## Supporting Statement for EPA Information Collection Request:
“ Nom ination Application for the U.S. EPA Montreal Protocol Awards ”
EPA I CR # 2389.01 OMB Control No. 2060
- NEW

September 10 , 2010

Stratospheric Prot ection Division U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

### Table of Contents

1. ID ENTIFICATION 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 COLLECT ION
.......................... 2 2(a) Need/Authority for the Collection
................................ ................................ ........ 2 2(b) Practical Utility

/Use rs of the Data
................................ ................................ ....... 2 3. NON
- DUPLICATION, CONSUL TAT IONS, AND OTHER COLLECTION CRI TERIA
................................ ................................ ................................ .......................... 3 3(a) Non
- Duplication
................................ ................................ ................................ ... 3 3(b) Public Notice Required Prior to I CR 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 NAI CS Codes
................................ ................................ ........... 4 4(b) In formation Requested
................................ ................................ ......................... 4 5. THE INFORMATION COLLECTED
- AGENCIES ACTIVI ES, 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 COLLECTI ON
..................... 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 L ine Burden Hours and Cost Tables
................................ ....................... 1 6(f) Reasons for Change in Burden
................................ ................................ ............. 1 6(g) Burden Statement
................................ ................................ ................................ . 2 

### Appendices Appendix A Federal Register Notice s Seeking Comments on ICR Appendix B U.S. EPA Montreal Protocol Award Nomination 

### Exhibit s Exhibit 4.1 NAI CS Codes of Industries that May be Affected b y the USMPA I CR Exhibit 6.1 Estimated Burden and Costs to Private Industry Respondents Exhibit 6. 2 Agenc y Burden/Cost Exhibit 6. 3 Average Estimated Respondent Burden and Cost Summary Exhibit 6. 4 Average Estimated Agency Burden and Cost SummaryInformation C ollection Request for the U.S. EPA Montreal Protocol Awards Program



### Supporting St atement 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 Numbe r : 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 particularl y prestigious because nominees compete globally against the accomplishments of many other potential awardees, and recipients are selected by previous awardees and EPA. Participation in th e program requires applicants (called nominees or nominators) to complete a nomination form that details the project or activity they believe i s worthy of the USMPA award. EPA seeks nominations for the following accomplishments: originalit y and public purpose; leadership and corporate responsibility ; global perspective and implication; actual elimination of ozone
- depleting substance emissions; s uccess 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 o f overexposure to ultraviolet radiation. All nominations must be submitted using the nomination form provided by the USMPA program on its Web site 1 , 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. T his 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.htmlInformation C ollection 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 su bstances, 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 ozone
depleting substances. These organizations and individuals broke down many technical, institutional, and financial barriers, paving the way for the commercialization and standardization of new materia ls, 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 easil y achieved. The USMPA program recognize s outst anding 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 individual s 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 sy stem, cataracts, and damage to marine life and crops, as well as the health and environmental risks of climate change, which include air quality prob lems 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 cov erage 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 E PA use s the collected inf ormation 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 C ollection Request for the U.S. EPA Montreal Protocol Awards Program

3. NON - D UPLICATION, 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 strato spheric ozone layer. Nominees must include their names, contact information, and reference names and contact information , as well as a summary of their contribution s . 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 IC R must solicit public comments for a 60
- day period prior to submitting the I CR to OMB. These comments, if an y, could help EPA refine its burden assumptions or other aspects of the collection prior to submitting the ICR package to OMB for approval
. A cco rdingl y , for this I CR 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 I CR to the Office of Management and Budget. A draft of this Federal Register Notice is available in Appendix A. 3(c) Consu ltations 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 requireme nts 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 indiv iduals may be recognized for their accompli shments , 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 compl y with all regulatory

guidelines under 5 CFR 1320.5(d) (2).Information C ollection 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 man y 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 b y information collection requirements covered under this I CR , by North American Industry Cla ssification System (NAI CS) code, based on a re view of the pool of past award nominee s . This list is intended to be illustrative; entities from other i ndustries may elect to apply to the U.S. EPA Montreal Protocol Awards program
. However, EPA expects that most nomination s will come from the following industries:
E xhibit 4.1 NAICS Codes of Industries that May be A ffected by the USMPA ICR NAICS Code Industry 92 Public Administration 325 Chemical Manufacturing 541 Professional, Scientific and Technical Services 813212 Voluntary Health Organization s 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 appl y, 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 C ollection 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 an y records. The nomination form will be available in electronic form ( Microsoft Word and PDF ) from the USMPA program w eb site. Candidates may submit their nomination s by mail , electronic mail, or fax. The nomination deadline is March 1 st of each year.

(i) Data Items All submissions must include the following items (the first five of which are reported o n 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 USM P A program;  Cover letter ; and  Optional s upporting materials, such as photographs, videos, technical descriptions, news clippin gs, and press releases. (ii) Respondent Activities All respondents must complete these activities to apply for an award:

 Read the no mination instructions;  Provide contact information for the nominee/nominator;  C ontact references to obtain their consent to include their names and contact information on the nomination form;  Write a summary

of accomplishm ents in no more than 600 words;  C r eate supporting materials (optional) ;  Write a cover letter ; and  Submit the nomination via mail, e lectronic mail or fax.
5. THE INFORMATION COLLECTED - AGENCIES ACTIVIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5(a) Agency Activities The Agency

p erforms the following activities associated with processing and maintenance of the U.S. EPA Montreal Protocol Award nomination form :

 M aintain downloadable Microsoft Word and PDF version s of the nomination , with up
- to - date contact information, on the EPA w eb site ;Information C ollection Request for the U.S. EPA Montreal Protocol Awards Program

 Answer questions posed by potential nominee s ;  Receive nomination s and r eview them for completeness and follow up, as necessary , with nominators ;  Review nomination s to select awardees;  Notify

both successful and unsuccessf ul nominees of Agency

dec isions. 5(b) Collection Methodology and Management EPA will provide electronic forms in the Microsoft Word and PDF format s , as well as a hard cop y version if requested, to collect information associated with the USMPA program . Respondents will be able t o download the form from the EPA w eb 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 anal yz ing the information associated with this I CR, EPA will use a telephone s ys tem, personal computers, and applicable software. EPA will ensure the completeness of th e forms by reviewing each submission. Information about award winners will be posted to the U.S. EPA Montreal Protocol Award s w eb site for viewing by the public. EPA has collected award nominations since the inception of the award in 1990. In EPA’s expe rience 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 appropriatel y determine th e 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 t o 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. Nomination s 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 C ollection 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 cate gories. No capital or operations and management costs are incurred b y respondents under this I CR, 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 nominati on f

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

orm was designed to contain straightforward questions. It was also designed in such a way

that one nomination package will serve all ty pes of respondents. For purposes of this I CR, 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 est imate 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
. T he 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, respondent s are entitled to review nominations for future ye ars’ 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. Noneth eless, this cost is estimated here as part of respondent burden. 6(b) Estimating Respondent Costs EPA estimates an hourl y labor rate (base hourly rate plus fringe) of $ 27. 73 for all private industry

workers , based on the Employer Costs for Employee Comp ensation (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

r ate b y 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.pdfInformation C ollection Request for the U.S. EPA Montreal Protocol Awards Program

$ 33.28
. 4 EPA does not expect respondents to incur capital or operating and m aintenance cost s associated with the USMPA program nomination
. The ty pe of staff needed to complete the USMPA nomination f orm and their associated hourl y labor rates , reflected in the “all workers” ECEC categorization, appeared reasonable to the past resp ondents 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 C ontact 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 T otal Burden and Costs In 2008 , 2009 , and 2010, EPA received 37, 43 , and 49 nominations , respectively
. Half of all nominations were submitted b y respondents outside the United States. Assuming a high end of 25 domestic nominations per year, EPA estimates that 75 n omination s 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 , EPA
452
- 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 gu idance.Information C ollection 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 ye ars is 187.5 hours and $ 6,240 , respectivel y. 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 I CR. Other direct costs (copying, printing, telephone, and maili ng 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 Employ ment Statistics , EPA estimates an average hourly labor rate for all o ccupations under NAICS 999100 (Federal Executive Branch, OES Designation) of $34.38. 5 This rate is multiplied by a g overnment overhead (including benefits) factor of 1.6 6 , resulting in an hourly wage rate of $ 55.01
. The total burden hours and cost asso ciated with this information collection over the course of three ye ars is 243 hours and $ 13,368 , respectivel y.

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 C ollection Request for the U.S. EPA Montreal Protocol Awards Program

Exhibit 6. 2 . Agency Burden/Cost Activity No. of Nomination s per Year Estimated

Cost per Hour Person

Hours Total

Annual Cost Maintain downl oadable 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 completenes s 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 6 2.5 $ 2,080 b. Agency

Tall y E xhibit 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 I CR, change in respondent burden is not applicable.Information C ollection Request for the U.S. EPA Montreal Protocol Awards Program 6(g) Burden Statement The annual publ ic 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maint aining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; comple te 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 display s 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 an y 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.r egulations.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., Mon day through Friday , excluding legal holiday s. 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 sy stem, 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 inclu de the EPA Docket ID Number EPA
- HQ
- OAR
- 2010
- 0410 and OMB Control Number 2060
-NEW in any correspondence.