Supporting Statement for

EPA Information Collection Request:

“Nomination Application for the U.S. EPA 

Montreal Protocol Awards”

EPA ICR # 2389.01

OMB Control No. 2060-NEW

September 10, 2010

Stratospheric Protection Division

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
Table of Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION ............................... 1

1(a) Title and Number of the Information Collection ................................................. 1

1(b) Short Characterization/Abstract........................................................................... 1

2. NEED FOR AND USE OF THE INFORMATION COLLECTION.......................... 2

2(a) Need/Authority for the Collection........................................................................ 2

2(b) Practical Utility/Users of the Data ....................................................................... 2

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA .......................................................................................................................... 3

3(a) Non-Duplication................................................................................................... 3

3(b) Public Notice Required Prior to ICR Submissions to OMB................................ 3

3(c) Consultations........................................................................................................ 3

3(d) Effects of Less Frequent Collection..................................................................... 3

3(e) General Guidelines............................................................................................... 3

3(f) Confidentiality...................................................................................................... 4

3(g) Sensitive Questions.............................................................................................. 4

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ........................ 4

4(a) Respondents and NAICS Codes........................................................................... 4

4(b) Information Requested ......................................................................................... 4

5. THE INFORMATION COLLECTED- AGENCIES ACTIVIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT........................................ 5

5(a) Agency Activities................................................................................................. 5

5(b) Collection Methodology and Management.......................................................... 6

5(c) Small Entity Flexibility........................................................................................ 6

5(d) Collection Schedule.............................................................................................. 6

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION..................... 7

6(a) Estimating Respondent Burden............................................................................ 7

6(b) Estimating Respondent Costs............................................................................... 7

6(c) Estimating the Respondent Universe and Total Burden and Costs...................... 8

6(d) Estimating Agency Burden and Costs.................................................................. 9

6(e) Bottom Line Burden Hours and Cost Tables....................................................... 1

6(f) Reasons for Change in Burden............................................................................. 1

6(g) Burden Statement ................................................................................................. 2

Appendices

Appendix A Federal Register Notices Seeking Comments on ICR

Appendix B U.S. EPA Montreal Protocol Award Nomination

Exhibits

Exhibit 4.1 NAICS Codes of Industries that May be Affected by the USMPA ICR

Exhibit 6.1 Estimated Burden and Costs to Private Industry Respondents

Exhibit 6.2 Agency Burden/Cost

Exhibit 6.3 Average Estimated Respondent Burden and Cost Summary

Exhibit 6.4 Average Estimated Agency Burden and Cost Summary
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Nomination Application for the U.S. EPA Montreal Protocol Awards

EPA ICR Number: 2389.01

OMB Control Number: [2060-NEW]

1(b) Short Characterization/Abstract

The U.S. Environmental Protection Agency (EPA) Stratospheric Protection 

Division established the U.S. EPA Montreal Protocol Award (USMPA) program in 1990 

to recognize outstanding contributions to the protection of the Earth’s stratospheric ozone 

layer. It is named after the international treaty that aims to reverse erosion of the ozone 

layer by replacing and/or phasing out the production of ozone-depleting substances 

(ODS). Since 1990, EPA has presented more than 500 awards to outstanding individuals, 

teams, companies, organizations, and government institutions in 54 countries. Awards 

are particularly prestigious because nominees compete globally against the 

accomplishments of many other potential awardees, and recipients are selected by

previous awardees and EPA.

Participation in the program requires applicants (called nominees or nominators) 

to complete a nomination form that details the project or activity they believe is worthy

of the USMPA award. EPA seeks nominations for the following accomplishments: 

originality and public purpose; leadership and corporate responsibility; global perspective 

and implication; actual elimination of ozone-depleting substance emissions; success in 

eliminating substances that deplete the ozone layer and contribute to climate change or in 

transitioning to alternatives with reduced environmental impact; or leadership in 

improving awareness of the harmful health effects of overexposure to ultraviolet

radiation.

All nominations must be submitted using the nomination form provided by the 

USMPA program on its Web site1, and include a cover letter. Nominees are also 

encouraged, but not required, to submit supporting materials such as photographs, videos, 

technical descriptions, or news releases, to bolster their nomination. Submission of this 

additional material is encouraged because the judges do not conduct on-site visits.

This information collection request (ICR) supporting statement includes estimates 

of the burden for collection of USMPA program information for domestic respondents 

and EPA, only. The total estimated respondent burden is 187.5 hours and $6,240, and the 

estimated Agency burden is 243 hours and $13,368 over three years.

 

1 U.S. EPA Montreal Protocol Awards Web site: http://www.epa.gov/ozone/awards/index.html
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

 

2. NEED FOR AND USE OF THE INFORMATION COLLECTION

2(a) Need/Authority for the Collection

The USMPA program is associated with EPA’s Stratospheric Ozone Protection 

program. The U.S EPA is the federal agency primarily responsible for domestically

implementing the Montreal Protocol on Substances that Deplete the Ozone Layer 

(Montreal Protocol). Under the Clean Air Act, EPA has created several regulatory

programs to end the production of ozone depleting substances in the U.S., reduce 

emissions of ozone depleting substances, and identify safe and effective alternatives. The 

success of the Montreal Protocol has depended upon the work of many in government, 

industry, and the environmental community. Private and public leaders around the world 

collaborated to develop and test new technologies to eliminate the need for ozonedepleting substances. These organizations and individuals broke down many technical, 

institutional, and financial barriers, paving the way for the commercialization and 

standardization of new materials, products, and processes. In addition, their leadership 

has played a key role in the negotiation of the Montreal Protocol phaseout schedules. As 

a result of this leadership, phaseout targets were more easily achieved.

The USMPA program recognizes outstanding contributions to the protection of 

the Earth’s stratospheric ozone layer. The Stratospheric Protection Division believes 

award recipients are leading by example. Their demonstrated commitment and 

extraordinary contributions inspire other individuals and organizations to make a 

difference in protecting the environment and public health. Their significant contributions 

help mitigate the health and environmental risks of ozone depletion, which include skin 

cancer, suppression of the immune system, cataracts, and damage to marine life and 

crops, as well as the health and environmental risks of climate change, which include air 

quality problems and damage to agricultural crops.

Although the ozone layer is on track to recover this century, researchers at the 

National Aeronautics and Space Administration have studied the “world avoided” – the 

catastrophic implications for the ozone layer if the community of nations had not agreed 

to solve this problem. These implications, in addition to widespread media coverage of 

the Antarctic “ozone hole,” underscore the tremendous value of the awardees’ 

contributions to protecting the planet and public health. 

2(b) Practical Utility/Users of the Data

The Stratospheric Protection Division of EPA uses the collected information to 

evaluate award nominations, in conjunction with past awardees, and to choose USMPA 

program award recipients. The submitted information is edited by EPA and then 

included in the award ceremony program and posted to EPA’s USMPA web site.
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

EPA is requesting information from award nominees associated with projects or 

activities that EPA may consider outstanding contributions to the protection of the 

Earth’s stratospheric ozone layer. Nominees must include their names, contact 

information, and reference names and contact information, as well as a summary of their 

contributions. No other EPA program solicits this collection of information, and this 

information must be submitted together to allow EPA and its partners to evaluate the 

contributions of nominees and justify the awards. 

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

In compliance with the 1995 PRA, any agency developing a non-rule-related ICR must 

solicit public comments for a 60-day period prior to submitting the ICR to OMB. These 

comments, if any, could help EPA refine its burden assumptions or other aspects of the 

collection prior to submitting the ICR package to OMB for approval. Accordingly, for 

this ICR EPA provided a 60-day public notice and comment period that ended on

September 7, 2010 (see Appendix A for 75 FR 39011, July 7, 2010). No comments were 

submitted to the docket during the 60-day public notice and comment period.

EPA will also publish a second Federal Register notice requesting public comment on the 

ICR on or after the date of submission of this ICR to the Office of Management and 

Budget. A draft of this Federal Register Notice is available in Appendix A. 

3(c) Consultations

EPA consulted with Paul Horowitz of the World Bank to verify that the hours 

contained in Exhibit 6.1 are accurate of the burden to the respondent. Mr. Horowitz has 

submitted multiple nominations in prior years and is familiar with the requirements of the 

nomination.

3(d) Effects of Less Frequent Collection

The USMPA program acknowledges leaders of ODS reductions each year. If this 

information collection occurs less often, fewer organizations or individuals may be 

recognized for their accomplishments, and less frequently. Without annual recognition, 

fewer nominees may pursue this opportunity.

3(e) General Guidelines

The information collection activities discussed in this renewal ICR comply with 

all regulatory guidelines under 5 CFR 1320.5(d)(2). 
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

3(f) Confidentiality

No information collected by EPA for the USMPA program comprises confidential 

business information.

3(g) Sensitive Questions

The USMPA nomination form does not request any information that would be of 

a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

Previous USMPA program award winners have come from many different fields

and 54 countries. Winners of the award can be individuals, organizations, government, 

public- or private-sector, and domestic or international.2 

Exhibit 4.1, below, provides a list of industries that may be affected by 

information collection requirements covered under this ICR, by North American Industry

Classification System (NAICS) code, based on a review of the pool of past award 

nominees. This list is intended to be illustrative; entities from other industries may elect 

to apply to the U.S. EPA Montreal Protocol Awards program. However, EPA expects 

that most nominations will come from the following industries:

Exhibit 4.1 NAICS Codes of Industries that May be Affected by the USMPA ICR

NAICS Code Industry

92 Public Administration

325 Chemical Manufacturing

541 Professional, Scientific and Technical Services

813212 Voluntary Health Organizations

813312 Environment, Conservation and Wildlife Organizations

813910 Business Associations

813920 Professional Organizations

4(b) Information Requested

Once a prospective nominator/nominee reviews the USMPA program materials 

and decides to apply, the individual must submit a USMPA program application form 

 

2 Although the USMPA program includes nominations from international entities, this ICR only covers the 

paperwork burden imposed on U.S. persons. 
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

(see Appendix B for the complete form). This ICR does not require the respondents to 

keep any records.

The nomination form will be available in electronic form (Microsoft Word and 

PDF) from the USMPA program web site. Candidates may submit their nominations by

mail, electronic mail, or fax. The nomination deadline is March 1st of each year. 

(i) Data Items

All submissions must include the following items (the first five of which are reported on 

the nomination form):

 Award category information including project title, dates and status;

 Contact information for the nominee;

 Contact information for the nominator;

 Contact information for two references;

 Summary of accomplishments related to the USMPA program;

 Cover letter; and

 Optional supporting materials, such as photographs, videos, technical 

descriptions, news clippings, and press releases.

(ii) Respondent Activities

All respondents must complete these activities to apply for an award:

 Read the nomination instructions;

 Provide contact information for the nominee/nominator;

 Contact references to obtain their consent to include their names and contact 

information on the nomination form;

 Write a summary of accomplishments in no more than 600 words;

 Create supporting materials (optional);

 Write a cover letter; and

 Submit the nomination via mail, electronic mail or fax.

5. THE INFORMATION COLLECTED- AGENCIES ACTIVIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

5(a) Agency Activities

The Agency performs the following activities associated with processing and 

maintenance of the U.S. EPA Montreal Protocol Award nomination form:

 Maintain downloadable Microsoft Word and PDF versions of the nomination, 

with up-to-date contact information, on the EPA web site;
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

 Answer questions posed by potential nominees;

 Receive nominations and review them for completeness and follow up, as 

necessary, with nominators;

 Review nominations to select awardees;

 Notify both successful and unsuccessful nominees of Agency decisions.

5(b) Collection Methodology and Management

EPA will provide electronic forms in the Microsoft Word and PDF formats, as 

well as a hard copy version if requested, to collect information associated with the 

USMPA program. Respondents will be able to download the form from the EPA web 

site and send the completed form to the Agency via fax, mail, or electronic mail. At this 

time, EPA is not considering providing a web-based form through which nominations 

may be submitted. EPA does not believe that an online version would significantly

reduce burden for respondents.

In collecting and analyzing the information associated with this ICR, EPA will 

use a telephone system, personal computers, and applicable software. EPA will ensure 

the completeness of the forms by reviewing each submission. Information about award 

winners will be posted to the U.S. EPA Montreal Protocol Awards web site for viewing 

by the public.

EPA has collected award nominations since the inception of the award in 1990. 

In EPA’s experience with the award program, the information collected is useful, 

accurate, and reliable for determining the merits of award recipients. EPA’s long 

experience implementing the Montreal Protocol in the U.S. allows the Agency to 

appropriately determine the validity of nominations. EPA also seeks input from past 

award recipients on nominations.

5(c) Small Entity Flexibility

EPA expects that some of the entities completing the award nomination may be 

small entities. EPA has designed its nomination form to minimize respondent burden 

while obtaining sufficient information for evaluating applicants for award. In addition, 

given the voluntary nature of the collection, EPA expects that respondents will participate 

only if the benefits of participation outweigh the information collection burden.

5(d) Collection Schedule

Data collection occurs on a rolling basis. Nominations for award nominations 

must be submitted no earlier than January 1 and no later than March 1 of the year in 

which the award will be presented.
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Exhibit 6.1 presents the estimated burden hours and costs for all respondents 

covered under this ICR assuming a total of 2.5 hours for all respondent categories. No 

capital or operations and management costs are incurred by respondents under this ICR, 

with the possible exception of postage and/or photocopy costs.

The data collection mechanism for the U.S. EPA Montreal Protocol Awards is the 

USMPA nomination form. In an effort to minimize burden and cost, the USMPA 

nomination form was designed to contain straightforward questions. It was also designed 

in such a way that one nomination package will serve all types of respondents. For 

purposes of this ICR, given the array of industries in which respondents may work, cost 

and burden estimates are presented for two categories: private industry and state and local 

government. While some respondents are from countries outside the United States, this 

burden estimate considers only domestic respondents (even if they nominate an 

international entity).

6(a) Estimating Respondent Burden

Given that all respondents are asked to complete all elements of the same form, 

the burden rate for all entities will be the same. The average respondent burden is 

estimated to be 2.5 hours. The respondents must write a cover letter (0.2 hours), 

complete the USMPA nomination (1.6 hours), and submit the package via fax, mail, or 

electronic mail (0.2 hours). In addition, respondents are entitled to review nominations 

for future years’ awards and provide input to EPA on the merits of those nominations (0.5 

hours).

EPA used professional judgment to arrive at a burden estimate and then consulted 

representatives from the respondent categories to make sure the burden estimate was 

reasonable. While respondents are also encouraged to submit supporting materials such 

as photographs, videos, technical descriptions, news clippings, and press releases, they

are not required to do so. Nonetheless, this cost is estimated here as part of respondent 

burden.

6(b) Estimating Respondent Costs

EPA estimates an hourly labor rate (base hourly rate plus fringe) of $27.73 for all 

private industry workers, based on the Employer Costs for Employee Compensation 

(ECEC) series published by the Bureau of Labor Statistics in March of 2010.

3

 The 

Agency has accounted for overhead cost by increasing this hourly rate by 20 percent to 

 

3 BLS News Release, March 10, 2010. Employer Costs for Employee Compensation – March 2010. See 

Table 5, available at http://www.stats.bls.gov/news.release/pdf/ecec.pdf
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

$33.28.

4

 EPA does not expect respondents to incur capital or operating and maintenance 

costs associated with the USMPA program nomination.

The type of staff needed to complete the USMPA nomination form and their 

associated hourly labor rates, reflected in the “all workers” ECEC categorization,

appeared reasonable to the past respondents contacted as part of the consultations listed 

in section 3(c). Exhibit 6.1 provides a summary of respondent burden and cost for private 

industry. EPA does not anticipate any significant response from state and local 

government workers.

Exhibit 6.1. Estimated Burden and Costs to Private Industry Respondents

Activity Labor Rate Person 

Hours

Total

Annual Cost

Read the nomination instructions $33.28 0.2 $6.66

Provide contact information for the 

nominee/nominator

$33.28 0.1 $3.33

Contact references to obtain their 

consent to include their names and 

contact information on the nomination

form

$33.28 0.3 $9.98

Write a summary of accomplishments 

in no more than 600 words

$33.28 0.5 $16.64

Create supporting materials (optional) $33.28 0.5 $16.64

Write a cover letter $33.28 0.2 $6.66

Submit the nomination via mail, 

electronic mail or fax

$33.28 0.2 $6.66

Review subsequent nominations for 

merit

$33.28 0.5 $16.64

Total 2.5 $83.21

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

In 2008, 2009, and 2010, EPA received 37, 43, and 49 nominations, respectively. 

Half of all nominations were submitted by respondents outside the United States. 

Assuming a high end of 25 domestic nominations per year, EPA estimates that 75 

nominations will be submitted over the three-year life of the clearance.

 

4 U. S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA452-02-001, January 2002, pg. 2-34. The loading for indirect costs is within the range of 20-70% of the 

load labor rate (wage + benefits) suggested in EPA guidance.
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

The total burden hours and cost associated with this information collection over 

the course of three years is 187.5 hours and $6,240, respectively.

6(d) Estimating Agency Burden and Costs

Exhibit 6.2 presents the estimated Agency burden hours and costs associated with 

the information collection activities under this ICR. Other direct costs (copying, printing, 

telephone, and mailing expenses) are also included. EPA based its burden estimates on 

its experience managing this awards program in past years.

Based on the Bureau of Labor Statistics’ Occupational Employment Statistics, 

EPA estimates an average hourly labor rate for all occupations under NAICS 999100 

(Federal Executive Branch, OES Designation) of $34.38.5 This rate is multiplied by a

government overhead (including benefits) factor of 1.66, resulting in an hourly wage rate

of $55.01. 

The total burden hours and cost associated with this information collection over 

the course of three years is 243 hours and $13,368, respectively.

 

5 Bureau of Labor Statistics data for Federal executive Branch employees is available at 

http://www.bls.gov/oes/current/naics4_999100.htm#00-0000

6 This overhead factor is provided in the October 2009 EPA ICR Handbook. 
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

Exhibit 6.2. Agency Burden/Cost 

Activity No. of 

Nominations 

per Year

Estimated 

Cost per 

Hour

Person 

Hours

Total 

Annual 

Cost

Maintain downloadable Microsoft 

Word and PDF versions of the 

nomination, with up-to-date contact 

information, on the EPA web site

25 $55.01 20 $1,100.20

Answer questions posed by

potential nominees 

3 $55.01 1 $55.01

Receive nominations and review 

them for completeness and follow 

up, as necessary, with nominators

25 $55.01 20 $1,100.20

Review nominations to select 

awardees

25 $55.01 36 $1,980.36

Notify both successful and 

unsuccessful nominees of Agency

decisions

25 $55.01 4 $220.04

TOTAL 81 $4,456.17

6(e) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Exhibit 6.3. Average Annual Estimated Respondent Burden and Cost Summary

Average # of Respondents Average Burden Hours Average Cost

25 62.5 $2,080

b. Agency Tally

Exhibit 6.4. Average Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Cost

81 $4,456

6(f) Reasons for Change in Burden

Since this is a new ICR, change in respondent burden is not applicable.
Information Collection Request for the U.S. EPA Montreal Protocol Awards Program 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average less than 3 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 currently valid OMB control

number. The OMB control numbers for EPA's regulations are listed in 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-OAR-2010-0410, which is 

available for online viewing at www.regulations.gov, or in person viewing at the Air and 

Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. 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 Air and Radiation Docket is (202) 566-1669. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to 

submit or view public comments, access the index listing of the contents of the public 

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 above. Also, you can send comments to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA-HQ-OAR-2010-0410 and OMB Control Number 2060-NEW

in any correspondence.