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SUPPORTING STATEMENT

NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces

(40 CFR Part 60, Subpart QQQQ)

PART A

1.0 Identification of the Information Collection

(a) Title of the Information Collection.

The title of the Information Collection Request (ICR) is NSPS for New Residential 

Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Final Rule). This 

is a new ICR, and the U.S. Environmental Protection Agency (EPA) tracking number is 2442.02, 

Office of Management and Budget (OMB) Control Number 2060-0693.

(b) Short Characterization.

This ICR covers information collection requirements in the final rule, New Source 

Performance Standards (NSPS) for new residential hydronic heaters and forced-air furnaces (40 

CFR part 60, subpart QQQQ (subpart QQQQ)). The information collected will be used by the 

EPA and delegated state and local agencies to determine the compliance status of sources subject 

to the rule. A residential hydronic heater is defined as a fuel burning device designed to burn 

wood or wood pellet fuel for the purpose of heating building space and/or water through the 

distribution, typically through pipes, of a fluid heated in the device, typically water or a water 

and antifreeze mixture. A residential forced-air furnace is defined as a fuel burning device 

designed to burn wood or wood pellet fuel that warms spaces other than the space where the 

furnace is located, by the distribution of air heated by the furnace through ducts.

The residential hydronic heater and forced-air furnace NSPS is based on similar design 

principles as the NSPS for new residential wood heaters (40 CFR part 60, subpart AAA). These 

NSPS establish a certification program instead of the usual NSPS requirement that each affected 

facility demonstrate compliance with emission limits through performance testing. Under this 

certification program, a single wood-heating appliance is tested to demonstrate compliance with 

particulate matter (PM) emission limits for an entire model line which could consist of thousands 

of stoves. The use of a certification approach significantly reduces the compliance burden, 

including information collection, for the manufacturers of hydronic heaters and forced-air 

furnaces. In order to minimize risks to the environment from intentional or accidental misuse of 
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the certification approach, subpart QQQQ also includes several safeguards, some of which entail 

reporting and recordkeeping.

There are approximately 30 hydronic heater manufacturers, 7 forced-air furnace 

manufacturers and 4 laboratories (inclusive of both test labs and third-party certifiers) that would 

be subject to the final rule. Under subpart QQQQ, hydronic heater and forced-air furnace

manufacturers, testing laboratories, and third-party certifiers are required to submit reports to the 

EPA and to maintain records for demonstrating compliance with the NSPS. The information 

supplied by the manufacturer to the EPA is used: (1) to ensure that the best system of emission 

reduction is being applied to reduce emissions from hydronic heaters and forced-air furnaces; (2) 

to ensure that the appliance tested for certification purposes is in compliance with the applicable 

emission standards; (3) to provide assurance that non-tested production model appliances have 

emission performance characteristics similar to tested models; and (4) to provide an indicator of 

continued compliance. Information supplied to the EPA by testing laboratories and third-party 

certifiers is used to grant or deny laboratory accreditation and to assist in enforcement and 

compliance activities. Information supplied to the EPA by testing laboratories and certifying 

bodies/entities is used to grant or deny laboratory accreditation, assure continued test lab 

proficiency and to assist in enforcement and compliance activities.

Subpart QQQQ does not require any reporting or recordkeeping requirements on 

hydronic heater or forced-air furnace owners or operators. However, the final rule specifies a list 

of prohibited fuel types and prohibited operations, as well as good operating and good burning 

practices (which are required to be included in the owner’s manual for certified models) that 

owners and operators are directed to follow when installing and operating their heating 

appliances.

The phased implementation schedule of the final rule along with the two-step PM 

emission standards approach (with phased compliance dates) results in differing recordkeeping 

and reporting impacts. For purposes of the supporting statement, we refer to these steps as Step 1 

and Step 2. The compliance date for meeting Step 1 emission standards provided in the rule 

occurs in 2015, and the compliance date for meeting Step 2 emission standards provided in the 

rule occurs in 2020. The recordkeeping and reporting burden cost estimates as a result of the 

subpart QQQQ final rule for years 2018 to 2020 are presented in a memo to the docket.1The 

 

1 Memorandum to Docket ID Number EPA-HQ-OAR-2009-0734 from EC/R, Inc. 40 CFR Part 60, Subparts AAA 
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recordkeeping and reporting burden estimates included in this supporting statement are for years 

2015 to 2017 and the burden estimates outlined in the memo for years 2018 to 2020 are both 

included in cost impacts estimates included in a memo in the docket for the final rule.1

The estimated burden to the “Affected Public” is listed in Table 1, “Three-Year and 

Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the Final 

Rule.” The federal government burden associated with the review of reports submitted by

respondents is shown in Table 2, “Three-Year and Annual Burden and Cost to the Federal 

Government of the Final Rule.” (Tables 1 and 2 are located at the end of this supporting 

statement.) We do not anticipate any reporting or recordkeeping burden for state, local or tribal 

entities because we have only delegated ability to enforce the standards for residential hydronic 

heaters and forced-air furnaces sold or operated in their region. Under subpart QQQQ, partial 

delegations shall not include:

(1) Decisions on certification;

(2) Revocation of certification;

(3) Standards;

(4) Test methods;

(5) Laboratory and third-party certifier approvals and revocations;

(6) Enforcing provisions governing content of owner’s manuals; and

(7) Hearings and appeals procedures.

The information collection requirements for new sources subject to the NSPS for 

Residential Hydronic Heaters and Forced-Air Furnaces are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: “. . . application of the 

best system of emission reduction which (taking into consideration the cost of achieving such 

reduction and any non-air quality health and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. Section 111(a)(l). The agency

refers to this charge as selecting the “best system of emission reduction.” Section 111 also 

 

and QQQQ Estimated Three-Year and Annual Respondent Burden Cost of Reporting and Recordkeeping 

Requirements (Years 2018 to 2020). January 2015.

1 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts. January 2015.
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requires that the Administrator review and, if appropriate, revise such standards every 8 years.

Wood burning hydronic heaters and forced-air furnaces are part of the residential wood heating 

source category, pollutant emissions from which cause or contribute to air pollution that may

reasonably be anticipated to endanger public health or welfare, in the Administrator's judgment. 

As part of the review process, the EPA has decided to expand the types of appliances regulated 

under the residential wood heating source category to include hydronic heaters and forced-air 

furnaces. Therefore, the NSPS was promulgated for these appliances at 40 CFR part 60,

subpart QQQQ.

The records and reports required under subpart QQQQ are necessary for the 

Administrator to confirm the compliance status of new residential hydronic heaters and forcedair furnaces sold in the United States. These recordkeeping and reporting requirements are 

specifically authorized by CAA section 114. 

(b) Practical Utility//Users of the Data.

The control of pollution from new residential hydronic heaters and forced-air furnaces

relies on the reduction of particulate matter emissions by proper appliance design. A 

representative unit for each model line is subjected to a certification test for particulate matter

emissions for a range of operating conditions. The manufacturer also contracts with a third-party

certifier, which reviews the test reports and quality assurance (QA) plan, and conducts periodic 

QA audits to ensure that hydronic heaters and forced-air furnaces manufactured subsequent to 

the initial certification test continue to comply with the NSPS. Manufacturers must renew or 

recertify their model lines every 5 years or when they make changes to the model line that would 

exceed specified parameters.

The required certification test notification is used to inform the EPA when a new model 

line is expected to be tested. The EPA may then observe the testing, if desired. Emission test 

reports are needed as these are the EPA’s record of a model line’s initial capability to comply

with the emission standard, and serve as a record of the operating conditions under which 

compliance was achieved. The EPA compliance audit tests and QA annual audit reports are 

necessary to ensure continued compliance with the emission standards.

Adequate recordkeeping and reporting are necessary to ensure compliance with these 

standards as required by the CAA. The information collected from recordkeeping and reporting 
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requirements is also used for targeting inspections and is of sufficient quality to be used as 

evidence in court.

3. Non-duplication, Consultations, and Other Collection Criteria

(a) Non-duplication.

A computer search of the EPA’s ongoing ICRs revealed no duplication of informationgathering efforts.

Similar requirements to this NSPS are found in the requirements to 40 CFR part 60, 

subpart AAA, the NSPS for Residential Wood Heaters. Subpart AAA has a separate ICR

undergoing OMB review. Although the requirements are similar, they are not duplicative 

because they apply to separate groups of appliances and their associated manufacturers. In the 

case of test laboratories and third-party certifiers, similar accreditation requirements are found in 

both subparts (40 CFR part 60, subparts AAA and QQQQ), but each has different test methods. 

Therefore, the requirements under each of these subparts are not duplicative because separate 

accreditation is required for each test method.

(b) Public Notice Required Prior to ICR Submission to OMB.

The preamble to the proposed rule (79 FR 6330, February 3, 2014) provided public notice

of the proposed ICR. The EPA considered comments (see Docket ID No. EPA-HQ-OAR-2009-

0734) when preparing this revised ICR. The preamble to the final rule provides public notice on

this revised ICR.

(c) Consultations.

The final rule was developed using information obtained during extensive consultation 

with individual companies, trade associations and state agencies. Several of the key non-EPA 

persons consulted on the information collection activities are identified in Table 3. Additional 

meetings and contacts are documented in the project docket for this final rule, Docket No. EPAHQ-OAR-2009-0734.
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TABLE 3. PERSONS CONSULTED ON THE INFORMATION

COLLECTION ACTIVITIES

Contact Organization Telephone Number

Dennis Brazier Central Boiler

John Crouch Hearth, Patio, Barbecue Association (HPBA) 916.536.2390

Rick Curkeet Intertek Testing Services 608.836.4400

Alice Edwards Alaska Dept. Of Environmental Conservation 907.465.5105

Chuck Gagnor Northwest Manufacturing

Stephen Hartsfield National Tribal Air Association 505.242.2175

Frank Moore Hardy Manufacturing 601.656.5866

Ben Myren Myren Consulting, Inc. 509.684.1154

Scott Nichols Tarm Biomass

Lisa Rector Northeast States for Coordinated Air Use

Measurement (NESCAUM)

617.259.2095

Rod Tinnemore Washington State Department of Ecology 360.407.6978

(d) Effects of Less Frequent Collection.

Less frequent information collection would decrease the margin of assurance that 

manufacturers are producing residential hydronic heaters and forced-air furnaces that (1) pass the 

initial certification test, and (2) continue to be manufactured in a way that ensures continuous 

compliance with the emission standards. If the information required by these standards were

collected less frequently, the likelihood of detecting violations would be reduced.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 is being exceeded, with the exception of the 

requirement to retain records for 5 years (which exceeds the guideline requirement that records 

not be required to be retained for more than 3 years). The basis for the 5-year record retention is 

due to required emission standard model certifications being valid for 5 years prior to the need 

for renewal or recertification. During this time, the EPA needs to require the retention of model 

certification tests and QA compliance documentation to support initial and continued compliance 

with model certifications (e.g., certification tests, QA emissions tests, QA audit reports, biennial 

reports). 

(f) Confidentiality.

All information submitted to the agency for which a claim of confidentiality is made will 

be safeguarded according to the EPA regulations set forth in 40 CFR 2.201 et seq., Chapter 1, 

Part 2, Subpart B—Confidentiality of Business Information.
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(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart QQQQ are manufacturers of new residential 

hydronic heaters and forced-air furnaces. The North American Industry Classification System 

(NAICS) code for residential hydronic heating manufacturing facilities is 333414, Heating 

Equipment (Except for Warm Air Furnace Manufacturing). The NAICS code for forced-air 

furnaces is 333415, Air-Conditioning and Warm Air Heating Equipment and Commercial and 

Industrial Refrigeration Equipment Manufacturing. Subpart QQQQ also applies to laboratories 

that conduct or plan to conduct hydronic heater and forced-air furnace certification tests (referred 

herein as testing labs) and laboratories that plan to become third-party certifiers (referred herein 

as third-party certifiers) for manufacturers. The NAICS code for testing laboratories is 541380.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. In this ICR, all the data recorded 

or reported is required by the NSPS for New Residential Hydronic Heaters and Forced-air 

Furnaces (40 CFR Part 60, subpart QQQQ). The reporting requirements for NSPS 

subpart QQQQ were uniquely designed for the manufacturers, third-party certifiers and testing 

laboratories. The records required by this regulation must be retained by the manufacturer, thirdparty certifier and/or test laboratory for 5 years. A special table is attached that describes the 

reporting and recordkeeping requirements. See Attachment 1.

(ii) Respondent Activities. The respondent activities that will be required by the final rule

are identified in Table 1 (located at the end of this supporting statement) and introduced in 

section 6(a).

5. The Information Collected–Agency Activities, Collection Methodology and 

Information Management

(a) Agency Activities.

Attachment 2 is a summary of the reporting and recordkeeping requirements for the 

federal government. The agency activities associated with the final rule are provided in Table 2

(located at the end of this supporting statement) and are introduced in section 6(c).
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(b) Collection Methodology and Management.

All reports are sent directly to the EPA electronically. Data obtained from reports 

submitted and records maintained by the respondents will be used in compliance and 

enforcement programs. Portions of the data obtained will be entered into a special database 

program maintained exclusively by the EPA and some of the data will be made available to the 

public on an EPA website. 

The EPA provides public access to the list of certified appliances and their emissions 

ratings on line at 

http://www.epa.gov/compliance/resources/publications/monitoring/caa/woodstoves/certifiedwoo

d.pdf.

(c) Small Entity Flexibility.

Most of the manufacturers, laboratories and commercial owners affected by the final rule

are considered small businesses based on the definition used by the Small Business 

Administration. Additional efforts were taken by the EPA to reduce the burden imposed on the 

small businesses affected by this regulation. For instance, we have included provisions that allow

models with existing certifications that meet Step 1 emission standards that meet specified 

(conditional) criteria to be automatically certified until the Step 2 emission standards effective 

date (2020). We believe that allowing this automatic conditional certification approval and 

including phased compliance dates in the final rule allows additional time for sources to come 

into compliance and helps to reduce the burden on small businesses by spreading out research 

and development (R&D) costs over several years. The final rule also includes QA program 

requirements that align with existing safety QA procedures, thus avoiding duplicative 

procedures. Additionally, the final rule allows currently EPA-accredited testing laboratories to be 

allowed to test as approved testing labs for subpart QQQQ for three years after the effective date 

of the rule. For forced-air furnaces, we have also deferred implementation of the requirement that 

third-party certifiers be accredited under subpart QQQQ until 6 months after the effective date of 

the final rule.

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is 

shown in Table 1 for new residential hydronic heaters and forced-air furnaces, which is located 

at the end of this supporting statement.
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6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual recordkeeping and reporting respondent burden estimates for subpart QQQQ

are shown in Table 1, located at the end of this section. These numbers were derived from 

estimates based on EPA’s experience with implementing existing subpart AAA rule and other 

rules, and the EPA voluntary hydronic heater program.

(b) Estimating Respondent Costs.

(i) Estimating Labor Costs. Loaded labor rates have been calculated for 2013. We used 

May 2013 labor rates from the Bureau of Labor Statistics for the Ventilation, Heating, AirConditioning and Commercial Refrigeration Equipment Manufacturing (NAICS 333400).

1

Loading factors (i.e., fringe benefits and overhead rates) were calculated using methodologies 

referenced in promulgated regulations and their accompanying ICRs, particularly those used in 

New Source Review regulations. Fringe benefits are calculated as 29 percent of hourly earnings, 

and overhead is calculated using a standard 110 percent above hourly earnings. Table 4 presents 

the labor rates used in the cost analysis.

Table 4. 2013 LOADED LABOR RATES

Labor Category

Hourly 

earnings 

[$2013] Fringe Overhead

Loaded 2013

Hourly 

Earnings ($)

Professional 

specialty and 

technical 31.53 1.29 2.1 $85.41

Executive, admin, 

managerial 54.89 1.29 2.1 $148.70

Admin support 18.22 1.29 2.1 $49.36

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. In this section 

we provide estimated capital costs and one-time start-up costs associated with complying with 

the NSPS over the 3-year ICR clearance period. These costs are summarized in Table 5 at the 

end of this section. Estimated capital costs included in Table 5 include fixed capital cost 

estimates provided by an analysis prepared by Ferguson, Andors & Company for the Hearth, 

 

1 May 2013 National Industry-Specific Occupational Employment and Wage Estimates. Located 

http://www.bls.gov/oes/current/naics4_333400.htm.
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Patio and Barbecue Association.1See the manufacturer costs impacts memo2and the unit cost 

memo3for more information on assumptions used in this section.

As discussed in the manufacturer costs impacts memo, we estimate that there are 

currently 50 model lines of forced-air furnaces produced by 7 manufacturers and 120 model lines 

of hydronic heaters (about 10 percent of which are indoor hydronic heaters) produced by 30 

manufacturers. We assume that of these 170 existing model lines, 47 models (approximately 5 

forced air furnace models and 42 hydronic heater models) will meet EPA criteria as meeting 

Step 1 emission standards and will qualify for conditional certification approval until 2020 and 

will not have to undergo certification testing during the three-year ICR period (2015-2017). We 

assume that a like number of models to replace existing models that currently do not meet the 

Step 1 emission standards (approximately 115 models (45 forced air furnace models and 70

hydronic heater models)) will be developed/tested and will apply to certify to meet Step 1 

emission standards or Step 2 emission standards and would be required by the NSPS to arrange 

for certification testing during the three-year ICR period (2015-2017) at a cost of $55,000 per 

test (assumes EPA testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping 

costs).

4

The final rule requires a permanent label on each hydronic heater and forced-air furnace

model, just as required under subpart AAA. To estimate the costs of permanent labels, we 

assumed the capital costs to be $1,250 per model certified (including those with conditional 

certification) and that all new models produced by manufacturers (170; 120 outdoor hydronic 

heater models, 50 forced-air furnace models) produced by all manufacturers will have a 

permanent label affixed. These costs are consistent with cost estimates provided in Ferguson’s 

analysis.5

 

1

Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. 

Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses, Appendix A: Woodstove Cost Modeling. 

(Available at http://www.regulations.gov/#!documentDetail:D=EPA-HQ-OAR-2009-0734-1643).

2 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts. January 2015.

3 Memorandum to USEPA from EC/R, Inc. Unit Cost Estimates of Residential Wood Heating Appliances. January 

2015.

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Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. 

Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses, Appendix A: Hydronic Heater Cost 

Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA-HQ-OAR-2009-0734-1643); Page 

7, Table 6. Fixed Costs per Model - Certification). May 2014.

5

Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. 

Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses, Appendix A: Hydronic Heater Cost 

Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA-HQ-OAR-2009-0734-1643); Page 
January 2015

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The final NSPS requires that each hydronic heater and forced-air furnace offered for sale 

by a commercial owner be accompanied by an owner’s manual that contains specified 

installation and operation and maintenance information required to be followed to minimize 

emissions. We have assumed an average fixed cost of $3,750 for owner's manual (revised or 

new, possibly bilingual) per model, assuming 170 model owner's manuals will need to be 

developed/revised to include subpart QQQQ requirements. These costs are consistent with cost 

estimates provided in Ferguson’s analysis.1

The final rule includes the requirement for a QA program whereby the manufacturer 

contracts with a third-party certifier to conduct QA audits. The third-party certifier will be 

required to conduct regular (at least annual), unannounced audits (and prepare a report for 

submission to the EPA) of each certified model line to ensure that the manufacturer’s QA plan is 

implemented properly. For purposes of this ICR, we assume that the contracted third-party 

certifier will require one QA performance test and two QA audits for each of the hydronic heater 

and forced-air furnace manufacturers (37 manufacturers) under the QA program between 2015 

and 2017. 

Another category of capital costs includes costs that would be incurred if the EPA 

requests a compliance audit, which would be infrequent and sporadic. Under the final rule, we 

anticipate EPA conducting one audit test for one model that would affect one manufacturer 

during the period covered by this ICR (2015-2017). Costs assume the cost of one appliance 

(based on the average cost of three appliances:1 outdoor ($11,571) and 1 indoor ($11,543) 

hydronic heater and 1 forced-air furnace ($2,579)), plus $55,000 for one test (assumes EPA 

testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs).

The last category of capital costs relates to ISO accreditation costs for test labs and thirdparty certifiers seeking accreditation (at a cost of $75,000/accreditation).

 

7, Table 6. Fixed Costs per Model - Certification). May 2014. 

1

Ferguson, Robert (Ferguson, Andors & Company), prepared for the Hearth, Patio & Barbecue Association. 

Proposed Wood Heater NSPS Incremental Cost Effectiveness Analyses, Appendix A: Hydronic Heater Cost 

Modeling. (Available at http://www.regulations.gov/#!documentDetail:D=EPA-HQ-OAR-2009-0734-1643); Page 

7, Table 6. Fixed Costs per Model - Certification). May 2014.
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TABLE 5. ESTIMATED CAPITAL/START-UP COSTS FOR 3-YEAR 

CLEARANCE PERIOD (2015-2017)

(A) (B) (C) (D)

Data Collection 

Device

Capital/Start-Up for 

One Respondent/Unit

Number of New 

Respondents/Models/Units

Total 

Capital/Start-Up 

Cost

(B X C)

Certification Test a$55,000 per respondent 115 models $6,325,000

Cost of Permanent 

Label b $1,250 per model 170 models $212,500

QA Performance

Test c $55,000 per respondent 37 respondents $2,035,000

EPA Compliance

Audit Test d $63,564 per respondent 1 respondent $63,564

Owner’s Manuale$3,750 per model 170 models $637,500

ISO Accreditation –

Test Laboratoriesf $75,000 per respondent 2 respondents $150,000

ISO Accreditation –

Third-Party 

Certifiersg

$75,000 per respondent 2 respondents $150,000

Total $9,573,564

Annual Average $3,191,188

a Models certified by testing per manufacturer: Assumes that 42% of existing hydronic heater models (.42 X 120

models = 50) and 10% of existing forced air furnace models (.10 X 50 models= 5) will not need to test to certify 

to meet limits during the three-year ICR period (2015-2017). We assume that manufacturers will test (at a cost of 

$55,000 per test (includes EPA testing ($30,000), confirmation safety testing or full safety testing ($22,500), and 

shipping of prototype(s)($2,500) costs)) and apply to meet either Step 1 emission standards or Step 2 emission 

standard for 115 models (70 hydronic heater and 45 forced-air furnace models) during the three year ICR period 

(2015-2017) in order to replace old models that will not meet the 2015 and 2016/2017 (for forced-air furnaces)

compliance emission standards.

b Total costs of permanent labels are estimated to be $1,250 per model (170 models) (2015-2017).

c Assumes each of the manufacturers (37 manufacturers) will be required to test one of their models under their

QA program during the period covered by this ICR (2015-2017) at $55,000 per test ( includes EPA testing 

($30,000), confirmation safety testing or full safety testing ($22,500), and shipping of prototype(s)($2,500) costs).

d Assumes one model line will be audited by EPA during the three-year ICR period (2015 – 2017). Costs assume 

the cost of one appliance (based on the average cost of three appliances: 1 outdoor ($11,571) and 1 indoor 

($11,543) hydronic heater and 1 forced-air furnace ($2,579)) plus the cost of testing at $55,000 (assumes EPA 

testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs).
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e Assumes an average fixed cost of $3,750 for owner's manual (revised or new, possibly bilingual) per model 

certified (assumes 170 model lines from 37 manufacturers).

f Assumes all test labs will be ISO accredited (that are going to choose be accredited) before 2018, a total of four 

labs between 2015 and 2017 and 0 occurrences between 2018 and 2020. We assume an average cost to obtain ISO 

accreditation is $75,000 based on cost estimates provided by manufacturers.

g Assumes all third-party certifiers will be ISO accredited (that are going to choose be accredited) before 2018, a 

total of four labs between 2015 and 2017 and 0 occurrences between 2018 and 2020. We assume an average cost 

to obtain ISO accreditation is $75,000 based on cost estimates provided by manufacturers.

(iii) Annualizing Capital Costs. The total annual capital/start-up costs are estimated to 

average $3,191,188 over the period of this ICR (2015-2017).

(c) Estimating Agency Burden and Cost.

The major costs to the EPA are those costs associated with reviewing applications for 

model certifications, testing lab and third-party certifier accreditations, and ongoing compliance 

verification QA functions. This is consistent with the overall EPA compliance and enforcement 

program, which includes activities such as the examination of records maintained by the 

respondents, periodic inspection of sources of emissions and the publication and distribution of 

collected information.

The average annual agency cost during the 3 years of the ICR is estimated to be $28,630.

See Table 2, located at the end of this supporting statement.

The agency labor rates are from the Office of Personnel Management 2014 General 

Schedule which excludes locality rates of pay. These rates can be obtained from Salary Table 

2014-GS available on the OPM website, http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/salary-tables/pdf/2014/salhrl.pdf. The government employee labor rates are 

$15.78/hour for clerical (GS-6, Step 3), $29.17 for technical (GS-12, Step 1) and $39.31/hr for 

management (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits 

and overhead. The fully-burdened wage rates used to represent agency labor costs are: clerical at 

$25.25; technical at $46.67 and management at $62.90.

(d) Estimating the Respondent Universe and Total Burden and Costs.

Subpart QQQQ requires hydronic heater and forced-air furnace manufacturers, test 

laboratories and third-party certifiers to submit reports to the EPA and/or to maintain records for 

demonstrating and documenting compliance with the NSPS. A third-party certification process is 

required under subpart QQQQ. Under this process, for all heaters/stoves subject to subpart 
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QQQQ, after testing is completed by an approved test laboratory, a certification of conformity 

with the particulate matter emissions standards must be issued by a third-party certifier with 

whom the manufacturer has entered into contract for certification services. To avoid the potential 

for manufacturer model certification delays (and the potential for lost revenues), we are allowing 

automatic conditional certification for hydronic heaters and forced-air furnaces that meet Step 1 

emission standards until the Step 2 emission standards compliance date (2020).

The third-party certifier is an independent third-party that is ISO accredited to perform 

certifications, inspections and audits by an accreditation body. The third-party certifier can 

certify conformity if the emission tests have been conducted per the appropriate guidelines; the 

test report is complete and accurate; the instrumentation used for the test was properly calibrated; 

the test report shows that the representative hydronic heater or forced-air furnace meets the 

applicable emission standards; and the QA plan prepared by the manufacturer is adequate to 

ensure that units within the model line will be similar in all material respects that would affect 

emissions to the wood heater submitted for certification testing. The third-party certifier is also 

required to conduct regular (at least annual) unannounced audits to ensure that the 

manufacturer’s QA plan is being implemented and must prepare a report for each audit that fully

documents the results of the audit. The manufacturer must include in its contract with the thirdparty certifier the authorization and requirement to submit all such reports to the Administrator. 

The ISO accreditation and approval to be third-party certifiers will be required on the effective 

date for hydronic heaters and 6 months after the effective date of the rule for forced-air furnaces. 

We have assumed that two laboratories will be ISO-accredited and will apply to be third-party 

certifiers and two will seek to obtain accreditation and will apply to be third-party certifiers 

during the three-year ICR period (2015-2017).

Test laboratories that want to become approved test laboratories to conduct NSPS 

certification testing will need to apply for ISO accreditation as a test laboratory, conduct 

proficiency testing and report the results of all such testing. Accredited approved test laboratories 

must maintain records of all certification tests, proficiency tests and compliance audit test data.

Approved test laboratories must be approved for hydronic heater and forced air furnace 

certification under subpart QQQQ or must be an independent third-party test laboratory that is 

accredited by a nationally recognized accrediting entity to perform testing using the test methods 

specified in subpart QQQQ. The final rule allows a three-year extension of current EPA 
January 2015

15

accreditations of labs (as approved test laboratories). Laboratories not currently EPA-accredited 

will be required (as of the date 6 months after the effective date of the final rule) to register their 

credentials with the EPA and be approved by the EPA prior to conducting any certification 

testing or related work used as a basis for compliance with subpart QQQQ. Of the 4 labs, we 

assume that 2 will have ISO accreditation as test laboratories by the effective date of the final 

rule and 2 will obtain ISO accreditation as test laboratories during the three-year period covered 

by this ICR (2015-2017).

This ICR assumes that there is an overlap of laboratories that will obtain accreditation 

and approval as approved testing laboratories and as third-party certifiers under subpart QQQQ.

The only subpart QQQQ final rule testing laboratory and third-party certifier recordkeeping and 

reporting burden costs not passed on to the manufacturer would be the burden associated with 

obtaining ISO accreditation, proficiency testing and reporting required for approved test 

laboratories to maintain accreditation and approval as test labs, and specified recordkeeping 

requirements (e.g., certification tests, proficiency tests, QA program inspections, audit test 

results). 

There are an estimated 37 existing manufacturers that will be subject to the Residential 

Hydronic Heater and Forced-Air Furnace NSPS. We recognize that this value may be high. We 

obtained information on the number of existing manufacturers by appliance type, which may

double count manufacturers that make more than one type of appliance. Also, there seems to be a 

certain amount of consolidation in the industry. However, the number of new manufacturers, 

particularly outside of the United States, is unknown. Therefore, we consider the total of 37 

manufacturers to be a reasonable estimate of the number of new and existing manufacturers. 

Manufacturers of new hydronic heaters and forced-air devices are required to submit 

applications for certification of model lines, to submit results of emissions tests conducted to 

demonstrate that the model lines would comply with the emission standards and produce 

certified units according to a QA plan approved by an independent third-party certifier. For 

hydronic heaters, compliance dates with Step 1 and Step 2 emission limits are 2015 and 2020, 

respectively. For forced-air furnaces, compliance with work practice/operational standards is 

required in 2015, and compliance with Step 1 emission limits for small (<65,000 BTU/hr 

models) and large furnaces (> 65,000 BTU/hr models) is required in 2016 and 2017, 

respectively. The final rule allows hydronic heater/forced-air heater models that meet specified 
January 2015

16

EPA criteria that show compliance with the Step 1 emission standards to be automatically 

deemed as certified to meet the Step 1 emission standards under this final rule until the Step 2 

emission standards compliance date (2020). Manufacturers must submit a notification of the 

initial test and biennial reports that each certified model line remains unchanged. They must also 

maintain records of all certification data, maintain results of QA program inspections and 

emissions test data, and seal and store the tested appliance. 

Manufacturers are also required to apply permanent labels on each applicable unit prior 

to sale. These labels provide important compliance information to enforcement officials and 

important information to consumers for purchasing appliances. 

For subpart QQQQ, the components of the total annual responses attributable to this ICR 

are test notifications, applications for certification, biennial reporting for certified models, 

applications for accreditation, test report submittals, QA audit reports and test lab proficiency

reporting for the 41 respondents (37 manufacturers and 4 testing laboratories (including both 

approved test laboratories and third-party certifiers)) that will be subject to the rule. The number 

of total annual responses for subpart QQQQ is estimated at 199.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent Tally. The bottom line respondent burden hours and costs for the 3 years 

(2015-2017) covered by this ICR are presented in Table 1 (located at the end of this supporting 

statement). The average annual burden for the recordkeeping and reporting requirements in 

subpart QQQQ for the estimated 37 manufacturers and 4 laboratories (consisting of both thirdparty certifiers and test laboratories) that will be subject to subpart QQQQ is 2,337 person-hours,

with an annual labor average labor cost of $191,904 (approximately $140,000 for manufacturers, 

$15,000 for third-party certifiers and $36,000 for test laboratories) and annualized capital/startup costs of $3,191,188.

(ii) The Agency Tally. The average annual Federal Government cost is $28,630 for 

629 hours for subpart QQQQ. The bottom line agency burden hours and costs for the 3 years 

covered by this ICR are presented in Table 2 (located at the end of this supporting statement).

(iii) Variations in the Annual Bottom Line. This section does not apply since no 

significant variation is anticipated.
January 2015

17

(f) Reasons for Change in Burden.

We are requesting a burden of an estimated 2,337 hours and annualized capital/startup 

costs of $3,191,188 due to implementation of this new regulation.

(g) Burden Statement

The average annual respondent burden for the New Residential Hydronic Heaters and 

Forced-Air Furnaces NSPS is approximately 57 hours with an average annual burden per 

response of 12 hours. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 60 are listed in 40 CFR part 9.

To comment on the agency’s need for this information the accuracy of the provided 

burden estimates, and any suggestions for minimizing respondent burden, including through the 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID No. EPA-HQ-OAR-2009-0734, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA WJC West Building, Room 3334, 

1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

EPA Docket is (202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in one of 
January 2015

18

the Docket ID Numbers identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID 

Number (EPA-HQ-OAR-2009-0734) and OMB Control Number (2060-NEW) in any

correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection 

associated with the final rule.
January 2015

19

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

Person- No. of Person-hours Respondents Technical Management Clerical Cost,$ bTotal Avg. annual Avg. annual

hours per occurrences per respondent 2015-2017 person-hours person-hours aperson-hours a2015-2017 person-hours person-hours costs

occurrence per respondent 2015-2017 2015-2017 2015-2017 2015-2017 2015-2017

Activity 2015-2017 (C=AxB) (E=CxD) (F=Ex0.05) (G=Ex0.1) (I=E+F+G) (J=I/3) (K=H/3)

Reporting Requirements

Manufacturers

1. Certification test notification c2.00 3.1 6.2 37 230.0 11.5 23.0 $ 22,491 264.5 88.2 $ 7,497

2. Application for certification d8.00 3.1 24.9 37 920.0 46.0 92.0 $ 89,963 1,058.0 352.7 $ 29,988

3. Biennial reporting e 2.00 4.6 9.2 37 340.0 17.0 34.0 $ 33,247 391.0 130.3 $ 11,082

4. EPA compliance audit testing f8.00 1.0 8.0 1 8.0 0.4 0.8 $ 782 9.2 3.1 $ 261

5. QA performance test results g2.00 1.0 2.0 37 74.0 3.7 7.4 $ 7,236 85.1 28.4 $ 2,412

6. QA annual audit report 

h

20.00 37.0 740.0 2 1,480.0 74.0 148.0 $ 127,898 1,702.0 567.3 $ 42,633

7. Review annual QA audit report i 4.00 2.0 8.0 37 296.0 14.8 29.6 $ 26,767 340.4 113.5 $ 8,922

Test Laboratories

1. Application for test lab approval j

a. Already has ISO accreditation 20.00 1.0 20.0 2 40.0 2.0 4.0 $ 4,901 46.0 15.3 $ 1,634

b. Needs to obtain ISO accreditation 80.00 1.0 80.0 2 160.0 8.0 16.0 $ 15,646 184.0 61.3 $ 5,215

2. Biennial proficiency testing and report development k 150.00 1.0 150.0 4 600.0 30.0 60.0 $ 58,671 690.0 230.0 $ 19,557

Third-Party Certifiers

1. Application for approval as a third-body certifier l

a. Already has ISO accreditation 20.00 1.0 20.0 2 40.0 2.0 4.0 $ 3,417 46.0 15.3 $ 1,139

b. Needs to obtain ISO accreditation 80.00 1.0 80.0 2 160.0 8.0 16.0 $ 13,666 184.0 61.3 $ 4,555

Subtotal for Reporting Requirements 4,348.0 217.4 434.8 $ 404,685 5,000.2 1,666.7 $ 134,895

Recordkeeping Requirements

Manufacturers

1. Test documentation m 1.00 4.6 4.6 37 170.0 8.5 17.0 $ 16,624 195.5 65.2 $ 5,541

2. QA parameter inspections n2.00 12.0 24.0 37 888.0 44.4 88.8 $ 86,833 1,021.2 340.4 $ 28,944

3. Retained (sealed) stoves o1.00 3.1 3.1 37 115.0 5.8 11.5 $ 11,245 132.3 44.1 $ 3,748

Test Laboratories

1. Certification test, proficiency test, and audit test results

 p 2.00 36.0 72.0 4 288.0 14.4 28.8 $ 28,162 331.2 110.4 $ 9,387

Third-Party Certifiers

1. Certification test, QA program inspection and audit tests q

2.00 36.0 72.0 4 288.0 14.4 28.8 $ 28,162 331.2 110.4 $ 9,387

Subtotal for Recordkeeping Requirements 1,749.0 87.5 174.9 $ 171,027 2,011.4 670.5 $ 57,009

TOTAL BURDEN AND COST (SALARY) 6,097.0 304.9 609.7 $ 575,712 7,011.6 2,337.2 $ 191,904

TOTAL NUMBER OF RESPONSES 2015-2017 598 Annual avg. 199

a

 Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

b

 Costs are based on the following hourly rates: technical at $88.41, management at $148.70 and clerical at $49.36.

d Model applications per manufacturers: 115 model lines from 37 manufacturers projected from 2015-2017.

f Assumes that one of the 37 manufacturers will be required to undergo an EPA compliance audit test for one of their models during the three-year ICR period (2015-2017).

TABLE 1. THREE-YEAR AND ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL RULE (2015-2017)

c Models certified by testing per manufacturer: Assumes 10% of forced air furnaces (.1 X 50 models = 5) and 42% of hydronic heater (.42 X 120 models = 50) model lines will not need to test to certify to meet emission standards

during the three-year period (2015-2017). We assume that manufacturers will test and apply to meet emission standards for 115 models (45 forced air furnace models and 70 hydronic heater models) during the three year ICR 

period (2015-2017) in order to replace old models that will not meet the 2015 (for hydronic heaters) and 2016/2017 (for forced-air furnaces) compliance emission standards.

h, i Assumes there will be two QA audits by the third-party certifier for each of the 37 manufacturers over the three-year ICR period (2015-2017) and that each of these audit reports will be reviewed by the manufacturer (in all cases) 

and may require preparing a response to the audit (in cases where deficiencies are identified). It is assumed that the third-party certifier will audit multiple manufacturer models when they conduct their audits (thereby reducing the 

time needed to audit manufacturers and their associated models).

e

 For purposes of this ICR, we assume that 170 models will either test and apply to certify to meet Step 1 emission standards/Step 2 emission standards or will obtain a conditional approval as meeting limits. We have assumed 2 

hours per report, and that 1 biennial report will be required for all 170 models (37 manufactures) during the three-year ICR period (2015-2017).

g Assumes that there will be one QA audit performance test per manufacturer (37 manufacturers) under the QA program during the period covered by this ICR (2015-2017). We assume that each of the manufacturers will be required 

to test one model and report results to the EPA under their QA program between 2015 and 2017.
January 2015

20

k Assumes that each of the 4 test laboratories will conduct one biennial proficiency test and prepare one report during the three-year ICR period (2015-2017).

o Assumes one unit sealed for each original certification test (for 115 models) required of the 37 manufacturers.

p We expect the required recordkeeping to be highly automated and have assumed that test laboratories will spend 2 hours per month for the 3-year period of this ICR (2015-2017) to maintain the required records.

q

 We expect the required recordkeeping to be highly automated and have assumed that third-party certifiers will spend 2 hours per month for the 3-year period of this ICR (2015-2017) to maintain the required records.

n Parameter inspections are part of the existing safety inspection program. We have assumed that all manufacturers (37 manufacturers) will spend an additional 2 hours per quarter for the 3-year period of this ICR to document

results.

j Assumes that 4 test laboratories will submit applications for approval as test laboratories during the three-year ICR period (2015-2017). Two of those laboratories will be ISO-accredited and two will need to obtain ISO-accreditation.

l

 Assumes that all 4 test laboratories will submit applications for approval as third party certifiers between 2015 and 2017. Two of those laboratories are assumed to be ISO-accredited and two are assumed to need to obtain ISOaccreditation.

m Assumes that manufacturers will spend 1 hour per certification test (assuming certifications for 170 models) to keep the required records.
A-1

TABLE 2. THREE-YEAR AND ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE FINAL RULE

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

EPA person- No. of EPA person- Respondents Technical Management Clerical Cost,$ b Total Avg. annual Avg. annual

hours per occurrences hours per 2015-2017 person-hours person-hours aperson-hours aperson-hours person-hours costs

occurrence per respondent respondent 2015-2017 2015-2017 2015-2017 2015-2017

2015-2017 2015-2017

Activity (C=AxB) (E=CxD) (F=Ex0.05) (G=Ex0.1) (I=E+F+G) (J=I/3) (K=H/3)

1. Certification test notification c 0.5 3.1 1.6 37 57.5 2.9 5.8 $ 3,010 66.1 22.0 $ 1,003

2. Certification test d20.0 3.1 62.2 6 373.0 18.6 37.3 $ 19,522 428.9 143.0 $ 6,507

3. Application for certification of model line e8.0 3.1 24.9 37 920.0 46.0 92.0 $ 48,154 1058.0 352.7 $ 16,051

4. Biennial reporting for certified models f1.0 4.6 4.6 21 96.5 4.8 9.6 $ 5,050 111.0 37.0 $ 1,683

5. Review and approval of test lab credentials g4.0 1.0 4.0 4 16.0 0.8 1.6 $ 837 18.4 6.1 $ 279

6. Review test lab biennial proficiency test reports h10.0 1.0 10.0 4 40.0 2.0 4.0 $ 2,094 46.0 15.3 $ 698

7. Review QA performance test results i 2.0 1.0 2.0 37 74.0 3.7 7.4 $ 3,873 85.1 28.4 $ 1,291

8. Review QA audit report j 2.0 2.0 4.0 2 8.0 0.4 0.8 $ 419 9.2 3.1 $ 140

9. EPA compliance audit k 40.0 1.0 40.0 1 40.0 2.0 4.0 $ 2,094 46.0 15.3 $ 698

10. Review and approval of third-party certifier credentials l

8.0 1.0 8.0 2 16.0 0.8 1.6 $ 837 18.4 6.1 $ 279

TOTAL BURDEN AND COST (SALARY) 1641.0 82.0 164.1 $ 85,890 1887.1 629.0 $ 28,630

a

 Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

b

 Costs are based on the following hourly rates: technical at $46.67, management at $62.90, and clerical at $25.24. 

c

 Models certified by testing per manufacturer: 115 model lines from 37 manufacturers projected to be tested during the three-year ICR period (2015-2017).

d Assumes that over the long term EPA will observe 5 percent of certification tests, which is rounded to 6 tests observed during the period of this ICR.

e

 EPA must review and approve certification applications: 115 model lines from 37 manufacturers projected to be certified from 2015-2017.

f During the 3-year ICR period, EPA must review 1 biennial report for each certified model line (170 models/37 manufacturers).

g

 Assumes that 4 test laboratories will submit applications for subpart QQQQ testing lab approval (2 that already have ISO accreditation and 2 that do not) between 2015 and 2017.

h

 Assumes that there will be one biennial laboratory proficiency test per laboratory (4 laboratories) during the three-year ICR period (2015-2017).

k Assumes that one model line for one of the 37 manufacturers will be audited by the EPA during the ICR three-year period (2015-2017).

l EPA approval of third-party certifiers for this rule: We assume that two labs will submit applications for approval to the EPA as third-party certifiers during the three-year ICR period (2015-2017). 

I

 Assumes that there will be 37 performance test results submitted under the QA program and reviewed by the EPA during the period covered by this ICR (2015-2017). We assume that each of the hydronic heater and 

forced-air furnace manufactures will be required to test one model and report results to the EPA under their QA program between 2015 and 2017.

j

 Assumes there will be two QA audits by the third-party certifier reviewed by the EPA for each of the 37 manufacturers over the three-year ICR period (2015-2017).
A-2

Attachment 1

Respondent Reporting and Recordkeeping Requirements

NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR part 60, subpart QQQQ) 

Regulatory Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.5475(b), 60.5475(f)(1) Manufacturer Report: Application for a certificate of compliance. 

Include results of certification test, model identification 

information, engineering drawings and component 

specifications (for components that may affect 

emissions), identification of any CBI (as necessary), 

warranty information, owner’s manual, documentation 

of contracts with an approved test laboratory and thirdparty certifier, quality assurance (QA) program and 

various affirmations of compliance.

Once for each model line.

60.5475(g)* Manufacturer Report: Request for waiver from submitting certification 

test results.

Once per model, if at all.

60.5475(i) Manufacturer Report: Renewal of certification. Renewal of certificate 

allowed by reapplying or by affirming in writing that the 

wood heater has been subject to no changes that would 

impact emissions and requesting a waiver from 

certification testing.

Must renew or apply for recertification every 

5 years.

60.5475(k)** Manufacturer Report: Recertification required whenever a change is 

heater design exceeds specified parameters. May request 

a waiver with adequate rationale that changes may not 

reasonably be anticipated to cause wood heaters in the 

model line to exceed the applicable emission limits.

Variable.

60.5475(m) Manufacturer Report: Develop a QA program and submit with 

application for a certificate of compliance.

Report: Review third-party certifier QA audit report and 

submit corrective actions for any identified deficiencies.

Once per model line.

Variable.

60.5475(n)** Manufacturer Report: EPA compliance audit test results. EPA may 

select a hydronic heater or forced-air furnace for 

compliance audit testing. EPA may test or direct the 

manufacturer to test a selected model line; at 

manufacturer’s expense.

Variable and infrequent.

60.5476(f) Manufacturer Report: Notification in advance of compliance 

certification test.

Once per model line, at least 30 days before 

the start of testing.

60.5478(a)-(d) Manufacturer Produce and apply permanent label. One per unit produced.
A-3

Regulatory Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.5478(e)*** Manufacturer Optional requirement. Produce and apply temporary 

label.

Variable/optional.

- Each model that meets 2020 emission 

limits prior to the 2020 compliance date 

may display a temporary label indicating 

that the model meets the 2020 emission 

limits.

- Each model certified to meet the 2020 cord 

wood alternative means of emissions 

limitation compliance option may display

that the model meets the 2020 cord wood 

alternative compliance option.

60.5478(f) Manufacturer Develop and publish owner’s manual. One owner’s manual developed per model 

line; a copy accompanies each unit produced.

60.5479(a) Manufacturer Maintain records of all certification test data, results of 

QA program inspections, emission test data.

Once per model for certification and test 

data. Periodically for all QA inspections and 

tests.

60.5479(c) Manufacturer Retain sealed wood heater for 3 years after the 

certification test of the model.

One for each certified model.

60.5479(d) Manufacturer Report: Certification that model line is unchanged and 

sales for each model by state.

Every 2 years following issuance of a 

certificate of compliance for each model line.

60.5479(f) Manufacturer Report: Performance test data submitted electronically. Within 60 days after completion of each 

performance test.

60.5479(g) Manufacturer For each certified model line, post the non-CBI 

certification test report to the manufacturer’s website.

Once for each model lint, within 30 days of 

receiving the certificate of compliance.

60.5481** Manufacturer Various requests, submittals, motions, filings, etc., 

under hearing and appeal procedures.

Variable and infrequent, if at all.

60.5477(a) Test Laboratory Report: After being accredited by a nationally 

recognized accrediting entity, application for EPA 

approval as a test lab. 

Once (unless not renewed every 5 years by 

the EPA).

60.5477(a), 60.5479(b) Test Laboratory Report: Proficiency test and documentation. Approved 

test labs must participate in a biennial proficiency 

testing program conducted by a nationally recognized 

accrediting entity. Each approved test laboratory must 

submit all proficiency test results to the EPA.

Biennially.

60.5479(b) Test Laboratory Keep records of documentation pertaining to 

certification tests, QA audit tests, including the full test 

report and raw data sheets, technician notes, calculations 

and test results for all test runs.

Once for each certification test, QA audit 

test. 

60.539** Test Laboratory Various requests, submittals, motions, filings, etc., 

under hearing and appeal procedures.

Variable and infrequent, if at all.

60.5475(m), 60.5477(e)(2) Third-Party Certifier Report: Submit report of unannounced QA program 

audits to EPA and the manufacturer.

At least annually.
A-4

Regulatory Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.5477(e) Third-Party Certifier Report: After being accredited by a nationally 

recognized accrediting entity, application for EPA 

approval as a third-party certifier.

Once, to be renewed every 5 years.

60.5479(b) Third-Party Certifier Keep records of documentation pertaining to 

certification tests, QA inspections and audit tests, 

including the full test report and raw data sheets, 

technician notes, calculations and test results for all test 

runs.

Once for each certification test, QA 

inspection and audit test.

60.5479(b) Third-Party Certifier Each certifier must submit each certification test, QA 

inspection report and ISO IEC accreditation credentials 

to the EPA.

Once for each certification test, QA 

inspection and audit test.

60.539** Third-Party Certifier Various requests, submittals, motions, filings, etc., 

under hearing and appeal procedures.

Variable and infrequent, if at all.

* This is associated with an exemption or waiver (which would eliminate other reporting and recordkeeping burdens) and therefore not counted as a burden in the 

calculation. 

** This is not a routine report or is a provision for an extraordinary circumstance and, therefore, is not included in the calculations because it is very unlikely to occur 

during the next 3 years.

*** This is an optional requirement and, therefore, is not included in the calculated burden estimates.
A-5

Attachment 2

Federal Reporting and Recordkeeping Requirements

NSPS for New Hydronic Heaters and Forced-Air Furnaces (40 CFR part 60, subpart QQQQ)

Regulatory Reference

Title 40, Part 60

Agency Reporting/Recordkeeping Frequency/Other Comments

60.5475(c)(1) or (2), 

60.5475(f)(2) or (3)

EPA Report: Review application for a certificate of 

compliance and issue the certificate or a notice of 

denial.

Once per model.

60.5475(i)(2) or (3) EPA Report: Renewal or denial of certificate of compliance. Every 5 years.

60.5475(l)(2)* EPA Report: Notice of revocation of certification. Variable and infrequent, if at all.

60.5475(n)(1)(ii) EPA Report: Notice to manufacturer that a model has been 

selected for an EPA compliance audit test.

Variable and infrequent.

60.5475(n)(3)* EPA Report: Issue notification of suspension or revocation of 

a model’s certification. 

Variable and infrequent, if at all.

60.5477(a) EPA Report: Review test laboratory application and provide 

the test laboratory with a certificate of approval if 

approval criteria are met. If approval not granted, 

provide written notice with rationale.

Test lab approval (unless revoked sooner) 

is valid for 5 years from the date of 

issuance. 

60.5477(b)* EPA Report: Notice of revocation of test laboratory approval 

with basis for revocation and notice of opportunity for a 

hearing.

Variable and infrequent, if at all.

60.5477(e) EPA Report: Review of third-party certifier application and 

provide a certificate of approval if approval criteria met. 

If approval not granted, provide a written notice with 

rationale.

Third-party certifier approval expires 

5 years after being issued unless 

renewed.

60.5477(f)* EPA Report: Notice of revocation of third-party certifier 

approval with basis for revocation and notice of 

opportunity for a hearing.

Variable and infrequent, if at all.

60.5479(b) EPA Evaluation of laboratory proficiency tests submitted by 

test laboratories.

Biennially.

60.5481* EPA Various requests, submittals, motions, filings, etc., 

under hearing and appeal procedures.

Variable and infrequent, if at all.

* This is not a routine occurrence. It is a provision for an extraordinary circumstance and, therefore, is not included in the calculations because it is very unlikely to occur 

during the next 3 years.