SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) 

(Renewal), EPA ICR Number 1176.11, OMB Control Number 2060-0161.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for New Residential Wood Heaters (40 

CFR Part 60, Subpart AAA) were: proposed on February 18, 1987; promulgated on February 26, 

1988; and was last-amended on October 17, 2000. These regulations apply to each wood heater 

manufactured either on or after July 1, 1988, or sold at retail either on or after July 1, 1990. 

Wood heaters manufactured either on or after July 1, 1990, or sold at retail either on or after July

1, 1992, must meet more stringent emission standards. Particulate matter (PM) is the pollutant 

regulated under these standards. This information is being collected to assure compliance with 40 

CFR part 60, subpart AAA.

Two features of this rulemaking which are unique to the NSPS program require emphasis 

at the outset. First, these standards were negotiated by representatives of groups affected by the 

NSPS, including those groups which are burdened by the information collection activities. None 

of these activities were judged to be unreasonable by these representatives. Some of these 

provisions were recommended by the affected groups as a means of promoting an efficient and 

smooth running certification and enforcement program. Second, these regulations established a 

certification program instead of the usual NSPS requirement that each affected facility 

demonstrates compliance through New Source Review and testing. Under this certification 

program, a single wood heater is tested to demonstrate compliance for an entire model line which 

could consist of thousands of stoves. The certification approach significantly reduces the 

compliance burden, including information collection for the manufacturers of wood heaters. 

Because of the potential risks to the environment from the intentional or accidental misuse of the 

certification approach, there were several safeguards included, some of which entail reporting and 

recordkeeping requirements.

Under this regulation, wood heater manufacturers, testing laboratories, and retailers are 

required to submit reports to the Environmental Protection Agency (EPA) and/or to maintain 

records for demonstrating compliance with the NSPS.

The information supplied by the manufacturer to the Agency is used to: (1) ensure that 

best demonstrated technology 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 
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performance characteristics similar to tested models; and (4) provide an indicator of continued 

compliance.

Information supplied to the Agency by testing laboratories is used to grant or deny

laboratory accreditation, and to assist in enforcement and compliance activities. Information 

requested by the Agency from manufacturers is used to determine compliance with requirements 

that are based upon volume of production.

Over the next three years, an average of 66 manufacturers, 875 retailers, and 6 

certification laboratories, for a total of 947 respondents, are currently subject to the regulations. 

It is estimated that no additional sources per year will become subject to these standards.

“The active (previous) ICR had the following Terms of Clearance (TOC):”

Prior to submission of a request to extend this collection, the Agency

should reassess estimates of burden, taking into account recent

experience with the program. In particular, the Agency should verify

estimates of the number of affected entities and individual models for 

which information must be submitted.

EPA has addressed the TOC by updating respondent estimates using the latest data 

obtained during development of proposed revisions to the NSPS. These estimates have been 

verified through consultations with industry. The comments that EPA received from these 

consultations are discussed in Section 3(c).

The “Affected Public” are manufacturers of new residential wood heaters, retailers, and 

accredited testing laboratories. The “burden” to the “Affected Public” may be found below in 

Table 1: Annual Respondent Burden and Cost – NSPS for New Residential Wood Heaters (40 

CFR Part 60, Subpart AAA) (Renewal). The “burden” to the Federal Government is attributed 

entirely to work performed by either Federal employees or government contractors, and may be 

found below in Table 2: Average Annual EPA Burden and Cost – NSPS for New Residential 

Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal). 

2. Need for and Use of the Collection

2(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 technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 
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Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years.

In addition, section 114(a) states that the Administrator may require any owner/operator 

subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; (C) 

install, use, and maintain such monitoring equipment, and use such 

audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); and 

(G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, PM emissions from wood heaters cause or contribute to 

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

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

2(b) Practical Utility/Users of the Data

The control of pollution from new residential wood heaters (i.e., wood stoves) relies on 

the reduction of particulate matter emissions by proper wood heater design. A representative unit 

for each certified model line is tested for particulate emissions. The manufacturer also conducts 

periodic quality assurance inspections and emissions tests to ensure that wood heaters 

manufactured subsequent to the initial certification test continue to comply with the NSPS. 

Manufacturers must recertify their wood heater model lines every five years.

The required notifications are used to inform the Agency or delegated authority when a 

new model line is expected to be tested. The reviewing authority may then observe the testing 

operation, if necessary. Emission test reports are needed as these are the Agency’s record of a 

model line’s initial capability to comply with the emission standard, and to serve as a record of 

the operating conditions under which compliance was achieved.

Adequate recordkeeping and reporting are necessary to ensure compliance with these 

standards as required by the Clean Air Act. 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.
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3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart 

AAA.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, duplication does 

not exist.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (FR citation, e.g., 78 FR 33409) on June 4, 2013. No comments were 

received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the

collection, maintenance, and retrieval of all compliance data. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, EPA 

contacted: 1) the Hearth, Patio, Barbeque Association (HPBA), at (916) 536-2390 and 2) Myren 

Consulting, Incorporated, at (509) 684-1154. HPBA indicated that there has not been a wholesale 

change in the number of respondents subject to the standard. Both contacts believed the 

estimated number of respondents presented in this ICR (i.e., 66 manufacturers and 6 testing 

laboratories) appears reasonable, but noted it to be a conservative estimate due to possible 

industry consolidation. At this time, the extent of the industry consolidation is unknown.

It is our policy to respond after a thorough review of comments received since the last ICR 

renewal as well as those submitted in response to the first Federal Register notice.
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3(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.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

these standards. EPA believes that the five-year records retention requirement is consistent the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B -

Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are manufacturers of 

new residential wood heaters. The United States Standard Industrial Classification (SIC) codes, 

and corresponding North American Industry Classification System (NAICS) codes for the 

respondents affected by the standard are provided in the following table.
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40 CFR Part 60, Subpart AAA SIC Codes NAICS Codes

Heating Equipment (Except Warm Air Furnaces

Manufacturing)

3433 333414

Household Cooking Appliance Manufacturing 3631 335221

Testing Laboratories 8734 541380

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for New 

Residential Wood Heaters (40 CFR Part 60, Subpart AAA).

A source must make the following reports: 

Notifications

The reporting requirements for the NSPS were uniquely designed for the 

manufacturers, testing laboratories, and retailers/distributors of new 

residential wood heaters. A special table is attached that describes the 

requirements in detail. See below Table A: Respondent Reporting and 

Recordkeeping, NSPS for New Residential Wood Heaters (40 CFR Part 

60, Subpart AAA) (Renewal).

See Table A

A source must keep the following records:

Recordkeeping 

The recordkeeping requirements for the NSPS were uniquely designed for 

the manufacturers, testing laboratories, and retailers/distributors of new 

residential wood heaters. A special table is attached that describes the 

requirements in detail. See below Table A: Respondent Reporting and 

Recordkeeping, NSPS for New Residential Wood Heaters (40 CFR Part 

60, Subpart AAA) (Renewal).

See Table A

Electronic Reporting

No special automated, mechanical, or technical collection techniques are used to collect 

information.
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The reports submitted by the manufacturer to EPA either are very voluminous (e.g., the 

application for model line certificate) or are performed infrequently. Therefore, the electronic 

submission of such reports is not considered economically viable.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Manufacturers must obtain a certificate of compliance for each model line of wood heater to 

be manufactured or sold, and conduct quality assurance activities.

Install, calibrate, maintain, and operate the appropriate equipment and demonstrate their 

proficiency at performing the required test (emission, burn rate, and air-to-fuel ratio).

Retailers/distributors must maintain sale records of used wood heaters.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way (e.g., continuous parameter monitoring system). Although personnel at the source 

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping.
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5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, 

and distribution of the required information.

Agency Activities

The Agency activities for the NSPS are in response to a uniquely 

designed rule. A special table is attached below that describes the 

requirements in detail. See below Table B: Agency Activities, NSPS for 

New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) 

(Renewal).

See Table B

5(b) Collection Methodology and Management

All reports are sent directly to the Agency. Data obtained during periodic visits by

Agency personnel from records maintained by the respondents are tabulated and published for 

internal Agency use in compliance and enforcement programs.

Information contained in the reports is systematically filed at EPA headquarters. Portions 

of the data are entered into a special database program maintained exclusively by the agency for 

later retrieval, study and essential reports.

Public access to the wood heater database can be obtained by writing to the Agency. 

Reports of wood heaters currently certified are commonly requested by both retailers and the 

general public.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

Virtually all of the manufacturers, laboratories, and commercial owners affected by this 

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

Administration. Special efforts taken by the Agency to minimize burden to these respondents are 

summarized elsewhere in this supporting statement.

Since this rule was developed through the regulatory-negotiation process, industry

representatives directly participated in the writing of the rule and agreed to make all of the 

required reports and keep the appropriate records as specified in the rule. 

Additional efforts were taken by the Agency to reduce the burden imposed on the smallest 
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businesses affected by this regulation. Provisions were included which allow delayed compliance 

of up to one year for those manufacturers producing fewer than 2,000 wood heaters per year. 

In addition, less frequent quality assurance emission audits were required for those manufacturers 

that produce fewer than 2,500 wood heaters within a model line. The wood heater standards also 

allow small manufacturers to purchase a certified design from another manufacturer. In this case, 

no certification testing is required. This provision has significantly reduced the burden associated 

with certification process for small manufacturers of wood heaters.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – NSPS for New Residential 

Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 11,749 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NSPS program, the 

previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($111.85+ 110%) 

Technical $101.22 ($92.02 + 110%)

Clerical $51.18 ($46.53 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2013, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs
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The type of industry costs associated with the information collection activities in the 

subject standards are both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with testing and labeling. The Capital/startup costs are one-time costs when a facility 

becomes subject to the regulation. Annual operation and maintenance (O&M) costs are the 

ongoing costs to maintain continuous monitoring systems and other costs such as photocopying 

and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Data Collection 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

Sampling Trains $6,500 0 $0 $500 6 $3,000

Certification Test a

$10,000 88 $880,000 $0 0 $0

Cost of Permanent 

Label b $2 201,118 $402,236 $0 0 $0

Removable Label 

Purchase/ Printing 

Cost c

$0.75 201,118 $150,838.50 $0 0 $0

QA Emissions Test d

$7,500 40 $300,000 $0 0 $0

Total (rounded) $1,733,075 $3,000

a Each of the 66 manufacturers is assumed to pay $10,000 per certification test for four tests over three years (1.33 

tests per year). 1.33 x 66 = 88. This cost is assumed to include the cost incurred by the laboratory to seal the 

certified stove. There are essentially no burden hours associated with this cost.

b Total costs of permanent labeling are estimated at $2.00 per stove. There are essentially no burden hours associated 

with this cost. There are an expected 603,354 wood heaters produced by all manufacturers over the three-year ICR 

period (603,354/3 = 201,118).

c Removable labels estimated to cost $0.75 per label. There are an expected 603,354 wood heaters produced by all 

manufacturers over the three-year ICR period (603,354/3 = 201,118).

d Assumes an emissions test is performed once every 5,000 units, and since 762 units are produced each year for each 

model, 0.15 emission tests are performed annually per manufacturer per model. Each manufacturer has four models;

therefore, 0.6 tests per manufacturer will be conducted (0.15 x 4 = 0.6). There are 66 manufacturers (0.6 x 66 = 40).

The total capital/startup costs for this ICR are $1,733,075. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $3,000. This is the 

total of column G. 
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The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $1,736,075.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program 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 three years of the ICR is estimated to be 

$359,225.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule, which 

excludes locality rates of pay. The rates have been increased by 60 percent to account for the 

benefit packages available to government employees. Details upon which this estimate is based 

appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for New Residential 

Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

947 existing respondents will be subject to the standard. This total comprises of 66 

manufacturers, 875 retailers, and 6 certification laboratories. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 947 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 72 875 0 947

2 0 72 875 0 947

3 0 72 875 0 947

Average 0 72 875 0 947

 1

 New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the

average Number of Respondents over the three year period of this ICR is 947. 

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Certification test notification 66 1.33 0 87.78

Application for certification 66 1.33 0 87.78

Biennial reporting for certified 

models

66 0.5 0 33

QA emission test notification 66 0.8 0 52.8

Application for accreditation 1 1 0 1

Notice of proficiency test 1 2 0 2

Annual proficiency test 6 1 0 6

Rescheduling of proficiency test 6 2 0 12

Total 282.36

The number of Total Annual Responses is 282 (rounded).

The total annual labor costs are $1,149,212. Details regarding these estimates may be 
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found below in Table 1: Annual Respondent Burden and Cost – NSPS for New Residential Wood 

Heaters (40 CFR Part 60, Subpart AAA) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 (below), respectively, and summarized below. 

(i) Respondent Tally

The total of annual labor hours is 11,749 hours at a cost of $1,149,212. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 42 hours per response.

The total annual capital/startup and Operation and Maintenance (O&M) costs to the 

regulated entity are $1,736,075.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 7,971

labor hours at a cost of $359,225. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in the total estimated respondent and Agency burdens as currently

identified in the OMB Inventory of Approved Burdens. The change in burdens from the mostrecently approved ICR is due to an increase in the number of sources subject to the standard, and 

is not due to any program changes. The number of sources has been increased in this ICR to 

reflect more current information obtained during development of proposed revisions to the NSPS.

There is also an increase in respondent and Agency burden costs from the most-recently 

approved ICR due to the use of updated labor rates. This ICR references labor rates from the 

Bureau of Labor Statistics to calculate respondent burden costs, and references labor rates from 

OPM to calculate Agency burden costs.

There is an increase in capital/startup and O&M costs as compared to the previous 

ICR. This change also is not due to any program changes. Similar to the respondent burden

adjustments, the change is due to the increased number of sources estimated to be subject to these

standards and is not due to any program changes.
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6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 42 hours per response. 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 valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2013-0331. An electronic version of the public docket is 

available at http://www.regulations.gov, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the 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 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 

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 docket center is (202) 566-1752. 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 EPA Docket ID 

Number EPA-HQ-OECA-2013-0331 and OMB Control Number 2060-0161 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.
15

Table 1: Annual Respondent Burden and Cost – NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA)

 (Renewal)

Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total 

cost per year 

($) b

Reporting Requirements

Manufacturers

1. Certification test notification c2 1.33 2.66 66 175.56 8.78 17.56 $19,748.68

2. Application for certification c8 1.33 10.64 66 702.24 35.11 70.22 $78,994.73

3. Biennial reporting for certified models d2 0.5 1 66 66 3.3 6.6 $7,424.32

4. Labeling labor cost - removable label e0.0083 3,047 25.39 66 1,675.74 83.79 167.57 $188,503.41

5. Owner's manual f20 1 20 66 1,320 66 132 $148,486.34

6. QA emission test notification g2 0.8 1.6 66 105.6 5.28 10.56 $11,878.91

Laboratories

1. Application for accreditation h40 1 40 1 40 2 4 $4,499.59

2. Proficiency test accreditation h135 1 135 1 135 6.75 13.5 $15,186.10

3. Notice of proficiency test i1 2 2 1 2 0.1 0.2 $224.98

4. Annual proficiency test j135 1 135 6 810 40.5 81 $91,116.62

5. Rescheduling of proficiency test k2 2 4 6 24 1.2 2.4 $2,699.75

6. Certification test runs l4 52 208 6 1,248 62.4 124.8 $140,387.08

Subtotal for Reporting Requirements 7,249.76 $709,150.51

Recordkeeping Requirements

Manufacturers

1. Test documentation c, m 1 1.33 1.33 66 87.78 4.39 8.78 $9,874.34

2. QA parameter inspections n2 20 40 66 2,640 132 264 $296,972.68

3. Sales data o N/A

4. R&D stoves report p2 1 2 66 132 6.6 13.2 $14,848.60
16

Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total 

cost per year 

($) b

3. Retained stoves c, q 8 1.33 10.64 66 702.24 35.11 70.22 $78,994.70

Retailers

1. Used stoves r0.1 4 0.4 875 350 17.5 35 $39,371.38

Subtotal for Recordkeeping Requirements 4,498.82 $440,061.70

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 11,749 $1,149,212

Assumptions:

a. We have assumed an average of 947 respondents will be subject to this rule. There will be no new additional sources during the next three years of this ICR. It 

was necessary to make several assumptions regarding: 1) how wood heater manufacturers would respond to the various alternatives for compliance; and 2) the 

large variety of wood heater manufacturer sizes and marketing approaches. Using data from the EPA section 114 survey of manufacturers, the following 

assumptions were developed for this burden calculation:

1) 66 woodstove manufacturers;

2) 4 woodstove models per manufacturer;

3) 762 woodstoves produced annually for each model by each manufacturer;

4) 3,047 woodstoves produced annually by each manufacturer; and

5) 201,118 woodstoves produced each year by all manufacturers.

b. This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, March 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, 

“Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c. We have assumed that the typical manufacturer will require four Phase II certification tests over the three-year ICR period (4/3 = 1.33).

d. We have assumed it will take each of the 66 respondents 2 hours to accomplish task 0.5 times per year .

e. We have assumed the estimated time required to apply removable labels per wood heater is 30 seconds.

f. We have assumed it will take 20 hours to include requisite information in owner’s manual.

g. We have assumed it will take each of the 66 respondents 2 hours to complete task 0.8 times per year.

h. We have assumed that one laboratory will apply for accreditation one time per year.

i. We have assumed there will be an average of two notifications per proficiency test due to test cancellation and rescheduling.

j. We have assumed each laboratory will conduct proficiency tests.

k. We have assumed each laboratory is required to report to EPA regarding changes in the testing schedule or interruptions in testing that last more than 24 hours. 

It is assumed that two of these events will occur for each test.

l. We have assumed each laboratory is expected to spend four hours per week to update and maintain records on certification tests.

m. We have assumed that each respondent will take 1 hour to complete task 1.33 times per year.
17

n. We have assumed that 762 units per model per year are produced, and that one out of every 150 units undergoes a parameter inspection. Thus, a parameter 

inspection will occur approximately five times per year per manufacturer model. Since each manufacturer has four models, 20 parameter inspections will be 

conducted annually by each manufacturer (5*4 = 20).

o. We have assumed there will be no additional burden because manufacturers already keep track of sales data for marketing purposes and payment of income 

taxes.

p. We have assumed one report will be filed by each manufacturer annually.

q

. We have assumed it will take eight hours for each respondent to complete the task.

r. We have assumed that one-tenth of the estimated 8,751 wood heater retailers will buy and sell used wood stoves. We assume each of these 875 retailers will 

purchase 4 used stoves per year and will spend 6 minutes per purchase maintaining records of each wood heater purchase.
18

Table 2: Average Annual EPA Burden and Cost – NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) 

(Renewal)

Burden Item

A B C D E F G H

Technical 

person-hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year (AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($) b

Response to applicability 

determination c

4 1 4 7 28 1.4 2.8 $1,451.09

Manufacture certification 

notification and changes d

2 1.33 2.66 66 175.56 8.78 17.56 $9,098.31

Certification test e40 0.13 5.2 66 343.2 17.16 34.32 $17,786.17

Apply for certification of model 

line f

60 1.33 79.8 66 5,266.8 263.34 526.68 $272,949.28

Biennial reporting for certified 

models g

2 0.5 1 66 66 3.3 6.6 $3,420.42

Laboratory application for 

accreditation h

40 1 40 1 40 2 4 $2,072.98

Laboratory proficiency test 

accreditation i

2 1 2 1 2 0.1 0.2 $103.65

Laboratory proficiency test notice –

new lab accreditation h, j

25 2 50 1 50 2.5 5 $2,591.23

Laboratory proficiency test report –

annual k

 a. Test design and 

implementation 

80 1 80 1 80 4 8 $4,145.96

 b. Test observation 40 0.25 10 6 60 3 6 $3,109.47

 c. Review of test reports 20 1 20 6 120 6 12 $6,218.94

 d. Analysis/conclusions 40 1 40 1 40 2 4 $2,072.98

Parameter inspections l40 0.25 10 66 660 33 66 $34,204.17

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 7,971 $359,225
19

Assumptions:

a. We have assumed an average of 947 respondents will be subject to this rule. There will be no new additional sources during the next three years of this ICR. It 

was necessary to make several assumptions regarding: 1) how wood heater manufacturers would respond to the various alternatives for compliance; and 2) the 

large variety of wood heater manufacturer sizes and marketing approaches. Using data from the EPA section 114 survey of manufacturers, the following 

assumptions were developed for this burden calculation:

1) 66 woodstove manufacturers;

2) 4 woodstove models per manufacturer;

3) 762 woodstoves produced annually for each model by each manufacturer;

4) 3,047 woodstoves produced annually by each manufacturer; and

5) 201,118 woodstoves produced each year by all manufacturers.

b. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM) 2013 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit 

packages available to government employees.

c. We have assumed that 10 percent of wood heater manufacturers will request a determination of applicability once per year (0.1*66 = 7, after rounding).

d. We have assumed each manufacturer will require four EPA certification tests over the next three years for an average of 1.33 certification tests per manufacturer 

per year.

e. We have assumed that there will be 1.33 certifications per manufacturer per year, and that EPA will send an observer to one out of every ten certification tests.

f. We have assumed that the typical manufacturer will require four Phase II certification tests over the three-year period. Thus, four notices in three years equals to 

1.33 notices per year (4/3 = 1.33).

g. We have assumed biennial reporting occur 0.50 occurrences per year.

h. We have assumed one new lab will apply for accreditation each year.

i. We have assumed that for labs to receive accreditation, each laboratory will be required to perform a proficiency test one time during each year.

j. We have assumed there will be an average of two notifications per proficiency test due to test cancellation and rescheduling. We also have assumed it will take 

25 hours to complete the new lab accreditation.

k. Laboratory proficiency test reports will consist of four parts. The first part, test design and implementation, is assumed to require 80 hours once per year to 

evaluate. The second part, test observation, assumes that EPA will send an observer to one-fourth of all tests. The third part, review of test reports, assumes 

that each laboratory will submit a report and that each report will require 20 hours to review. The fourth part, analysis and conclusions, is assumed to take 40 

hours once per year.

l. Random compliance audits to inspect wood heater parameters are expected to be conducted on one-quarter of each manufacturer’s model lines per year.
20

Table A: Respondent Reporting and Recordkeeping, NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) 

(Renewal)

Regulatory 

Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.533(f)(l) Manufacturer Report: notification of certification testing at 

least 30 days prior to test

Once per model.

60.533(b) Manufacturer Report: Application for certification. Includes

identifying characterization results and various 

affirmations of compliance

Once for each model line for each 

phase of the standard (unless wood 

date, complete certification test heater 

qualifies for Phase Ii stand). Must 

reapply every 5 years.

60.537(f) Manufacturer Report: To EPA certifying that model line is 

unchanged

Every 2 years.

60.536(a) Manufacturer Report: Produce and apply permanent label One per unit produced.

60.536(i) Manufacturer Produce and apply removable label One per unit produced.

60.536(l) Manufacturer Develop and publish owners manual One per unit produced.

60.533(o)(3) Manufacturer Report: Notify EPA that a Q.A. emissions test 

will be conducted within one week of the 

mailing of the notice. Submit test report for 

accelerated Q.A. [(o)(3)(iii)]*

Once for each Q.A. emission test.

60.537(a)(2) Manufacturer Maintain records of all certification data Once per model.

60.533(o) & 

60.537(a)(3), (a)(4)

Manufacturer Recordkeeping of results, remedial measures 

taken pursuant to quality assurance program

Parameter inspections every 150 units. 

Emission tests vary according to 

manufacturer size and certification 

results.

60.537(a)(5) Manufacturer Maintain records of the number of wood 

heaters sold each year

Continuously through production year.
21

Regulatory 

Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.537(g) Manufacturer Recordkeeping for all models and units 

exempted under R and D provision

Variable unpredictable.

60.537(c) Manufacturer Retain sealed wood heater for the life of model One for each certified model.

60.533(i)* Manufacturer Report: Request for waiver of testing 

requirement for certification testing

Once per model, if at all.

60.533(h)(3)** Manufacturer Report: Application for alternative certification Once per model, if at all.

60.533(k)(l) Manufacturer Report: Request for waiver of the requirement 

that a model line be recertified when changes 

exceed specified tolerances

Variable.

60.533(p)(5)** Manufacturer Development of documentation to rebut 

presumption of audit failure

Variable, but no more than one for 

every four certified models.

60.535(a)(l) Laboratory Report: application for accreditation One per laboratory.

60.535(b)(5) Laboratory Report: Proficiency test and all test 

documentation

At time of application and annually.

60.535(b)(3) Laboratory Keep records of audit tests Once for each five certification tests.

60.534(e)(l)(3) Laboratory Report: To EPA changes in testing schedule or 

interruptions in testing

Once per test.

60.537(b)(l) Laboratory Maintain records of certification test data Once per certified model.

60.535(g) Laboratory Recordkeeping. Seal each certified wood 

heater

Once per certified model.

60.533(h)(4) Laboratory Report: Submission of preliminary test reports 

from laboratory to EPA and manufacturer for 

wood heaters which exceed emission limits. 

Report is submitted within 10 days of test 

completion. (This provision for wood heaters 

which have been granted alternative 

certification, only.)

Once per model, if at all.
22

Regulatory 

Reference

Title 40, Part 60

Regulated Entity Reporting/Recordkeeping Requirement Frequency/Other Comments

60.537(h) Commercial Owner 

(e.g., retailer)

Name and address of previous owner of a used 

stove that he has purchased or obtained as a 

trade in

Variable.

* 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.
23

Table B: Agency Activities, NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal)

Regulatory Reference

Title 40, Part 60

Agency Reporting/Recordkeeping Frequency/Other Comments

60.533(1)(2)* EPA Report: Notice of revocation of certification Once per model, if at all.

60.533(p)(5)(B) EPA Issue notification of audit test failure and 

certificate suspension or revocation

Variable, but no more than one for 

every four certified models.

60.535(b) EPA Evaluate laboratory proficiency tests Annually.

60.535(e)* EPA Notice of intention to revoke laboratory

accreditation with justification and basis

Variable and infrequent.

60.539* Manufacturer

EPA

Various requests, submittals, motions, 

filings, etc., under hearing and appeal 

procedures

* 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.