January 2015

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SUPPORTING STATEMENT

NSPS for New Residential Wood Heaters

(40 CFR Part 60, Subpart AAA) (Revision)

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 Wood 

Heaters (40 CFR Part 60, Subpart AAA) (Revision), U.S. Environmental Protection Agency

(EPA) tracking number 1176.12, Office of Management and Budget (OMB) Control 

Number 2060-0161.

(b) Short Characterization/Abstract.

This ICR covers information collection requirements in the final revisions of the New 

Source Performance Standards (NSPS) for new residential wood heaters (40 CFR part 60, 

subpart AAA (subpart AAA)). 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 wood 

heater is defined as an enclosed, wood burning appliance capable of and intended for residential 

or space heating and domestic water heating. Unless otherwise specified, these devices include, 

but are not limited to, adjustable burn rate wood heaters, single burn rate wood heaters and pellet 

stoves.

One feature of the NSPS requires emphasis at the outset. That is, the requirements of 

subpart AAA establish a certification program instead of the usual NSPS requirements where

each affected facility is required to demonstrate compliance through performance testing. Under 

the subpart AAA-required certification program, a single wood heater 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 wood heating 

appliances. In order to minimize risks to the environment from intentional or accidental misuse 

of the certification approach, subpart AAA includes several safeguards, some of which entail 

reporting and recordkeeping.

There are approximately 66 manufacturers and 6 laboratories (inclusive of both test labs 

and third-party certifiers) that would be subject to the final amended subpart AAA. Under 
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subpart AAA, wood heater 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 to: (1) ensure that 

best system of emission reduction is being applied to reduce emissions from wood heaters; (2) 

ensure that the wood heater tested for certification purposes is in compliance with the applicable 

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

emission performance characteristics similar to tested models; and (4) 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, assure continued test lab proficiency

and to assist in enforcement and compliance activities.

Subpart AAA does not require any reporting or recordkeeping requirements on wood 

heater 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 wood heater models) that owners and 

operators are directed to follow when installing and operating their wood stoves. 

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 estimates provided during this ICR 

period are for years 2015 to 2017. The recordkeeping and reporting burden cost estimates as a 

result of the subpart AAA final amendments for years 2018 to 2020 are presented in a memo to 

the docket.

1

The recordkeeping and reporting respondent burden estimates included in this 

supporting statement 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.2

You can find the estimated burden to the “Affected Public” listed in Table 1, Three-Year 

 

1 Memorandum to Docket ID Number EPA-HQ-OAR-2009-0734 from EC/R, Inc. 40 CFR Part 60, Subparts AAA 

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

Requirements (Years 2018 to 2020). January 2015.

2 Memorandum to USEPA from EC/R, Inc. Estimated Wood Heater Manufacturer Cost Impacts. January 2015.
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and Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements of the 

Final Amended Rule. The federal government burden associated with the review of reports 

submitted by the respondents is shown below in Table 2, Three-Year and Annual Burden and 

Cost to the Federal Government of the Final Amended 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 enforcement of the standards for 

new residential wood heaters sold or operated in their region. Under subpart AAA, 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 Wood Heaters 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 

requires that the Administrator review and, if appropriate, revise such standards every 8 years. In 

the Administrator's judgment, pollutant emissions from wood heaters cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the 

NSPS was promulgated for this source category at 40 CFR part 60, subpart AAA.

The records and reports required under the amended subpart AAA are necessary for the 

Administrator to confirm the compliance status of new residential wood heaters sold in the 
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United States. These recordkeeping and reporting requirements are authorized by CAA section 

114. 

(b) Practical Utility/Users of the Data.

The control of pollution from new residential wood heaters relies on the reduction of 

particulate matter emissions by proper wood heater 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 wood 

heaters manufactured subsequent to the initial certification test continue to comply with the 

NSPS. Manufacturers must renew or recertify their wood heater 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 standards, 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 emissions 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 

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. The information-gathered under the final amended subpart AAA will replace 

the information gathered under subpart AAA prior to being amended.

Similar requirements to this amended NSPS are found in the requirements to 40 CFR 

part 60, subpart QQQQ, the NSPS for New Residential Hydronic Heaters and Forced-Air 

Furnaces. Subpart QQQQ 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 
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certifiers, similar test accreditation requirements are found in both subparts, 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 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 amendments were 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. EPA-HQ-OAR-2009-0734.

TABLE 3. PERSONS CONSULTED ON THE INFORMATION COLLECTION 

ACTIVITIES

Contact Organization Telephone Number

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

Bob Ferguson Ferguson, Andors & Company 802.763.2339

Stephen Hartsfield National Tribal Air Association 505.242.2175

Mike Haefner American Energy Systems 320.587.6565

Dan Henry Hearth & Home Technologies 509.685.8904

Ben Myren Myren Consulting, Inc. 509.684.1154

Chris Neufeld Blaze King Industries 509.522.2730

Mitch Pisik Breckwell Hearth Products 817.652.9602

Lisa Rector Northeast States for Coordinated Air Use 

Measurement (NESCAUM)

617.259.2095

Rod Tinnemore Washington State Department of Ecology 360.407.6978

Steve Vogelzang Vogelzang International, Inc. 616.396.1911

Paul Williams United States Stove Company 423.837.2100
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(d) Effects of Less Frequent Collection.

Less frequent information collection would decrease the margin of assurance that 

manufacturers are producing residential wood heaters 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 

because the required emission standard model certifications are 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 EPA 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.

(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 AAA are manufacturers of new residential wood 

stoves and pellet heaters. The North American Industry Classification System (NAICS) code for 

residential wood heating manufacturing facilities is 333414, Heating Equipment (Except for 

Warm Air Furnace Manufacturing). Subpart AAA also applies to laboratories that conduct or 

plan to conduct wood heater certification tests (referred herein as testing labs) and laboratories 
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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 Wood Heaters (40 CFR part 60, subpart 

AAA). The reporting requirements for NSPS subpart AAA were uniquely designed for the 

manufacturers, third-party certifiers and testing laboratories. The records required by this 

regulation must be retained by the manufacturer, third-party 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

amended New Residential Wood Heater NSPS 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 EPA activities associated with the final amended New Residential 

Wood Heater NSPS are provided in Table 2 (located at the end of this supporting statement) and

are introduced in section 6(c).

(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.
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(c) Small Entity Flexibility.

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

amended subpart AAA 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 smallest businesses affected by this regulation. For heaters/stoves with EPA 

certification currently in effect with Step 1 emission standards, we are giving conditional, 

automatic certification approval until the Step 2 emission standards effective date (2020). 

Allowing conditional, automatic certification of those heaters/stoves with compliant

certifications and including phased compliance dates in the final rule allows additional time for 

sources to come into compliance and helps reduce the burden on small businesses by spreading 

out research and development (R&D) costs over several years. We have also retained 

certification waiver provisions in the existing subpart AAA because they reduce the need for 

sources to re-test already certified models under qualifying conditions and reduce the burden 

associated with the certification process for small manufacturers of wood heaters. The final rule 

also includes changes to the QA program requirements that align better with existing safety QA

procedures, thus eliminating duplicative procedures. Lastly, we have also deferred the 

requirement for (1) EPA-accredited test labs to be accredited under subpart AAA for three years 

after the effective date of the rule and (2) non EPA-accredited test labs to be accredited under 

subpart AAA for six months after the effective date of the rule. 

(d) Collection Schedule.

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

shown in Table 1 for the residential wood heater source category, which is located at the end of 

this supporting statement.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual recordkeeping and reporting respondent burden estimates for the New 

Residential Wood Heater NSPS final amended rule are shown in Table 1, located at the end of 

this section. These numbers were derived from estimates based on the EPA’s experience with 

implementing existing subpart AAA and other standards.
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(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).

3

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 (NSR) 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 three-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, 

Patio and Barbecue Association.4See the manufacturer costs impacts memo5and the unit cost 

memo6for more information on assumptions used in this section. Note that these cost impacts 

differ from ICR 1176.11 based on new information on the structure of the industry and the final 

 

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

http://www.bls.gov/oes/current/naics4_333400.htm.

4

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).

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

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

2015.
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amendments made to subpart AAA that would result in additional expenses during the three-year 

ICR clearance period in order for all models to comply with the final standards.

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

125 model lines of adjustable burn rate stoves produced by 34 manufacturers, 20 model lines of 

single burn rate stoves produced by 3 manufacturers and 125 model lines of pellet stoves 

produced by 29 manufacturers. We assume that 90% of existing adjustable burn rate models (0.9 

X 125 models = 112.5)(34 manufacturers), 25% of existing pellet stove models (0.25 X 125 

models = 31.25)(29 manufacturers), and 0% of single burn rate stove models (0 X 20 = 0) (3 

manufacturers) will meet EPA criteria as meeting Step 1 emission standards, and therefore will 

not need to test or apply for certifications 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 126 models) will be developed/tested and will apply to 

certify to meet the Step 1 emission standards or Step 2 emission standards during the three-year 

ICR period (2015-2017) at a cost of $16,750 per test (includes EPA-required testing ($11,000), 

confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)($750) 

costs).

7

The amended NSPS requires a permanent label on each wood heater model. To estimate 

the capital costs of the permanent label, we assumed the capital costs to be $400 per model 

certified (including those that receive conditional certification) and that all new models produced 

by all manufacturers to meet subpart AAA will have a permanent label affixed. These costs are 

consistent with cost estimates provided in Ferguson’s analysis.8

The amended NSPS requires that each wood heater 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 $2,250 for owner's manual (revised or new, possibly bilingual) per 

model, assuming 125 pellet stoves, 44 adjustable burn rate stoves and 20 single burn rate stove 

 

7

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); Page 8, Table 5. 

Fixed Costs per Model: Certification).

8

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); Page 8, Table 5. 

Fixed Costs per Model: Certification). May 2014.
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owner's manuals will need to be developed/revised to include subpart AAA requirements. These 

costs are consistent with cost estimates provided in an analysis prepared for the Hearth, Patio & 

Barbecue Association (HPBA) by Ferguson, Andors & Company.

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The 1988 requirements for manufacturer QA programs are strengthened in the revised 

rule by requiring the manufacturer to contract 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 one QA audit for each 

of the wood stove manufacturers (66 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. We assume that there 

would only be one EPA compliance audit during the three-year ICR period (2015-2017) that 

would affect one manufacturer. For purposes of estimating the capital costs that would be 

incurred by an EPA compliance audit, we assume the cost of one appliance (based on the 

average of two appliances: 1 adjustable burn rate model ($848 each) and 1 pellet ($1,281 each) 

stove model) plus $16,750 for testing (includes EPA-required testing ($11,000), confirmation 

safety testing or full safety testing ($5,000), and shipping of prototype(s) ($750) costs).

The last category of capital costs relates to ISO accreditation costs for test labs and thirdparty certifiers seeking accreditation (assuming a cost of $75,000/accreditation). Table 5 presents 

the estimated capital/start-up costs for the three-year clearance period (2015-2017).

 

9

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); Page 8, Table 5. 

Fixed Costs per Model: Certification). May 2014.
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TABLE 5. ESTIMATED CAPITAL/START-UP COSTS FOR THREE-YEAR 

CLEARANCE PERIOD (2015-2017)

10

(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$16,750 per respondent 126 models $2,110,500

Cost of Permanent Label b$400 per model 270 models $108,000

QA Performance Test c$16,750 per respondent 66 respondents $1,105,500

EPA Compliance Audit 

Test d $17,815 per respondent 1 respondent $17,815

Owners Manuale$2,250 per model 270 models $607,500

ISO Accreditation-Test 

Laboratoriesf $75,000 per respondent 4 respondents $300,000

ISO Accreditation-ThirdParty Certifiersg $75,000 per respondent 2 respondents $150,000

Totals $4,399,315

Annual average $1,466,438

a Models certified by testing per manufacturer: Assumes that 90% of existing adjustable burn rate models (.9 X 125 models = 

112.5)(34 manufacturers), 25% of existing pellet stove models (.25 X 125 models=31.25)(29 manufacturers), and 0% of single 

burn rate stove models (0 X 20 = 0) (3 manufacturers) will not need to test and apply to certify to meet emission standards

during the three-year ICR period (2015-2017). We assume that manufacturers will test (at a cost of $16,750 per test (includes 

EPA testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)($750) costs)) and 

apply to meet emission standards for 126 models during the three-year ICR period (2015-2017) in order to replace old models 

that will not meet the Step 1 emission standards.

b Total costs of permanent labels are estimated to be $400 per model. We estimate that there will be 270 certified models 

produced by all manufacturers (66 manufacturers) during the period covered by this ICR (2015-2017) that would be subject to 

permanent labeling requirements.

c Assumes that there will be 66 QA performance tests (at a cost of $16,750 per test (includes EPA testing ($11,000), 

confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)($750) costs)) under the QA program 

during the three-year period covered by this ICR (2015-2017). We assume that each of the 66 manufacturers will be required to 

test one model under their QA program between 2015 and 2017.

d Assumes that there will be EPA compliance audit testing for one model affecting one manufacturer during the period covered 

by this ICR (2015-2017). Costs for EPA compliance audit testing of one model assumes the cost of one appliance (based on the 

average cost of two models: 1 adjustable burn rate model ($848 each) and 1 pellet ($1,281 each) stove model)) plus $16,750 for 

the test (includes EPA testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)

($750) costs).

e Assumes an average fixed cost of $2,250 for owner's manual (revised or new, possibly bilingual) per model (270 models) that 

 

10 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); Page 8, Table 5. 

Fixed Costs per Model: Certification). 
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will need to be developed/revised to include subpart AAA requirements.

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 costs estimates provided by manufacturers.

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

third-party certifiers 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 $1,466,438 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 $32,603.

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

The agency labor rates are from the Office of Personnel Management (OPM) 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 AAA requires wood heater manufacturers, test laboratories and third-party 

certifiers to submit reports and/or to maintain records for demonstrating and documenting

compliance with the NSPS. A third-party certification process is required under subpart AAA. 

Under this process, for all heaters/stoves subject to subpart AAA, 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. In order to avoid the potential for manufacturer model 
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certification delays (and the potential for lost revenues), subpart AAA allows for automatic 

certification for wood heaters that meet Step 1 emission standards until the Step 2 emission 

standard 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. Accredited third-party certifiers 

under subpart AAA must maintain records of all certification tests, QA program inspections and 

QA audit performance tests. 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 affected wood heater meets the applicable emission limits; 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 third-party certifier the authorization and requirement to 

submit all such reports to the Administrator. The ISO accreditation and approval to be third-party

certifiers will not be required until 6 months after the effective date of the rule. We have assumed 

that of the 6 labs, 2 will have ISO accreditation as third-party certifiers by the effective date of 

the final amended rule and 2 will choose to obtain ISO accreditation as third-party certifiers 

during the period covered by this ICR (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 wood heater certification under subpart AAA 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 AAA. The final 

rule allows a three-year extension of current EPA accreditations of labs (as approved test 

laboratories). We assume that 6 laboratories will submit applications to become approved test 

labs between 2015 and 2017. Current EPA-accredited laboratories may retain their accreditation 
January 2015

15

and may conduct testing as approved test labs until 3 years after the effective date of this rule. 

Two of the labs are assumed to already be ISO-accredited and will need to apply to be approved 

test laboratories for subpart AAA testing and four labs are assumed to need to obtain ISOaccreditation and apply to be approved test labs for subpart AAA testing.

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 AAA. 

The only final amended subpart AAA 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 66 existing manufacturers that will be subject to the New 

Residential Wood Heater 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 66 

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

Manufacturers of new residential wood heating 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 limits and produce certified 

units according to a QA plan approved by an independent third-party certifier. The final rule 

allows heaters/stove models that meet specified 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.

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. 
January 2015

16

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. The amended rule also specifies 

that manufacturers have the option of using temporary labels for the cleanest heaters in order to 

provide consumers the ability to select wood heaters that meet or exceed the Step 2 emission 

standards prior to the Step 2 emissions standards 2020 compliance date. Temporary labels may

also be used to indicate wood heaters that meet Step 2 emission standards based on cord wood 

instead of crib wood, allowing consumers to select heaters better tuned to in-home performance.

For the final amended New Residential Wood Heater NSPS, 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 72 respondents (66 manufacturers and 6 

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 AAA is estimated at 246.

(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 AAA for the estimated 72 respondents (66 manufacturers and 6 laboratories (including 

approved test labs and third-party certifiers)) that will be subject to the New Residential Wood 

Heater NSPS is estimated to be 2,947 person-hours, with an estimated average annual labor cost 

of $250,551 (approximately $179,000 for manufacturers, $16,000 for third-party certifiers and 

$55,000 for test laboratories) and estimated annual capital/start-up costs of $1,466,438.

(ii) The Agency Tally. The average annual federal government cost is approximately

$32,603 for approximately 716 hours for subpart AAA. 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.

(f) Reasons for Change in Burden.
January 2015

17

This ICR requests a reduction in 8,802 total annual labor hours (11,74911- 2,947) and an 

associated decrease in total annual respondent burden cost for reporting and recordkeeping of 

$898,661 ($1,149,21212- $250,551). This ICR requests a decrease in the total annual capital and 

operation and maintenance costs of $269,637 ($1,736,07513- $1,466,438). The predominant 

reason for the changes in costs/burden is the result of revisions to the NSPS (program changes). 

The amendments to subpart AAA will have several major impacts. 

The first of these is the change in the number of affected appliances because of the 

inclusion of single burn rate stoves and all wood-burning pellet stoves. Although this change 

increases the number of certification applications and certification tests to be processed over the 

clearance period for those models that do not qualify for automatic certification with the Step 1 

emission standards, it is important to note that by the final rule allowing for automatic 

certification with the Step 1 emission standards for those models that hold certificates that meet 

the EPA’s criteria as meeting the Step 1 emission standards, the number of certification 

tests/applications in the initial three-year ICR period focuses on only those wood stove models 

that have not yet demonstrated that they can meet the Step 1 emission standards.

The second impact results from changes in calculating estimates for permanent labels for 

new models. Previously, we estimated costs for permanent labels based on the number of units 

shipped. Our new estimates calculate costs based on the number of model lines consistent with 

cost estimates provided in an analysis prepared for the Hearth, Patio & Barbecue Association 

(HPBA) by Ferguson, Andors & Company.

14

The third impact results from changes to the QA requirements and use of a third-party 

certifier certification process. The focus in the three-year clearance period will be for 

manufacturers to design and certify stoves to meet the new emission limits (where necessary) as 

demonstrated through certification testing and to begin to implement the new QA-related 

provisions. The new QA and third-party certifier certification process provisions of the revised 

subpart AAA are implemented in order to ensure initial and continuing compliance with the 

 

11 NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal), EPA ICR Number 1176.11, 

OMB Control Number 2060-0161. (See 

http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201311-2060-010

12 See Footnote 11.

13 See Footnote 11.

14 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); Page 8, Table 5. 

Fixed Costs per Model: Certification). May 2014.
January 2015

18

applicable emission limits. In the long run, the combination of the use of ISO third-party certifier 

and test laboratories should streamline the certification and accreditation process for the industry

and laboratories and decrease the amount of time spent by the EPA in reviewing QA-related 

documents. These changes, combined with increasing automation and experience in complying 

with this standard result in less capital and operation and maintenance costs as well as 

recordkeeping and reporting burden.

The fourth impact results from changes to streamline reporting and recordkeeping 

requirements to those that are essential for implementation and enforcement of the rule and that 

reflect the agency’s experience under the current subpart. For example, we no longer use the 

number of units sold as the trigger for model line QA audits, so it is no longer important for 

retailers to track the number of units sold. These changes reduce industry burden, while 

simultaneously not affecting the agency’s ability to enforce the standard. We have also carefully 

reviewed the requirements included in this supporting statement to focus on activities that 

routinely occur. For example, revocation of certification and/or laboratory accreditation is 

extremely rare and is not reflected in this estimate of reporting and recordkeeping. Instead, we 

have focused on the routine activities that serve to demonstrate that sources are in compliance 

with the rule.

The fifth impact results from changes in labor rates used. The labor rates used are greater 

for managerial and slightly less for technical and clerical than those used in the currently

approved ICR based on May 2013 labor rates obtained from the Bureau of Labor Statistics for 

the Ventilation, Heating, Air-Conditioning and Commercial Refrigeration Equipment 

Manufacturing (NAICS 333400).

15

(g) Burden Statement

The average annual respondent burden for the final Residential Wood Heating NSPS is 

approximately 41 hours with an approximate 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 

 

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

http://www.bls.gov/oes/current/naics4_333400.htm.
January 2015

19

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 the 

Docket ID Number 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 (2060-0161) in any correspondence.

PART B

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

associated with this final rule.
January 2015

20

(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 1.9 3.8 66 252.5 12.6 25.3 $ 24,691 290.4 96.8 $ 8,230

2. Application for certification d8.00 1.9 15.3 66 1,010.0 50.5 101.0 $ 98,763 1,161.5 387.2 $ 32,921

3. Biennial reporting e 2.00 4.1 8.2 66 540.0 27.0 54.0 $ 52,804 621.0 207.0 $ 17,601

4. EPA compliance audit testing f 8.00 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 66 132.0 6.6 13.2 $ 12,908 151.8 50.6 $ 4,303

6. QA annual audit reports h20.00 16.5 330.0 4 1,320.0 66.0 132.0 $ 129,077 1,518.0 506.0 $ 43,026

7. Review annual QA audit report i 4.00 1.0 4.0 66 264.0 13.2 26.4 $ 25,815 303.6 101.2 $ 8,605

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 $ 3,911 46.0 15.3 $ 1,304

b. Needs to obtain ISO accreditation 80.00 1.0 80.0 4 320.0 16.0 32.0 $ 31,291 368.0 122.7 $ 10,430

2. Biennial profiency testing and report development k 150.00 1.0 150.0 6 900.0 45.0 90.0 $ 88,007 1,035.0 345.0 $ 29,336

Third-Party Certifier

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

a. Already has ISO accreditation 20.00 1.0 20.0 2 40.0 2.0 4.0 $ 3,911 46.0 15.3 $ 1,304

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

Subtotal for Reporting Requirements 4,986.5 249.3 498.7 $ 487,607 5,734.5 1,911.5 $ 162,536

Recordkeeping Requirements

Manufacturers

1. Test documentation m 1.00 4.1 4.1 66 270.0 13.5 27.0 $ 26,402 310.5 103.5 $ 8,801

2. QA parameter inspections n 2.00 12.0 24.0 66 1,584.0 79.2 158.4 $ 154,892 1,821.6 607.2 $ 51,631

3. Retained (sealed) stoves o 1.00 1.9 1.9 66 126.3 6.3 12.6 $ 12,345 145.2 48.4 $ 4,115

Test Laboratories

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

 p 2.00 36.0 72.0 6 432.0 21.6 43.2 $ 42,243 496.8 165.6 $ 14,081

Third-Party Certifier

1. Certification test, QA program inspection and audit tests q2.00 36.0 72.0 4 288.0 14.4 28.8 $ 28,162 331.2 110.4 $ 9,387

Subtotal for Recordkeeping Requirements 2,700.3 135.0 270.0 $ 264,045 3,105.3 1,035.1 $ 88,015

TOTAL BURDEN AND COST (SALARY) 7,686.8 384.3 768.7 $ 751,652 8,839.8 2,946.6 $ 250,551

TOTAL NUMBER OF RESPONSES 2015-2017 738 Annual avg. 246

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 $85.41, management at $148.70 and clerical at $49.36.

d Model applications per manufacturer: 126 model lines (see table note "c") from 66 manufacturers projected from 2015-2017.

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

e

 For purposes of this ICR, we assume that 270 models will either test and apply to certify to meet limits 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 270 models (66 manufactures) during the three-year ICR period (2015-2017).

c

 Models certified by testing per manufacturer: Assumes that 90% of existing adjustable burn rate models (.9 X 125 models = 112.5)(34 manufacturers), 25% of existing pellet stove models (.25 X 125 models = 31.25)(29 

manufacturers), and 0% of single burn rate stove models (0 X 20 = 0) (3 manufacturers) will not need to test and apply to certify to meet limits during the three-year ICR period (2015-2017) . We assume that manufactures will test 

and apply to meet limits for 126 models during the three-year ICR period (2015-2017) in order to replace old models that will not meet the 2015 compliance emission standards.

f Assumes that one of the 66 manufacturers will be required to undergo an EPA compliance audit test for one of their models during the three-year ICR period (2015-2017).

g Assumes that there will be one QA audit performance test per manufacturer (66 manufacturers) under the QA program during the period covered by this ICR (2015-2017). We assume that each of the 66 manufacturers will be 

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

h, i Assumes there will be one QA audit by the third-party certifier for each of the 66 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). 
January 2015

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m We have assumed that manufacturers will spend one hour per certification test (for 270 models) to keep the required records.

q We expect the required recordkeeping to be highly automated and have assumed that third-party certifiers (4 third party certifiers) will spend 2 hours per month for the 3-year period of this ICR to maintain the required records.

o

 It is assumed that one stove is sealed and retained for each certification test (assuming 126 certification tests) required of the 66 manufacturers that certify to meet limits (does not include models that obtain automatic certification).

p We expect the required recordkeeping to be highly automated and have assumed that test laboratories (6 laboratories) will spend 2 hours per month for the 3-year period of this ICR to maintain the required records.

k We assume there will be one biennial proficiency test and report per testing lab (6 labs) required during the three-year ICR period (2015-2017). 

l We assume that 4 laboratories will submit applications for approval as third-party certifiers between 2015 and 2017. Two of those laboratories will be ISO-accredited and two will need to obtain ISO-accreditation.

n Parameter inspections are part of the existing safety inspection program. We have assumed each of the 66 wood stove manufacturers that certifies model lines between 2015-2017 will spend an additional 2 hours per quarter 

during the 3-year period of this ICR (2015-2017) to document results.

j

 Assumes that 6 laboratories will submit applications to be approved as test laboratories for subpart AAA during the three-year ICR period (2015-2017). We assume that two of those laboratories will already be ISO-accredited as test

laboratories and four will need to obtain ISO-accreditation as test laboratories. 
January 2015

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TABLE 2. THREE-YEAR 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 a2015-2017 person-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 1.9 1.0 66 63.1 3.2 6.3 $3,304 72.6 24.2 $ 1,101

2. Certification test d20.0 1.9 38.3 6 229.5 11.5 23.0 $12,015 264.0 88.0 $ 4,005

3. Application for certification of model line e8.0 1.9 15.3 66 1,010.0 50.5 101.0 $52,865 1,161.5 387.2 $ 17,622

4. Biennial reporting for certified models f1.0 4.1 4.1 66 270.0 13.5 27.0 $14,132 310.5 103.5 $ 4,711

5. Review and approval of test lab credentials g4.0 1.0 4.0 6 24.0 1.2 2.4 $1,256 27.6 9.2 $ 419

6. Review test lab biennial proficiency test reports

 h 10.0 1.0 10.0 6 60.0 3.0 6.0 $3,140 69.0 23.0 $ 1,047

7. Review QA performance test results i 2.0 1.0 2.0 66 132.0 6.6 13.2 $6,909 151.8 50.6 $ 2,303

8. Review QA audit report j2.0 1.0 2.0 4 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 4 32.0 1.6 3.2 $1,675 36.8 12.3 $ 558

TOTAL BURDEN AND COST (SALARY) 1,868.7 93.4 186.9 $97,809 2,149.0 716.3 $ 32,603

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: 126 model lines from 66 manufacturers projected during the three-year ICR period (2015-2017). Assumes that it will take 30 minutes to review certification test notifications.

e

 EPA must review and approve certification applications: 126 model lines from 66 manufacturers during the three-year ICR period (2015-2017).

f

 Assumes that the EPA will receive one biennial report for 270 models (66 manufacturers) over the 3-year ICR period (2015-2017.

g

 Assumes that 6 test laboratories will submit applications for subpart AAA testing approval (2 that already have ISO accreditation and 4 that do not) between 2015 and 2017.

h Assumes that there will be one biennial laboratory proficiency test per laboratory (6 laboratories) during the three-year ICR period (2015-2017).

k Assumes that one model line for one of the 66 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 4 labs will submit applications for approval to the EPA as third-party certifiers during the three-year ICR period (2015-2017). 

d Assumes that over the long term the EPA will observe 5 percent of certification tests (126 X .05) conducted during the ICR reporting period, which is rounded to 6 tests observed during the period of this ICR (2015-2017).

i

 Assumes that there will be 66 QA emissions 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 66 manufacturers 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 one QA audit by the third-party certifier reviewed by the EPA for each of the 66 manufacturers over the three-year ICR period (2015-2017).
January 2015

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Attachment 1

Respondent Reporting and Recordkeeping Requirements

NSPS for New Residential Wood Heaters (40 CFR part 60, subpart AAA) (Revision)

Regulatory Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.533(b), 60.533(f)(1) Manufacturer Report: Application for a certificate of compliance. 

Report is to include results of certification test, model 

identification information, engineering drawings and 

component emissions specifications (for components 

that may affect emissions), identification of CBI (as 

necessary), warranty information, owner’s manual, 

documentation of contract with approved laboratory and 

third-party certifier, quality assurance (QA) program 

and various other affirmations of compliance. 

Once for each model line.

60.533(g)* Manufacturer Report: Waiver from submitting test results. May apply 

for a waiver of the requirement to submit the results of a 

certification test. 

Once per model, if at all.

60.533(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.

60.533(k)** Manufacturer Report: Recertification required whenever a change in 

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.

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

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.

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

select a wood heater for compliance audit testing. EPA 

may test or direct the manufacturer to test a selected 

model line; at manufacturer’s expense.

Variable and infrequent.

60.534(g) Manufacturer Report: Notification of in advance of compliance 

certification test.

Once for each model line, at least 30 days before 

the start of testing.

60.536(a) Manufacturer Produce and apply permanent label. One per unit produced.
January 2015

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60.536(f)*** 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.

60.536(g) Manufacturer Develop and publish owner’s manual. One owner’s manual developed per model line; a 

copy accompanies each unit produced.

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

QA program inspections and emission test data.

Once per model for certification test data. 

Periodically for QA inspections and tests. 

60.537(c) Manufacturer Retain sealed wood heater at facility for 5 years after 

certification test of model.

One for each model certified. 

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

sales data for each model by state.

Every 2 years following issuance of a certificate of 

compliance for each model line.

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

performance test.

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

certification test report to the manufacturer’s website

Once for each model line, within 30 days of 

receiving the certificate of compliance.

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

under hearing and appeal procedures.

Variable and infrequent, if at all.

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

recognized accrediting entity, application for EPA 

approval as a test lab. Laboratories previously accredited 

by the EPA may continue to be accredited and deemed 

EPA approved for testing under this rule until 3 years 

after the effective date of the rule.

Once (unless not renewed every 5 years by the 

EPA).

60.535(a)(2)(i), 

60.537(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.

60.537(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.

60.533(m), 60.535(e)(2) Third-Party Certifier Report: Submit report of unannounced QA program At least annually.
January 2015

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

calculation. 

** This is not a routine report. 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.

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

audits to EPA and the manufacturer

60.535(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.

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

certification tests, QA inspection 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/QC inspection 

and audit test. 

60.537(b) Third-Party Certifier Report: Each certifier must submit each certification 

test, QA inspection report and ISO IEC accreditation 

credentials to the EPA.

Once for each certification test, QA/QC 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.
January 2015

A-5

Attachment 2

Federal Reporting and Recordkeeping Requirements

NSPS for New Residential Wood Heaters (40 CFR part 60, subpart AAA) (Revision)

Regulatory Reference

Title 40, Part 60

Agency Reporting/Recordkeeping Frequency/Other Comments

60.533(c)(1) or (2), 

60.533(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 line.

60.533(i)(3) or (4) EPA Report: Renewal or denial of certificate of compliance. Every 5 years.

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

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

selected for an EPA compliance audit test.

Variable and infrequent

60.533(n)(3)* EPA Report: Notification of suspension or revocation of a 

model’s certification. 

Variable and infrequent, if at all.

60.535(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. 

60.535(b)(2)* EPA Notice of intention to revoke test laboratory approval 

with justification and basis.

Variable and infrequent, if at all.

60.535(e)(3) 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.

60.535(f)(2)* EPA Notice of intention to revoke third-party certifier 

approval with justification and basis.

Variable and infrequent, if at all.

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

test laboratories.

Biennially.

60.539* 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.