NOTES
FOR
TABLE
2
a
Please
note:
numbers
shown
in
columns
(
A),
(
C),
and
(
E)
are
in
personhours
except
when
enclosed
in
parenthesis.
Numbers
enclosed
by
parenthesis
signify
costs.
It
was
necessary
to
make
several
general
assumptions
regarding
1)
how
wood
heater
manufacturers
would
respond
to
the
various
alternatives
for
compliance
and
2)
the
large
variety
of
wood
heater
manufacturer
size
and
marketing
approaches.
Using
data
from
EPA's
Section
114
survey
of
manufacturers,
the
following
assumptions
were
developed
for
this
burden
calculation:

1)
50
woodstove
manufacturers
2)
200
woodstove
models
3)
4
woodstove
models
per
manufacturer
4)
750
woodstoves
produced
annually
for
each
model
by
each
manufacturer
5)
3,000
woodstoves
produced
annually
by
each
manufacturer
6)
150,000
woodstoves
produced
each
year
by
all
manufacturers
b
Assumes
that
during
the
next
3
years
of
the
woodstoves
NSPS,
the
typical
manufacturer
will
require
4
Phase
II
certification
tests
over
the
3
year
period.
Thus,
4
notices
in
3
years
equals
1.33
notices
per
year.

c
Each
manufacturer
is
assumed
to
pay
$
7,500
per
certification
test
for
4
tests
over
3
years
(
1.33
tests
per
year).
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.

d
See
footnote
b.

E
Biennial
reporting
equals
0.50
occurrences/
year.

f
Total
costs
of
permanent
labeling
are
estimated
at
$
2.00
per
stove.
There
are
essentially
no
burden
hours
associated
with
this
cost.

g
Removable
labels
estimated
to
require
30
seconds
to
apply
per
wood
heater.

h
Removable
labels
estimated
to
cost
$
0.75
per
label.

i
Twenty
hours
required
to
include
requisite
information
in
owner's
manual.

j
Assumes
an
emissions
test
is
performed
once
every
5,000
units
and
since
750
units
are
produced
each
year
for
each
model,
0.15
emission
tests
are
performed
annually
per
manufacturer
per
model.
Since
each
manufacturer
has
three
models,
0.8
emissions
tests
per
year,
per
manufacturer
will
be
conducted
(
0.15
*
3
=
0.45).

k
See
footnote
b.

l
Assumes
that
750
units
per
model
year
are
produced
and
that
one
out
of
every
150
units
undergoes
a
parameter
inspection.
Thus,
a
parameter
inspection
will
occur
approximately
5
times
per
year
per
manufacturer
per
model.
Since
each
manufacturer
has
four
models,
20
parameter
inspections
will
be
conducted
annually
for
each
manufacturer.
2
m
See
footnote
j.

n
No
additional
burden
because
manufacturers
already
keep
track
of
sales
data
for
marketing
purposes
and
payment
of
income
taxes.

o
Assumes
one
report
filed
by
each
manufacturer
annually.

P
See
footnote
b.

q
Assumes
that
one
new
lab
will
apply
for
accreditation
each
year.

r
An
average
of
two
notifications
per
proficiency
test
is
assumed
due
to
test
cancellation
and
rescheduling.

s
Annual
proficiency
tests.
It
is
assumed
that
for
each
laboratory
applying
for
accreditation,
another
laboratory
will
not
renew
their
accreditation;
therefore,
there
is
no
net
increase
in
the
number
of
laboratories
from
year
to
year
and
the
number
of
respondents
remains
constant
at
four.

t
Each
laboratory
is
required
to
report
to
EPA
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.

u
Laboratories
are
expected
to
spend
4
hours
per
week
to
update
and
maintain
records
on
certification
tests.

v
One­
quarter
of
the
estimated
3,500
wood
heater
retailers
are
assumed
to
buy
and
sell
used
wood
stoves.
These
875
retailers
are
each
assumed
to
purchase
4
used
stoves
per
year
and
to
spend
6
minutes
per
purchase
maintaining
records
of
each
used
wood
heater
purchase.
