Burden Calculation Tables

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Overview

Table 1
Table 2
CapitalO&M
Respondents Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal)
Burden Item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical person-hours per year (G=Ex0.1)	(H) Total Cost per year ($) b
Reporting Requirements										Labor Rates
Manufacturers - New Model Lines										Management	$153.55
1. Test notification for new model lines c	2	1	2	15	30	2	3	$4,080.86		Technical	$122.20
2. Application for certification for new model lines c	8	1	8	15	120	6	12	$16,323.42		Clerical	$61.51
3. Submit performance test results c	2	1	2	15	30	2	3	$4,080.86
4. Renewal of certification of compliance d	8	0.2	2	0	0	0	0	$0.00
5. Biennial reporting e	2	0.33	1	15	10	0.5	1.0	$1,346.68
6. Quality assurance testing f	8	0.33	2.7	0	0	0	0	$0
7. EPA compliance audit testing g	8	0.33	2.7	0	0	0	0	$0
8. Review annual QA audit report h	4	0	0	0	0	0	0	$0
Manufacturers - Existing Model Lines
1. Renewal of certification of compliance d	8	1	8	51	408	20.4	40.8	$55,499.63
2. Biennial reporting i	2	2.48	5	51	253	12.7	25.3	$34,415.21
3. Quality assurance testing f	8	0.33	2.7	51	136	6.8	13.6	$18,499.88
4. EPA compliance audit testing g	8	0.33	2.7	1	2.7	0.1	0.3	$362.74
5. Review annual QA audit report k	4	1	4.0	51	204	10.2	20.4	$27,749.81
Testing Laboratories
1. Application for test lab approval (new)
a. Already has ISO accreditation	20	1	20	0	0	0	0	$0
b. Needs to obtain ISO accreditation	80	1	80	0	0	0	0	$0
2. Biennial proficiency testing and report development l	150	0.5	75	8	600	30	60	$81,617.10
3. Application for re-approval as a test lab m	20	0.2	4	8	32	1.6	3.2	$4,352.91
Third-Party Certifiers
1. Application for approval as a third-party certifier (new)
a. Already has ISO accreditation	20	1	20	0	0	0	0	$0
b. Needs to obtain ISO accreditation	80	1	80	0	0	0	0	$0
2. Application for re-approval as a third-party certifier m	20	0.2	4	8	32	1.6	3.2	$4,352.91
3. Annual quality assurance audits j	20	6.4	128	8	1,020	51	102	$138,749.07
Subtotal for Reporting Requirements					3,309			$391,431
Recordkeeping Requirements
Manufacturers
1. Test documentation n	1	1.1	1.1	51	53.6	2.7	5.4	$7,291.13
2. QA parameter inspections o	2	4	8	51	408	20.4	41	$55,499.63
3. Retained (sealed) stoves p	1	1.8	2	51	89	4.5	8.9	$12,151.88
Test Laboratories
1. Certification test, proficiency test, and audit test results q	2	12	24	8	192	9.6	19	$26,117.47
Third-Party Certifier
1. Certification test, QA program inspection and audit tests r	2	12	24	8	192	9.6	19	$26,117.47
Subtotal for Recordkeeping Requirements					1,075			$127,178
Total Labor Burden and Costs (rounded) s					4,380			$520,000		12	hr/response
Total Capital and O&M Cost (rounded) s								$657,000
GRAND TOTAL (rounded) s								$1,180,000
Assumptions:
a There are fifty-one existing manufacturers of woodstoves. We assume no additional manufacturers will become subject to this regulation in the three-year period of this ICR. There are 253 existing model lines of woodstoves. We assume that existing manufacturers will introduce and certify a total of 10 new model lines each year during the three-year period of this ICR.
b This ICR uses the following labor rates: $153.55 per hour for Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c We assume that 15 of the 51 existing manufacturers will each introduce and certify 1 new model line each year during the three-year period of this ICR. These 15 manufacturers introducing a new model line will notify EPA of the performance test, apply for certification, and submit performance test results.
d Manufacturers must request renewal of a model line's certificate of compliance every 5 years. For new model lines introduced during the three-year period of this ICR, no recertifications are necessary. We assume that all 51 manufacturers with certified model lines will submit recertification requests each year.
e Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. The manufacturers of the 15 new model lines introduced and certified in year 1 of this ICR will submit a report in year 3, resulting in an average of 0.33 responses/year/manufacturer.
f Manufacturers perform quality assurance testing as part of their quality assurance program. We assume that each manufacturer will have one model line tested during the three-year period of this ICR for quality assurance and submit a report. We assume only existing model lines will be tested. 1 test/3 years = 0.33 responses/year/manufacturer
g We assume EPA will request compliance audit testing of a single manufacturer's model line once during the three-year period of this ICR. We assume this test will be done on an existing model line. (1 test / 3 years = 0.33 responses/year)
h Third-party certifiers perform the audits for all of a single manufacturer's model lines in one visit and submit the results of the audits in a single batch within 30 days to the manufacturers and to EPA. Manufacturers must review the QA audits and then report to the third-party certifier and to the Administrator their corrective actions and responses to any deficiencies identified in the audit report. The reviews of audits for both new and existing models are accounted for on the line item for existing models.
i Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. We assume manufacturers will submit one report for half of their existing model lines each year (253 model lines / 51 manufacturers / 2 = 2.48 response per year per manufacturer).
j Manufacturers of model lines are required to contract with third-party certifiers to perform quality assurance audits on each model line at least annually to ensure that the manufacturer's quality assurance plan is being implemented. We assume all of a manufacturer's model lines will be audited in a single visit. 51 manufacturers/8 third party certifiers = 6.4 occurances per certifier per year. We assume each audit takes 20 hours of the third-party certifier's time.
k Third-party certifiers perform the audits for all of a single manufacturer's model lines in one visit and submit the results of the audits in a single batch within 30 days to the manufacturers and to EPA. Manufacturers must review the QA audits and then report to the third-party certifier and to the Administrator their corrective actions and responses to any deficiencies identified in the audit report. 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).
l Test labs are required to participate biennially in an independently operated proficiency testing program. There are eight approved test labs. (1 occurance / 2 years = 0.5)
m Test Labs and Third-Party Certifiers must reapply for approval every five years. We assume all eight approved test labs and all eight approved third-party certifiers will reapply for approval when their current term of approval expires. We assume that EPA will approve all of the requests. 1 reapproval /5 years = 0.2 reapprovals/year
n Manufacturers that hold a certificate of compliance for a woodstove model line are required to retain all records of the certification test for five years. We assume that manufacturers will spend one hour per certification test (for 253 existing + 15 new models) to keep the required records. 268 models/51 manufacturers/5 years = 1.1 occurrences/year
o Manufacturers that hold a certificate of compliance for a woodstove model line are required to retain all records of the quarterly parameter inspections for five years. Parameter inspections are part of the existing safety inspection program. We have assumed each of the 51 wood stove manufacturers with certified models will spend an additional 2 hours per quarter to document results.
p Each manufacturer must retain each wood heater upon which certification tests were performed based upon which certification was granted under §60.533(c) or (f) at the manufacturer's facility for a minimum of 5 years after the certification test. We assume that one stove is sealed and retained for each certification test (for 253 + 15 = 268 model lines) required of the 51 manufacturers over the three-year ICR period.
q Each approved test laboratory must maintain records consisting of all documentation pertaining to each certification test, quality assurance program inspection and audit test. We expect the required recordkeeping to be highly automated and have assumed that test laboratories will spend 2 hours per month to maintain records.
r Each approved third-party certifier must maintain records consisting of all documentation pertaining to each certification test, quality assurance program inspection and audit test. We expect the required recordkeeping to be highly automated and have assumed that third-party certifiers will spend 2 hours per month to maintain records.
s Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost - NSPS for New Residential Wood Heaters (40 CFR Part 60, Subpart AAA) (Renewal)
Burden Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per year	(C) EPA person-hours per year (C=AxB)	(D) Respondents per year a	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (F=Ex0.05)	(G) Clerical person-hours per year (G=Ex0.1)	(H) Total Cost per year ($) b
Manufacturers - New Model Lines										Labor Rates
1. Certification test notification c	1	1	0.5	15	8	0.4	0.8	$430.91		Management	$69.04
2. Attend certification test d	20	1	20	1	15	1	2	$861.83		Technical	$51.23
3. Review performance test report and application for certification c	8	1	8	15	120	6	12	$6,894.60		Clerical	$27.73
4. Biennial reporting e	1	0.33	0	15	5	0.2	0.5	$284.40
5. Review quality assurance testing f	8	0.33	3	0	0	0	0	$0
6. EPA compliance audit testing g	40	0.33	13.3	0	0	0	0	$0
8. Review annual QA audit report h	2	0	0	0	0	0	0	$0
Manufacturers - Existing Model Lines
1. Review application for re-certification i	8	1	8	51	408	20.4	40.8	$23,441.64
2. Biennial reporting for certified models j	1	2	2.5	51	126.5	6.3	12.7	$7,268.06
3. Review quality assurance testing f	2	0.33	0.7	51	34	1.7	3.4	$1,953.47
4. EPA Compliance Audit testing g	40	0.33	13.3	1	13.3	0.7	1.3	$766.07
5. Review annual QA audit report l	2	1	2.0	51	102.0	5.1	10.2	$5,860.41
Testing Laboratories and Third-Party Certifiers
1. Review and approval of test lab credentials m	4	0.2	1	8	6	0	1	$368
2. Review test lab biennial proficiency test reports n	10	0.50	5	8	40	2	4	$2,298.20
3. Review and approval of third-party certifier credentials m	8	0.2	1.6	8	13	1	1	$735
4. Review annual quality assurance audits k	8	6.4	51.0	8	408	20.4	40.8	$23,441.64
TOTAL (rounded) o					1,490			$75,000
Assumptions:
a There are fifty-one existing manufacturers of woodstoves. We assume no additional manufacturers will become subject to this regulation in the three-year period of this ICR. There are 253 existing model lines of woodstoves. We assume that existing manufacturers will introduce and certify a total of 15 new model lines each year during the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.03 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c We assume 15 manufacturers will introduce a new model line each year during the three-year period of this ICR. EPA will review: the test notification, the application for certification, and the performance test report.
d We assume that EPA will observe 5 percent of certification/performance tests conducted during the three-year period of this ICR (15 x 0.05 = 0.75 or 1 (rounded)).
e Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. The manufacturers of the 15 new model lines introduced and certified in year 1 of this ICR will submit a report in year 3, resulting in an average of 0.33 responses/year/manufacturer.
f We assume that manufacturers perform quality assurance testing as part of their quality assurance program will test one model line during the three-year period of this ICR and submit a report. We assume only existing model lines will be tested.
g We assume EPA will request compliance audit testing of one model line of an existing manufacturer's once during the three-year period of this ICR.
h We assume that EPA will take 2 hours to review the reports submitted by manufacturers showing the corrective actions and responses to any deficiencies identified in the audit report. We assume all of a manufacturer's model lines will be audited in a single visit. The audits for both new and existing models are accounted for on the line item for existing models.
i We assume that EPA will review and approve all re-certification applications for previously certified model lines. New model lines will not require recertification during the three-year period of this ICR. We assume that all 51 manufacturers with certified model lines will submit recertification requests each year.
j Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. We assume manufacturers will submit one report for half of their existing model lines each year, resulting in 1 response per year per manufacturer. We assume that EPA will take one hour to review the biennial reports.
k We assume that EPA will take 2 hours to review the annual quality assurance audits submitted by third-party certifiers. We assume that third-party certifiers will audit all of a manufacturer's model lines in a single visit and submit all audits in a single report. 51 manufacturers/8 third party certifiers = 6.4 occurances per certifier per year. We assume each audit takes 20 hours of the third-party certifier's time.
l We assume that EPA will take 2 hours to review the reports submitted by manufacturers showing the corrective actions and responses to any deficiencies identified in the audit report. Each model line is audited each year. Manufacturers must review the QA audits and then report to the third-party certifier and to the Administrator their corrective actions and responses to any deficiencies identified in the audit report.
m Test Labs and Third-Party Certifiers reapply for approval every five years. We assume all eight approved test labs and all eight approved third-party certifiers will reapply for approval when their current term of approval expires. We assume that EPA will approve all of the requests.
n We assume that each of the 8 test laboratories will conduct two biennial proficiency tests and prepare two reports during the three-year ICR period.
o Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 3: CapitalO&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Data Collection Device	Capital/Start-Up for One Respondent/ Model Line	Number of New Respondents/Model Line	Total Capital/Start-Up Cost (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M (E X F)
Certification Test a	$16,750	15	$251,250
Cost of Permanent Label b	$400	15	$6,000
Prepare Quality Assurance Plan c	$5,000	15	$75,000
Owner's Manual d	$2,250	15	$33,750
Quality Assurance Testing e				$16,750	17	$284,750
EPA Compliance Audit Test f				$17,815	0.33	$5,938
ISO Accreditation-Test Laboratories g	$75,000	0	$0
ISO Accreditation-Third-Party Certifiers h	$75,000	0	$0
Totals i			$366,000			$291,000		$657,000
a Models certified by testing per manufacturer: 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 15 models each year during the three-year ICR period.
b Total costs of permanent labels are estimated to be $400 per model. We assume 15 new models per year will require permanent labels during the three-year period of this ICR.
c Manufacturers of new model lines are required to prepare a quality assurance plan for each new model line.
d Manufacturers are required to prepare an Owner's Manual for each new model line. We assume an average fixed cost of $2,250 for preparation of an owner's manual.
e We assume that each manufacturer will perform a performance test under their quality assurance program once during the three-year period of this ICR at a cost of $16,750 per test.
f We assume that EPA will select one wood heater model line for compliance audit testing during the three-year period of this ICR. 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).
g We assume all eight test labs are already ISO accredited.
h We assume all eight third-party certifiers are already ISO accredited.
i Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 4: Respondents Responses

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
Manufacturers - New Model Lines
Test notification for new model lines a	15	1	0	15
Application for certification for new model lines a	15	1	0	15
Submit performance test results (electronic submittal) a	15	1	0	15
Renewal of certification of compliance b	0	0.2	0	0
Biennial reporting c	15	0.33	0	5
Quality Assurance testing d	0	0.33	0	0
EPA compliance audit testing e	0	0.33	0	0
Review annual quality assurance audit report f, g	0	0	0	0
Manufacturers - Existing Model Lines
Renewal of certification of compliance h	51	1	0	51
Biennial reporting i	51	2.48	0	127
Quality Assurance testing d	51	0.33	0	17
EPA compliance audit testing e	1	0.33	0	0.33
Review annual quality assurance audit report f, j	51	1	0	51
Testing Laboratories
Application for test lab approval (new)	0	1	0	0
Biennial proficiency testing and report development k	8	0.5	0	4
Application for re-approval as a test lab l	8	0.2	0	1.6
Third-Party Certifiers
Application for approval as a third-party certifier (new)	0	1	0	0
Application for re-approval as a third-party certifier l	8	0.2	0	1.6
Annual quality assurance plan audit f, m	8	6.4	0	51
			Total n	354
a We assume that 15 of the 51 existing manufacturers will each introduce and certify 1 new model line each year during the three-year period of this ICR.
b Manufacturers must request renewal of a model line's certificate of compliance every 5 years. For new model lines introduced during the three-year period of this ICR, no recertifications are necessary. 1 response/5 years = 0.2 responses/year.
c Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. The manufacturers of the 15 new model lines introduced and certified in year 1 of this ICR will submit a report in year 3, resulting in an average of 5 reports per year over the three-year period of this ICR.
d Manufacturers perform quality assurance testing as part of their quality assurance program. We assume that each manufacturer will have one model line tested during the three-year period of this ICR for quality assurance and submit a report. We assume only existing model lines will be tested. 1 test/3 years = 0.33 responses/year/manufacturer
e We assume EPA will request compliance audit testing of a single manufacturer's model line once during the three-year period of this ICR. We assume this test will be done on an existing model line. (1 test / 3 years = 0.33 responses/year)
f A third-party certifier performs a quality assurance audit on each model line each year. We assume that third-party certifiers perform the audits for all of a single manufacturer's model lines in one visit. Third-party certifiers then send the results of these audits to the manufacturer and EPA within 30 days. Manufacturers must report within 30 days to the third-party certifier and to the Administrator its corrective actions and responses to any deficiencies identified in the annual quality assurance program audit report.
g The reviews for the annual quality assurance audit reports for new model lines will be included with the reviews submitted by manufacturers for their existing model lines. We assume that reviews for all audit reports for all of a manufacturer's model lines are submitted in a single batch. Reports for new and existing model lines are submitted together. Audits for new model lines are accounted under existing model lines.
h Manufacturers must request renewal of a model line's certificate of compliance every 5 years. We assume that all 51 manufacturers will submit recertification requests each year.
i Each manufacturer of a certified wood heater model line must submit a report to the Administrator every 2 years following issuance of a certificate of compliance for each model line. We assume manufacturers will submit one report for half of their existing model lines each year. (253 model lines / 51 manufacturers / 2 = 2.48 response per year per manufacturer)
j We assume that each manufacturer's model lines are audited in one visit by the third-party certifier. Manufacturers must review the QA audits and then report to the third-party certifier and to the Administrator their corrective actions and responses to any deficiencies identified in the audit report.
k Test labs are required to participate biennially in an independently operated proficiency testing program. (1 participation / 2 years = 0.5)
l Test Labs and Third-Party Certifiers must reapply for approval every five years. We assume all eight approved test labs and all eight approved third-party certifiers will reapply for approval when their current term of approval expires and that EPA will approve all of the requests.
m Manufacturers of model lines are required to contract with third-party certifiers to perform quality assurance audits on each model line at least annually to ensure that the manufacturer's quality assurance plan is being implemented. We assume that third-party certifiers perform the audits for all of a single manufacturer's model lines in one visit and submit the results of the audits in a single batch within 30 days to the manufacturers and to EPA. We assume the eight third-party certifiers will each submit 6.4 audit reports to EPA per year for a total of 51 audit reports (51 manufacturers/8 certifiers = 6.4 audit reports/certifier/year). One audit report is submitted to EPA for each manufacturer.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
	Woodstove Manufacturers a
1	0	51	0	0	51
2	0	51	0	0	51
3	0	51	0	0	51
Average	0	51	0	0	51
	Test Labs / Third-Party Certifiers b
1	0	11	0	0	11
2	0	11	0	0	11
3	0	11	0	0	11
Average	0	11	0	0	11
a The EPA Certified Wood Heater Database indicates there are currently 51 woodstove manufacturers with 253 certified model lines. We assume no new manufacturers will enter this industry and become respondents in the three-year period of this ICR. We assume existing manufacturers will apply for certification of a total of 15 new model lines each year during the three-year period of this ICR.
b The database of EPA-approved test labs and third-party certifiers (https://www.epa.gov/sites/production/files/2021-04/documents/epa_approved_test_labs_and_third_party_certifiers_april_2021.pdf) shows there are 8 approved test labs and 8 approved third-party certifiers for a total of eleven approved organizations. We assume that no new Test Labs and Third-Party Certifiers will apply for approval during the three-year period of this ICR. Test Labs and Third-Party Certifiers must reapply for approval every five years. We assume that all labs/certifiers will reapply and receive approval.