E

C

/R Incorporated Providing Environmental Technical Support Since 1989

.

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122

MEMORANDUM

DATE: January 2015

SUBJECT: 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).

FROM: Joanne O’Loughlin and Beth Friedman, EC/R Incorporated

TO: Docket ID Number EPA-HQ-OAR-2009-0734

1.0 PURPOSE

The phased implementation schedule for the new source performance standards (NSPS)

for new residential wood heaters (40 CFR part 60, revised subpart AAA and subpart QQQQ) 

results in differing recordkeeping and reporting impacts because it includes a two-step emission 

standards approach, each with different compliance dates. For purposes of this memorandum, we 

refer to these stepped emission standards as Step 1 and Step 2. The compliance date for meeting 

Step 1 emission standards provided in the rules occurs in 2015 for most types of wood heaters,

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

2020. The recordkeeping and reporting respondent burden estimates included in the information 

collection requests (ICR) supporting statements for 40 CFR part 60, subparts AAA and subpart 

QQQQ include respondent burden estimates for years 2015 to 2017.1The purpose of this 

memorandum is to document the recordkeeping and reporting respondent burden cost estimates 

(hourly labor and associated costs and not capital costs) as a result of the final amended rule for 

subpart AAA and final rule for subpart QQQQ for years 2018 to 2020. Section 2 presents a 

summary of the recordkeeping and reporting requirements for manufacturers, third-party 

certifiers and testing laboratories, and the number of respondents subject to subpart AAA and 

subpart QQQQ. The estimated recordkeeping and reporting respondent burden for years 2018 to 

2020 for subpart AAA and subpart QQQQ are presented in Attachment 1 (subpart AAA) and 

Attachment 2 (subpart QQQQ) to this memorandum.

 

1

See http://www.reginfo.gov for the ICR supporting statements for the New Residential Wood Heaters New Source 

Performance Standards (NSPS) (OMB Control Number 2060-0161), Hydronic Heaters and Forced-Air Furnaces 

New Source Performance Standards (NSPS) (OMB Control Number 2060-0693)(40 CFR Part 60, Subparts AAA 

and QQQQ).
2

2.0 SUBPART AAA AND SUBPART QQQQ RECORDKEEPING AND REPORTING 

REQUIREMENTS AND THE NUMBER OF AFFECTED RESPONDENTS

2.1 Summary of Recordkeeping and Reporting Requirements under Subparts AAA and QQQQ 

Subpart AAA and subpart QQQQ require manufacturers of new residential wood heaters, 

hydronic heaters and forced-air furnaces, test laboratories and third-party certifiers to submit 

reports and to maintain records for demonstrating and documenting compliance. A third-party 

certification process is required. Under this process, for all heaters/stoves subject to subpart 

AAA and subpart QQQQ, after testing is completed by an approved test laboratory, a 

certification of conformity with the particulate matter emissions standards must be issued by a 

third-party certifier with whom the manufacturer has entered into contract for certification 

services. In order to avoid the potential for manufacturer model certification delays, subpart 

AAA and subpart QQQQ allow for automatic certification for wood heaters that meet Step 1 

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

valid for 5 years, after which manufacturers need to either recertify or renew their model 

certifications.

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, quality assurance (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. 

Test laboratories must be approved by the EPA as test laboratories for subpart AAA and 

subpart QQQQ before beginning certification testing. Accredited approved test laboratories must 

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

Current EPA-accredited laboratories may retain their accreditation and may conduct testing as 

approved test labs until 3 years after the effective date of this rule (by 2018). 

As of the year 2018, for both subpart AAA and subpart QQQQ, the third-party certifierbased process will have already been established; and we assume that all laboratories that will 

apply for accreditation and approval as third-party certifiers and test laboratories will have been 

completed. The respondent recordkeeping and reporting burden estimates presented in this 

memorandum assume 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 and 
3

subpart QQQQ. The only approved 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 (accounted for in burden estimates prepared for 2015-2017)2,

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). 

Manufacturers of new residential wood heaters, hydronic heaters and forced-air furnaces 

are required to submit applications for certification/recertification of model lines, 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 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. Manufacturers must also maintain records of all certification 

data, maintain results of QA program inspections and emissions test data, and seal and store the 

tested appliance. 

Manufacturers of new residential wood heaters, hydronic heaters and forced-air furnaces 

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 permanent label requirements are assumed to be a 

capital cost per model developed and are not included in our respondent recordkeeping and 

reporting hourly burden estimates. Although not required, owners and operators of appliances 

subject to subpart AAA and subpart QQQQ also have the option of applying temporary labels for 

their cleanest heaters that meet or exceed the Step 2 emission standards prior to the Step 2 

emissions standards 2020 compliance date. This optional temporary label allowance, if adopted 

by a manufacturer, would inform consumers of their status as already meeting the Step 2 

emission standards 2020 compliance date. Additionally, subpart AAA and subpart QQQQ also 

allow wood heater manufacturers the option of applying temporary labels to wood heaters, 

hydronic heaters and forced-air furnaces 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.

The cost of temporary labels is not included in our recordkeeping and reporting hourly burden 

estimates because they are not required by subparts AAA and QQQQ. 

Subpart AAA and subpart QQQQ include provisions that the EPA may select a wood 

heater, hydronic heater or forced-air furnace model for compliance audit testing. The testing of 

the model would be at the manufacturer’s expense. For purposes of estimating respondent 

recordkeeping and reporting burden estimates, we assumed that this is an infrequent request and 

that only one audit affecting one manufacturer would occur in the 2018 to 2020 three-year 

period. Although the capital costs that would be associated with testing are not included in our 

respondent recordkeeping and reporting burden costs, we have included the manufacturer burden 

hours that would be associated with an EPA compliance audit. 

 

2

See footnote 1.
4

Other non-routine and infrequent (if at all) recordkeeping and reporting requirements, 

such as the need for responses due to revocation or certification and/or laboratory accreditation

and hearing and appeals procedures, are not included in the respondent recordkeeping and 

reporting burden estimates presented in this memorandum. Requests for waivers are also not 

included in the respondent recordkeeping and reporting burden estimates because they would, 

when granted, eliminate other reporting and recordkeeping burdens.

Lastly, subpart AAA and subpart QQQQ require owners and operators of wood heaters, 

hydronic heaters and forced-air furnaces to operate their appliances consistent with the owner’s 

manual for their model; and owners and operators of pellet fuel appliances are required to 

operate their pellet fuel appliances with specified grades of pellet fuels. Manufacturers are 

required to void warranties in cases of improper operation. Owner’s manual content development 

requirements are a one-time manufacturer capital cost per certified model and are not included in 

the respondent recordkeeping and reporting hourly burden estimates. There are no associated 

recordkeeping and reporting requirements for owners and operators.

In summary, the components of recordkeeping and reporting respondent burden estimates 

for subpart AAA and subpart QQQQ 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.

2.2 Number of Respondents Subject to Subpart AAA and Subpart QQQQ Recordkeeping and 

Reporting Requirements

There are approximately 66 manufacturers3and 6 laboratories (inclusive of test labs and 

third-party certifiers) that would be subject to the final amended subpart AAA. 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 

qualify for automatic certification approval until 2020. For years 2018 to 2020, we assume that 

270 models will be either newly certified or recertified under subpart AAA. We also assume that, 

as of 2018, there will be 6 approved test laboratories and 4 approved third-party certifiers under 

subpart AAA.

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

manufacturers4and 4 test laboratories that would be subject to subpart QQQQ. For forced-air 

furnaces, compliance with work practice/operational standards is required in 2015, and 

compliance with Step 1 emission limits for small (<65,000 BTU/hr models) and large furnaces 

(> 65,000 BTU/hr models) is required in 2016 and 2017, respectively. As discussed in the 

manufacturer costs impacts memo, we estimate that there are currently 50 model lines of forced-

 

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

4

See footnote 3.
5

air furnaces produced by 7 manufacturers and 120 model lines of hydronic heaters (about 10 

percent of which are indoor hydronic heaters) produced by 30 manufacturers. We assume that of 

these 170 existing model lines, 55 models (approximately 5 forced air furnace models and 50

hydronic heater models) will meet EPA criteria as meeting Step 1 emission standards and will 

qualify for automatic certification approval until 2020 and that 115 forced-air furnace models 

will certify to comply with Step 1 emission standards between 2015 and 2017. For years 2018 to 

2020, we assume that 170 models will be either newly certified or recertified under subpart 

QQQQ. We assume that, as of 2018, there will be 4 approved test laboratories and 4 approved 

third-party certifiers under subpart QQQQ.

2.3 Summary of the Burden Estimates Associated with Subpart AAA and Subpart QQQQ 

Recordkeeping and Reporting Requirements for Years 2018 to 2020

Attachment 1 presents the subpart AAA recordkeeping and reporting burden estimates 

for years 2018 to 2020. For years 2018-2020, the average annual burden for the recordkeeping 

and reporting requirements in subpart AAA for the estimated 72 respondents (66 manufacturers 

and 6 laboratories (including test laboratories and third-party certifiers) that will be subject to the 

New Residential Wood Heater NSPS is estimated to be 5,105 person-hours, with an average 

annual labor cost of $434,037 (approximately $352,000 for manufacturers, $9,000 for third-party

certifiers and $73,000 for test laboratories). Attachment 2 presents the subpart QQQQ 

recordkeeping and reporting burden estimates for years 2018 to 2020. For years 2018-2020, the 

average annual burden for the recordkeeping and reporting requirements in subpart QQQQ for 

the estimated 41 respondents (37 manufacturers and 4 laboratories (including test laboratories 

and third-party certifiers) that will be subject to the New Residential Hydronic Heaters and 

Forced-Air Furnaces NSPS is estimated to be 3,061 person-hours, with an average annual labor 

cost of $250,309 (approximately $197,000 for manufacturers, $5,000 for third-party certifiers 

and $49,000 for test laboratories). The average hourly rates used for technical, management and 

clerical estimates are the same rates that were used for estimates for years 2015 to 2017.5

 

5

See footnote 1.
ATTACHMENT 1

NEW RESIDENTIAL WOOD HEATER NSPS (SUBPART AAA) 

RECORDKEEPING AND REPORTING BURDEN (YEARS 2018-2020)
(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 2018-2020 person-hours person-hours aperson-hours a2018-2020 person-hours person-hours costs

occurrence per respondent 2018-2020 2018-2020 2018-2020 2018-2020 2018-2020

Activity 2018-2020 (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 4.1 8.2 66 540.0 27.0 54.0 $ 52,804 621.0 207.0 $ 17,601

2. Application for certification d8.00 4.1 32.7 66 2,160.0 108.0 216.0 $ 211,217 2,484.0 828.0 $ 70,406

3. Biennial reporting e2.00 8.2 16.4 66 1,080.0 54.0 108.0 $ 105,608 1,242.0 414.0 $ 35,203

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

 g 2.00 1.0 2.0 66 132.0 6.6 13.2 $ 12,908 151.8 50.6 $ 4,303

6. QA annual audit report h 20.00 49.5 990.0 4 3,960.0 198.0 396.0 $ 387,230 4,554.0 1,518.0 $ 129,077

7. Review annual QA audit report i 4.00 3.0 12.0 66 792.0 39.6 79.2 $ 77,446 910.8 303.6 $ 25,815

Test Laboratories .

1. Application for accreditation j

a. Already has ISO accreditation 20.00 - 0.0 6 - 0.0 0.0 $ - 0.0 0.0 $ -

b. Needs to obtain ISO accreditation 80.00 - 0.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

2. Biennial proficiency testing and report development k150.00 2.0 300.0 6 1,800.0 90.0 180.0 $ 176,014 2,070.0 690.0 $ 58,671

Third-Party Certifiers

1. Application to be an ISO Accrediting Entity l

a. Already has ISO accreditation 20.00 - 0.0 4 - 0.0 0.0 $ - 0.0 0.0 $ -

b. Needs to obtain ISO accreditation 80.00 - 0.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

Subtotal for Reporting Requirements 10,472.0 523.6 1047.2 $1,024,009 12,042.8 4,014.3 $ 341,336

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 4.1 4.1 66 270.0 13.5 27.0 $ 26,402 310.5 103.5 $ 8,801

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 Certifiers

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 2,844.0 142.2 284.4 $ 278,102 3,270.6 1,090.2 $ 92,701

TOTAL BURDEN AND COST (SALARY) 13,316.0 665.8 1331.6 $1,302,111 15,313.4 5,104.5 $ 434,037

TOTAL NUMBER OF RESPONSES 2018-2020 1,555 Annual avg. 518

e For years 2018 to 2020, we assume 2 biennial reports per manufacturer (66 manufacturers) for each of their models (270 models) at 2 hours per report.

g

 Assumes that there will be one QA emissions test per manufacturer (66 manufacturers) under the QA program during the 2018 to 2020 time period. We assume that each of the manufacturers will be required to test one model and 

report results to the EPA under their QA program between 2018 and 2020.

f For the years 2018 to 2020, we assume that one of the 66 manufacturers will be required to undergo an EPA compliance audit test for one of their models. 

h,i Assumes there will be three QA audits by the third-party certifier for each of the 66 manufacturers over the three-year period (2018-2020) 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 also 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). 

TABLE 1. THREE-YEAR AND ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL RULE (2018-2020)

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.

c Assumes that 270 models will require new certification to meet 2020 emission standards or will recertify their current compliant certifications during the 2018 to 2020 time period. For years 2021 to 2023, we would assume that up to

1/5 of models are recertified each year (although some may obtain test waivers).

d Assumes all models (270 models) will require new certification due to meet 2020 compliance emission standards or will recertify or renew (where a test waiver is obtained) compliant certifications during the 2018 to 2020 time

period. For years 2021 to 2023, we would assume that up to 1/5 of models are recertified or renewed (where a test waiver is obtained) each year.
q We expect the required recordkeeping to be highly automated and have assumed that third-party certifiers will spend 2 hours per month for the 3-year period (2018-2020) to maintain the required records.

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

n

 Parameter inspections are part of the existing safety inspection program. We have assumed each of the 66 wood stove manufacturers with certified models will spend an additional 2 hours per quarter during the 2018 to 2020 time 

period to document results.

o Assumes that one stove is sealed and retained for each certification test (for 270 models) required of the 66 manufacturers over the three year period (2018-2020).

p We expect the required recordkeeping to be highly automated and have assumed that test laboratories will spend 2 hours per month for the 3-year period (2018-2020) to maintain the required records.

j Assumes 0 occurrences for years 2018 to 2020.

k Assumes that each of the 6 test laboratories will conduct two biennial proficiency tests and prepare two reports during the three-year period (2018-2020).

l Assumes 0 occurrences for years 2018 to 2020.
ATTACHMENT 2

NEW RESIDENTIAL HYDRONIC HEATERS AND FORCED-AIR 

FURNACES NSPS (SUBPART QQQQ) RECORDKEEPING AND 

REPORTING BURDEN (YEARS 2018-2020)
(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

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

hours per occurrences per respondent 2018-2020 person-hours person-hours aperson-hours a2018-2020 person-hours person-hours costs

occurrence per respondent 2018-2020 2018-2020 2018-2020 2018-2020 2018-2020

Activity 2018-2020 (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 4.6 9.2 37 340.0 17.0 34.0 $ 33,247 391.0 130.3 $ 11,082

2. Application for certification d8.00 4.6 36.8 37 1,360.0 68.0 136.0 $ 132,988 1,564.0 521.3 $ 44,329

3. Biennial reporting e 2.00 9.2 18.4 37 680.0 34.0 68.0 $ 66,494 782.0 260.7 $ 22,165

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 37 74.0 3.7 7.4 $ 7,236 85.1 28.4 $ 2,412

6. QA annual audit report h20.00 27.8 555.0 4 2,220.0 111.0 222.0 $ 191,105 2,553.0 851.0 $ 63,702

7. Review annual QA audit report i 4.00 3.0 12.0 37 444.0 22.2 44.4 $ 39,409 510.6 170.2 $ 13,136

Test Laboratories

1. Application for accreditation j

a. Already has ISO accreditation 20.00 - 20.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

b. Needs to obtain ISO accreditation 80.00 - 80.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

2. Biennial proficiency testing and report development k 150.00 2.0 300.0 4 1,200.0 60.0 120.0 $ 117,343 1,380.0 460.0 $ 39,114

Third-Party Certifiers

1. Application to be a third-party certifier l

a. Already has ISO accreditation 20.00 - 20.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

b. Needs to obtain ISO accreditation 80.00 - 80.0 0 - 0.0 0.0 $ - 0.0 0.0 $ -

Subtotal for Reporting Requirements 6,326.0 316.3 632.6 $ 588,604 7,274.9 2,425.0 $ 196,201

Recordkeeping Requirements

Manufacturers

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

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

3. Retained (sealed) stoves o1.00 4.6 4.6 37 170.0 8.5 17.0 $ 16,624 195.5 65.2 $ 5,541

Test Laboratories

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

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

Third-Party Certifiers

1. Certification test, QA program inspection and audit tests

 q 2.00 36.0 72.0 2 144.0 7.2 14.4 $ 14,081 165.6 55.2 $ 4,694

Subtotal for Recordkeeping Requirements 1,660.0 83.0 166.0 $ 162,324 1,909.0 636.3 $ 54,108

TOTAL BURDEN AND COST (SALARY) 7,986.0 399.3 798.6 $ 750,928 9,183.9 3,061.3 $ 250,309

TOTAL NUMBER OF RESPONSES 2018-2020 837 Annual avg. 279

a

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

b

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

g

 Assumes that there will be one QA emissions test per manufacturer (37 manufacturers) under the QA program during the 2018 to 2020 time period. We assume that each of the manufacturers will be required to test one model and 

report results to the EPA under their QA program between 2018 and 2020.

TABLE 1. THREE-YEAR AND ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL RULE (2018-2020)

h, i Assumes there will be three QA audits by the third-party certifier for each of the 37 manufacturers over the three-year period (2018-2020) 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). 

f For the years 2018 and 2020, we assume that one of the 37 manufacturers will be required to undergo an EPA compliance audit test for one of their models.

e

 For years 2018 to 2020, we assume 2 biennial reports per manufacturer (37 manufacturers) for each of their models (170 models) at 2 hours per report.

c Assumes 170 models will require new certification to meet 2020 compliance emission standards or will recertify their current compliant certifications during the 2018 to 2020 time period. For years 2021 to 2023, we would assume 

that up to 1/5 of models are recertified or renewed each year.

d Assumes all models (170 models) will require new certification to meet 2020 compliance emission standards or will need to recertify or renew (where test waivers are granted) compliant certifications during the 2018 to 2020 time 

period. For years 2021 to 2023, we would assume that up to 1/5 of models are recertified or renewed (where test waivers are granted) each year.
j

 Assumes 0 occurrences for years 2018 to 2020.

k

 Assumes that each of the 4 test laboratories will conduct two biennial proficiency tests and prepare two reports during the three-year period (2018-2020).

l Assumes 0 occurrences for years 2018 to 2020.

q We expect the required recordkeeping to be highly automated and have assumed that third-party certifiers will spend 2 hours per month for the 3-year period (2018-2020) to maintain the required records.

p We expect the required recordkeeping to be highly automated and have assumed that test laboratories will spend 2 hours per month for the 3-year period (2018-2020) to maintain the required records.

o

 Assumes that one stove is sealed and retained for each certification test (for 170 models) required of the 37 manufacturers over the three year period (2018-2020).

m Assumes that manufacturers will spend one hour per certification test (for 170 models) to keep the required records.

n Parameter inspections are part of the existing safety inspection program. We have assumed each of the 37 manufacturers with certified models will spend an additional 2 hours per quarter during the 2018 to 2020 time period to

document results.