Burden Calculation Table

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Overview

inputs
Table 1
Table 2
Capital-Start-up

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Sheet 1: inputs

ICR covers years 2019-2021
	2015 ICR	2015 Memo Assumptions (2018-2020)	5/1/2018 Data	6/21/2018 Data1
Total manufacturers	66	66	83	88	Note: One manufacturer carries a single discontinued line and has not submitted new certifications since prior to 2015.
Total models certified	126	270	546	568
Total models discontinued from 2015-2018			48	55
Total models certified and in production (certified - discontinued)			498	513
Manufacturers w/ Models Certified to Step 1	66	66	70	75
Total Models Meeting Step 1 (Deemed Certified + Certified Post-Final):	-	-	418	425
Manufacturers w "Deemed Certified" Models thru 2020	66	66	64	66
Models "Deemed Certified" thru 2020	144	270	347	342
Step 1 models that may meet step 2 standards			118	118	(includes 35 manufactures)
Manufacturers w Models Certified to Step 1 fr May 2015-May 2018	-		24	29
Models Certified to Step 1 fr May 2015-current 2	126		71	83	(includes 46 lines that could meet Step 2 standards)
Model lines/manufacturers certified from 2015-2018 for Step 1:	4.1	4.1	3.0	2.9
Manufacturers w/ Models Meeting Step 2	66		36	37
Models Certified for Step 2 between 2015-2018	270		80	88
Model lines/manufacturers certified from 2015-2018 for Step 2:	4.1		2.2	2.4
Anticipated # of Manufacturers to Certify to Step 2 prior to 2020			30	33	# of Manufacturers
Anticipated # of Models Certified to Step 2 prior to 2020			75	85	# Models
Test Laboratories Accredited	6		6	8	# Test Labs
Third-Party Certifiers Accredited	6		7	8	# 3rd Party Certifiers
				49	Total Respondents
1 2018 Certification Data based on EPA's List of Certified Wood Heaters: https://www.epa.gov/sites/production/files/2017-08/usepa-certified-wood-heater-list.xlsx (June 2018)
2 Based on a count of models not included on EPA's Historical List of Certified Heaters: https://www.epa.gov/compliance/historical-list-epa-certified-wood-heaters (April 2015)
Findings:
As of June 2018, there are a total of 88 manufacturers and 568 model lines. Of these, 75 manufacturers have 425 model lines that are deemed certified through 2020. All model lines must be recertified for the 2020 PM standards.
Of the current model lines that were automatically certified (lines that met the 2015 PM standard at the time of the compliance date of the final rule), there are 35 manufacturers with 118 lines that could potentially be certified to Step 2 standards (meeting the PM standard of <= 2.5). At least 46 lines (owned by an additional 6 manufacturers) certified to Step 1 between 2015-2018 could also be recertified under Step 2 for 2020. However, this does not account for manufacturers who choose to discontinue model lines. Based on industry trends of consolidation and decreasing market size, it is anticipated that the number of manufacturers and market orders are in decline. Only 29 manufacturers have certified 83 new models to step 1 between 2015-2018 (~28 models/year), and only 37 manufacturers have certified 88 new models to step 2 between 2015-2018 (~29 models/year). It is not anticipated that additional models will be certified to Step 1 in 2019, due to the impending 2020 standards.
Based on the number of manufacturers and models certified following 2015 and industry consultations, and it is assumed that an average of 85 model lines could be recertified by 33 manufacturers over the three-year period of this ICR.
Based on current EPA data, there are 8 EPA-approved testing laboratories and 8 EPA-approved third-party certifiers. There are a total of 12 testing laboratories and third-party certifiers due to overlap between approvals.

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Sheet 2: 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	(E) Technical hours per year (E=CxD)	(F) Management hours per yeara (F=Ex0.05)	(G) Clerical person-hours per yeara (G=Ex0.1)	(H) Total Cost per year,$ b
Reporting Requirements										112.98	Technical
Manufacturers										149.35	Managerial
1. Certification test notification c	2.00	0.9	1.7	33	56.7	2.8	5.7	$7,135.95		54.81	Clerical
2. Application for certification d	8.00	0.9	6.9	33	226.7	11.3	22.7	$28,543.79
3. Biennial reporting e	2.00	1.7	3.4	33	113.3	5.7	11.3	$14,271.90
4. EPA compliance audit testing f	8.00	0.3	2.7	1	2.7	0.1	0.3	$335.81
5. QA performance test results g	2.00	0.3	0.7	33	22.0	1.1	2.2	$2,770.43
6. QA annual audit reports h	20.00	10.6	212.5	8	1700.0	85.0	170.0	$214,078.45
7. Review annual QA audit report i	4.00	1.0	4.0	33	132.0	6.6	13.2	$16,622.56
Test Laboratories	.
1. Application for test lab approval j
a. Already has ISO accreditation	20.00	0.0	0.0	8	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	$0
2. Biennial profiency testing and report development k	150.00	0.7	100.0	8	800.0	40.0	80.0	$100,742.80
Third-Party Certifier
1. Application for approval as a third-party certifier l
a. Already has ISO accreditation	20.00	0.0	0.0	8	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	$0
Subtotal for Reporting Requirements					3,511			$384,502
Recordkeeping Requirements
Manufacturers
1. Test documentation m	1.00	0.9	0.9	33	28.3	1.4	2.8	$3,567.97
2. QA parameter inspections n	2.00	4.0	8.0	33	264.0	13.2	26.4	$33,245.12
3. Retained (sealed) stoves o	1.00	0.9	0.9	33	28.3	1.4	2.8	$3,567.97
Test Laboratories
1. Certification test, proficiency test, and audit test results p	2.00	12.0	24.0	8	192.0	9.6	19.2	$24,178.27
Third-Party Certifier
1. Certification test, QA program inspection and audit tests q	2.00	12.0	24.0	8	192.0	9.6	19.2	$24,178.27
Subtotal for Recordkeeping Requirements					810			$88,738
TOTAL BURDEN AND COSTS (rounded)r					4,320			$473,000
TOTAL CAPITAL AND O&M COST (rounded)r								$740,000
GRAND TOTAL (rounded)r								$1,210,000			17	hr/response
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 $112.98, management at $149.35 and clerical at $54.81.
c Assumes that 85 models will require new certification to meet 2020 emission standards or will recertify their current compliance certifications over the period of the ICR..
d Assumes that 85 models will require new certification due to meet 2020 emission standards or will recertify or renew (where a test waiver is obtained) compliant certifications over the period of the ICR.
e For the three-year period of this ICR, we assume 2 biennial reports per manufacturer for each of their models 85 models/33 manufacturers x 2 reports = 5.2 reports), or 1.7 responses per year at 2 hrs per report.
f Assumes that one of the 33 manufacturers will be required to undergo an EPA compliance audit test for one of their models during the three-year ICR period.
g Assumes that there will be one QA audit performance test per manufacturer (33 manufacturers) under the QA program during the period covered by this ICR. We assume that each of the 33 manufacturers will be required to test one model and report results to the EPA under their QA program.
h Assumes there will be three QA audits by third-party certifiers for each of the 33 manufacturers over the three-year ICR period 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).
i 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).
j Assumes 0 occurances for the three-year ICR period.
k Assumes that each of the 8 test laboratories will conduct two biennial proficiency tests and prepare two reports during the three-year ICR period.
l Assumes 0 occurances for the three-year ICR period.
m Assumes that manufacturers will spend one hour per certification test (for 85 models) to keep the required records.
n Parameter inspections are part of the existing safety inspection program. We have assumed each of the 33 wood stove manufacturers with certified models will spend an additional 2 hours per quarter to document results.
o Assumes that one stove is sealed and retained for each certification test (for 85 models) required of the 33 manufacturers over the three-year ICR period.
p We expect the required recordkeeping to be highly automated and have assumed that test laboratories will spend 2 hours per month to maintain records.
q 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.
r Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 3: 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	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours a per year(F=Ex0.05)	(G) Clerical person-hours a per year (G=Ex0.1)	(H) Total Cost per year,$ b
1. Certification test notification c	0.5	0.9	0.4	33	14.2	0.7	1.4	$763.90		$48.08	technical
2. Certification test d	20.0	0.9	17.2	4	73.0	3.6	7.3	$3,935.22		$64.80	management
3. Application for certification of model line e	8.0	0.9	6.9	33	226.7	11.3	22.7	$12,222.32		$26.02	clerical
4. Biennial reporting for certified models f	1.0	0.9	0.9	33	28.3	1.4	2.8	$1,527.79
5. Review and approval of test lab credentials g	4.0	1.0	4.0	0	0.0	0.0	0.0	$0
6. Review test lab biennial proficiency test reports h	10.0	0.7	6.7	8	53.3	2.7	5.3	$2,875.84
7. Review QA performance test results i	2.0	0.3	0.7	33	22.0	1.1	2.2	$1,186.28
8. Review QA audit report j	2.0	1.0	2.0	8	16.0	0.8	1.6	$862.75
9. EPA Compliance Audit k	40.0	0.3	13.3	1	13.3	0.7	1.3	$718.96
10. Review and approval of third-party certifier credentials l	8.0	1.0	8.0	0	0.0	0.0	0.0	$0
TOTAL (rounded)m					514			$24,100
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 $48.08, management at $64.80, and clerical at $26.02.
c Models certified by testing per manufacturer: Assumes that 85 models will require new certification to meet 2020 emission standards or will recertify their current compliance certifications between the 2018-2020 time period, and that roughly 1/3 of models are recertified each year over the three-year period.
d Assumes that EPA will observe 5 percent of certification tests (85 X .05) conducted during the ICR reporting period, which is rounded to 4 tests per year.
e Assumes that EPA will review and approve certification applications for 85 models which will require new certification due to meet 2020 emission standards or will recertify or renew (where a test waiver is obtained) compliant certifications.
f Assumes that the EPA will receive one biennial report for 85 models (33 manufacturers) over the 3-year ICR period.
g Assumes 0 occurances for the three-year period.
h Assumes that each of the 8 test laboratories will conduct two biennial proficiency tests and prepare two reports during the three-year ICR period.
i Assumes that there will be 33 QA emissions test results submitted under the QA program and reviewed by the EPA during the period covered by this ICR. We assume that each of the 33 manufacturers will be required to test one model and report results to the EPA under their QA program between 2018 and 2020.
j Assumes there will be three QA audits by the third-party certifiers reviewed by the EPA for each of the 33 manufacturers over the three-year ICR period.
k Assumes that one model line for one of the 33 manufacturers will be audited by the EPA during the ICR three-year period.
l Assumes 0 occurances for the three-year ICR period.
m Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 4: Capital-Start-up

(A)	(B)	(C)	(D)
Data Collection Device	Capital/Start-Up for One Respondent/Unit	Number of New Respondents/Models/Units	Total Capital/Start-Up Cost
			(B X C)
Certification Test a	$16,750 per respondent	85 models	$1,423,750
Cost of Permanent Label b	$400 per model	85 models	$34,000
QA Performance Test c	$16,750 per respondent	33 respondents	$552,750
EPA Compliance Audit Test d	$17,815 per respondent	1 respondent	$17,815
Owners Manuale	$2,250 per model	85 models	$191,250
ISO Accreditation-Test Laboratoriesf	$75,000 per respondent	0 respondents	$0
ISO Accreditation-Third-Party Certifiersg	$75,000 per respondent	0 respondents	$0
Totals			$2,220,000
Annual average			$740,000
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 85 models during the three-year ICR period in order to replace old models that will not meet the Step 2 emission standards.
b Total costs of permanent labels are estimated to be $400 per model. We estimate that there will be 85 certified models produced by all manufacturers (33 manufacturers) during the period covered by this ICR that would be subject to permanent labeling requirements.
c Assumes that there will be 33 QA performance tests (at a cost of $16,750 per test (includes EPA testing ($11,000), confirmation safety testing or full safety testing ($5,000), and shipping of prototype(s)($750) costs)) under the QA program during the three-year period covered by this ICR. We assume that each of the 33 manufacturers will be required to test one model under their QA program between 2019 and 2020.
d Assumes that there will be EPA compliance audit testing for one model affecting one manufacturer during the period covered by 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).
e Assumes an average fixed cost of $2,250 for owner's manual (revised or new, possibly bilingual) per model (85 models) that will need to be developed/revised to include subpart AAA requirements.
f Assumes all test labs are ISO accredited (that are going to choose be accredited), a total of 6 labs.
g Assumes all third-party certifiers are ISO accredited (that are going to choose to be accredited).