125 576,411 31,174 545,237 2032 $0 $799,249 $4,606,583 38,448 769 37,679 $122 614,859 31,943 582,916 2033 $0 $799,249 $4,606,583 39,217 784 38,432 $120 654,076 32,728 621,348 2034 $0 $799,249 $4,606,583 40,001 800 39,201 $118 667,157 28,027 639,130 2035 $0 $799,249 $4,606,583 40,801 816 39,985 $115 680,500 23,233 657,268 2036 $0 $799,249 $4,606,583 41,617 832 40,785 $113 694,110 18,342 675,768 2037 $0 $799,249 $4,606,583 42,450 849 41,601 $111 707,993 17,763 690,230 2038 $0 $799,249 $4,606,583 43,298 866 42,433 $109 722,152 17,172 704,981 2039 $0 $799,249 $4,606,583 44,164 883 43,281 $106 736,595 16,569 720,026 2040 $0 $799,249 $4,606,583 45,048 901 44,147 $104 751,327 15,954 735,373 2041 $0 $799,249 $4,606,583 45,949 919 45,030 $102 766,354 15,327 751,027 2042 734,813 14,696 720,117 2043 702,642 14,053 688,589 2044 669,827 13,397 656,430 2045 636,356 12,727 623,629 2046 602,215 12,044 590,171 2047 567,392 11,348 556,044 2048 531,872 10,637 521,235 2049 495,642 9,913 485,729 2050 458,687 9,174 449,513 2051 420,993 8,420 412,573 2052 382,545 7,651 374,894 2053 343,328 6,867 336,462 2054 303,327 6,067 297,261 2055 262,526 5,251 257,276 2056 220,909 4,418 216,491 2057 178,459 3,569 174,890 2058 135,161 2,703 132,458 2059 90,996 1,820 89,177 2060 45,949 919 45,030

$133,590,914 8,378,994 $16 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 round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. 1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, 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, Step 2 standard in 2017, and Step 3 standard in 2022. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton) 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 

### $1,926,169$6,158,606 $1,503,929 20144 

### $1,926,169$6,158,606 $1,503,929 18,724 4,681 14,043 $107 18,724 4,681 14,043 2015 $968,569 $3,096,839 $1,503,929 19,098 4,775 14,324 $105 37,822 9,455 28,366 2016 $968,569 $3,096,839 $1,503,929 19,480 4,870 14,610 $103 57,302 14,326 42,977 20174 

### $1,705,781$5,453,954 $1,503,929 19,870 993 18,876 $80 77,172 15,319 61,853 2018 $1,705,781$5,453,954 $1,503,929 20,267 1,013 19,254 $78 97,439 16,332 81,107 2019 $760,692 $2,432,187 $1,503,929 20,672 1,034 19,639 $77 118,111 17,366 100,745 2020 $760,692 $2,432,187 $1,503,929 21,086 1,054 20,032 $75 139,197 18,420 120,777 2021 $760,692 $2,432,187 $1,503,929 21,508 1,075 20,432 $74 160,705 19,496 141,209 20224 

### $760,692 $2,432,187 $1,503,929 21,938 439 21,499 $70 182,643 19,934 162,708 2023 $0 $235,073 $1,503,929 22,377 448 21,929 $69 205,019 20,382 184,637 2024 $0 $235,073 $1,503,929 22,824 456 22,368 $67 227,843 20,838 207,005 2025 $0 $235,073 $1,503,929 23,281 466 22,815 $66 251,124 21,304 229,820 2026 $0 $235,073 $1,503,929 23,746 475 23,271 $65 274,870 21,779 253,091 2027 $0 $235,073 $1,503,929 24,221 484 23,737 $63 299,091 22,263 276,828 2028 $0 $235,073 $1,503,929 24,706 494 24,211 $62 323,797 22,757 301,039 2029 $0 $235,073 $1,503,929 25,200 504 24,696 $61 348,997 23,261 325,735 2030 $0 $235,073 $1,503,929 25,704 514 25,190 $60 374,700 23,776 350,925 2031 $0 $235,073 $1,503,929 26,218 524 25,693 $59 400,918 24,300 376,618 2032 $0 $235,073 $1,503,929 26,742 535 26,207 $57 427,660 24,835 402,825 2033 $0 $235,073 $1,503,929 27,277 546 26,731 $56 454,937 25,380 429,557 2034 $0 $235,073 $1,503,929 27,822 556 27,266 $55 464,036 21,256 442,780 2035 $0 $235,073 $1,503,929 28,379 568 27,811 $54 473,316 17,049 456,267 2036 $0 $235,073 $1,503,929 28,946 579 28,368 $53 482,783 12,758 470,025 2037 $0 $235,073 $1,503,929 29,525 591 28,935 $52 492,438 12,355 480,083 2038 $0 $235,073 $1,503,929 30,116 602 29,514 $51 502,287 11,944 490,343 2039 $0 $235,073 $1,503,929 30,718 614 30,104 $50 512,333 11,524 500,808 2040 $0 $235,073 $1,503,929 31,333 627 30,706 $49 522,579 11,097 511,483 2041 $0 $235,073 $1,503,929 31,959 639 31,320 $48 533,031 10,661 522,370 2042 511,093 10,222 500,871 2043 488,717 9,774 478,942 2044 465,893 9,318 456,575 2045 442,612 8,852 433,760 2046 418,866 8,377 410,488 2047 394,645 7,893 386,752 2048 369,939 7,399 362,540 2049 344,739 6,895 337,845 2050 319,036 6,381 312,655 2051 292,818 5,856 286,962 2052 266,076 5,322 260,755 2053 238,799 4,776 234,023 2054 210,977 4,220 206,757 2055 182,598 3,652 178,946 2056 153,651 3,073 150,578 2057 124,126 2,483 121,643 2058 94,010 1,880 92,130 2059 63,292 1,266 62,026 2060 31,959 639 31,320

$43,613,939 5,827,939 $7

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060.CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **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 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

3

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

Capital 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 

### $2,324,566$7,432,415 $3,102,654 20144 

### $2,324,566$7,432,415 $3,102,654 8,196 820 7,376 $421 8,196 820 7,376 2015 $2,324,566$7,432,415 $3,102,654 8,360 836 7,524 $412 16,556 1,656 14,900 2016 $2,324,566$7,432,415 $3,102,654 8,527 853 7,674 $404 25,083 2,508 22,574 20174 

### $4,093,875$13,089,489$3,102,654 8,698 435 8,263 $376 33,780 2,943 30,837 2018 $4,093,875$13,089,489$3,102,654 8,872 444 8,428 $368 42,652 3,387 39,265 2019 $1,825,661$5,837,250 $3,102,654 9,049 452 8,596 $361 51,701 3,839 47,862 2020 $1,825,661$5,837,250 $3,102,654 9,230 461 8,768 $354 60,931 4,301 56,630 2021 $1,825,661$5,837,250 $3,102,654 9,415 471 8,944 $347 70,345 4,771 65,574 20224 

### $1,825,661$5,837,250 $3,102,654 9,603 192 9,411 $330 79,948 4,963 74,985 2023 $0 $564,176 $3,102,654 9,795 196 9,599 $323 89,743 5,159 84,583 2024 $0 $564,176 $3,102,654 9,991 200 9,791 $317 99,734 5,359 94,374 2025 $0 $564,176 $3,102,654 10,191 204 9,987 $311 109,924 5,563 104,361 2026 $0 $564,176 $3,102,654 10,394 208 10,186 $305 120,319 5,771 114,548 2027 $0 $564,176 $3,102,654 10,602 212 10,390 $299 130,921 5,983 124,938 2028 $0 $564,176 $3,102,654 10,814 216 10,598 $293 141,735 6,199 135,536 2029 $0 $564,176 $3,102,654 11,031 221 10,810 $287 152,766 6,420 146,346 2030 $0 $564,176 $3,102,654 11,251 225 11,026 $281 164,017 6,645 157,372 2031 $0 $564,176 $3,102,654 11,476 230 11,247 $276 175,493 6,874 168,619 2032 $0 $564,176 $3,102,654 11,706 234 11,472 $270 187,199 7,108 180,090 2033 $0 $564,176 $3,102,654 11,940 239 11,701 $265 199,139 7,347 191,792 2034 $0 $564,176 $3,102,654 12,179 244 11,935 $260 203,122 6,771 196,350 2035 $0 $564,176 $3,102,654 12,422 248 12,174 $255 207,184 6,184 201,000 2036 $0 $564,176 $3,102,654 12,671 253 12,417 $250 211,328 5,584 205,743 2037 $0 $564,176 $3,102,654 12,924 258 12,666 $245 215,554 5,408 210,146 2038 $0 $564,176 $3,102,654 13,183 264 12,919 $240 219,865 5,228 214,637 2039 $0 $564,176 $3,102,654 13,446 269 13,177 $235 224,263 5,045 219,218 2040 $0 $564,176 $3,102,654 13,715 274 13,441 $231 228,748 4,857 223,891 2041 $0 $564,176 $3,102,654 13,989 280 13,710 $226 233,323 4,666 228,656 2042 223,720 4,474 219,246 2043 213,925 4,279 209,647 2044 203,934 4,079 199,856 2045 193,744 3,875 189,869 2046 183,350 3,667 179,683 2047 172,747 3,455 169,292 2048 161,933 3,239 158,694 2049 150,902 3,018 147,884 2050 139,651 2,793 136,858 2051 128,175 2,563 125,611 2052 116,469 2,329 114,140 2053 104,529 2,091 102,439 2054 92,351 1,847 90,504 2055 79,928 1,599 78,330 2056 67,258 1,345 65,912 2057 54,333 1,087 53,247 2058 41,151 823 40,328 2059 27,705 554 27,151 2060 13,989 280 13,710

$89,976,975 2,551,055 $35

4

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

5

### The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. CE based on total cost & cumulative emission reduction over 20-year stove lifespan (per ton)

Nationwide cumulative cost5 

### Cumulative Emission Reduction over 20-year stove lifespan **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 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 are past the 20-year model design lifespan used in this analysis.

2

### Estimated annual emissions are based on a forecasted revenue growth rate (as a surrogate for shipments) of 2.0 % from 2011 through 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).
3

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

Capital 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 $9,064,348$28,981,753$10,222,566 20144 $9,064,348$28,981,753$10,222,566 41,609 17,661 23,948 $427 41,609 17,661 23,948 2015 $7,723,708$24,695,280$10,222,566 42,441 18,014 24,427 $418 84,050 35,675 48,375 2016 $7,723,708$24,695,280$10,222,566 43,290 18,375 24,915 $410 127,340 54,050 73,290 20174$13,566,115$43,375,410$10,222,566 44,156 9,719 34,437 $297 171,496 63,769 107,727 2018 $13,566,115$43,375,410$10,222,566 45,039 9,913 35,125 $291 216,535 73,682 142,852 2019 $6,033,123$19,289,913$10,222,566 45,940 10,112 35,828 $285 262,474 83,794 178,680 2020 $6,033,123$19,289,913$10,222,566 46,858 10,314 36,545 $280 309,333 94,108 215,225 2021 $6,033,123$19,289,913$10,222,566 47,796 10,520 37,275 $274 357,128 104,628 252,500 20224 $6,033,123$19,289,913$10,222,566 48,751 5,391 43,361 $236 405,880 110,019 295,861 2023 $0 $1,325,783$10,222,566 49,727 5,498 44,228 $231 455,606 115,517 340,089 2024 $0 $1,325,783$10,222,566 50,721 5,608 45,113 $227 506,327 121,126 385,201 2025 $0 $1,325,783$10,222,566 51,735 5,721 46,015 $222 558,063 126,846 431,216 2026 $0 $1,325,783$10,222,566 52,770 5,835 46,935 $218 610,833 132,681 478,151 2027 $0 $1,325,783$10,222,566 53,826 5,952 47,874 $214 664,658 138,633 526,025 2028 $0 $1,325,783$10,222,566 54,902 6,071 48,831 $209 719,560 144,704 574,857 2029 $0 $1,325,783$10,222,566 56,000 6,192 49,808 $205 775,561 150,896 624,665 2030 $0 $1,325,783$10,222,566 57,120 6,316 50,804 $201 832,681 157,212 675,469 2031 $0 $1,325,783$10,222,566 58,263 6,442 51,820 $197 890,943 163,654 727,289 2032 $0 $1,325,783$10,222,566 59,428 6,571 52,857 $193 950,371 170,225 780,146 2033 $0 $1,325,783$10,222,566 60,616 6,703 53,914 $190 1,010,987 176,928 834,059 2034 $0 $1,325,783$10,222,566 61,829 6,837 54,992 $186 1,031,207 166,104 865,104 2035 $0 $1,325,783$10,222,566 63,065 6,973 56,092 $182 1,051,831 155,063 896,769 2036 $0 $1,325,783$10,222,566 64,327 7,113 57,214 $179 1,072,868 143,801 929,067 2037 $0 $1,325,783$10,222,566 65,613 7,255 58,358 $175 1,094,325 141,337 952,988 2038 $0 $1,325,783$10,222,566 66,925 7,400 59,525 $172 1,116,212 138,824 977,388 2039 $0 $1,325,783$10,222,566 68,264 7,548 60,716 $168 1,138,536 136,260 1,002,276 2040 $0 $1,325,783$10,222,566 69,629 7,699 61,930 $165 1,161,307 133,646 1,027,661 2041 $0 $1,325,783$10,222,566 71,022 7,853 63,169 $162 1,184,533 130,979 1,053,554 2042 1,135,781 125,588 1,010,193 2043 1,086,055 120,089 965,965 2044 1,035,334 114,481 920,853 2045 983,598 108,760 874,838 2046 930,828 102,925 827,903 2047 877,003 96,974 780,029 2048 822,101 90,903 731,198 2049 766,100 84,711 681,390 2050 708,980 78,395 630,585 2051 650,718 71,952 578,765 2052 591,290 65,381 525,909 2053 530,674 58,679 471,995 2054 468,845 51,842 417,003 2055 405,780 44,869 360,911 2056 341,453 37,756 303,697 2057 275,840 30,501 245,339 2058 208,915 23,101 185,814 2059 140,651 15,552 125,099 2060 71,022 7,853 63,169

$296,454,422 11,754,208 $25

5The nationwide cumulative cost represents the cost to manufacturers resulting from the R&D round(s) to meet the proposed NSPS and the NSPS-caused certification and reporting & recordkeeping costs to bring these stoves to market from 2013 through 2041. These stoves have lifespans of 20 years (a conservative estimate); thus stoves shipped in 2041 will be emitting through 2060. Year Annual

Capital CostsNationwide

Annual Cost1Nationwide

Average Annual Cost Annual Snapshots

1Estimated nationwide annual costs are in 2010 $ and are based on 6-year amortization periods of R&D costs at a 3% interest rate (during 2013-2018 for round one R&D and 2017-2022 for round two R&D), plus annual certification and reporting & recordkeeping costs (ongoing through 2041). Years2042 through 2060 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 2041, in keeping with the average annual growth in real GDP predicted by the US Bureau of Economic Analysis (2013 Global Outlook projections prepared by the Conference Board in November 2012; see http://www.conference-board.org/data/globaloutlook.cfm).

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, Step 2 standard in 2017, and Step 3 standard in 2022. No emission reductions are estimated for woodstoves and pellet stoves until 2017, although emission reductions are estimated for all other devices starting in 2014. **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