1 **SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  U.S. Department of Education Green Ribbon Schools Nominee Presentation Package **A. Justification**  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information. The Elementary

and Secondary

E ducation Act of 1965 authorizes the Secretary of Education (Secretary) to establish national recognition awards to improve academic achievement and community engagement, such as the National Blue Ribbon Schools Program and U.S. Department of Education Green Ribbon Schools. The authorizing statute is Public Law 107
- 110 (January 8 , 2002), section 501, Innovative Programs and Parental Choice Provisions, which created Part D

—Fund for the Improvement of Education, Subpart 1, Sec. 5411(b)(5), of the Elementary and Secondary Education Act of 1965 (20 U.S.C. § 7243(b)(5)). Begun in 2011
- 2012, U.S. Department of Education Green Ribbon Schools (ED

GRS) is a recognition award that honors s chools, districts, and postsecondary institutions that are exemplary in three Pillars: 1) reducing environmental impact and costs, including waste, water, energy use , and alternative transportation; 2) improving the health and wellness of students and staff, including environmental health of premises, nutrition , and fitness; and 3) providing effective sustainability e ducation, including STEM, civic skills , and green career pathways. The award is a tool to encourage state education agencies, stakeholders and higher education offi cials to consider matters of facilities, health and environment comprehensively and in coordination with state health, environment and energy counterparts. Inorder to be selected for federal recognition, schools, districts and postsecondary

institutions must be high achieving in all three of the above Pillars, not just one area. Schools, districts, colleges and universities apply to their state education authorities. S tate authorities can submit up to six nominees to ED, documenting achievement in all three Pillars. This information is used at the Department to select the awardees. ED collects information on nominees from state nominating authorities regarding their schools , districts, and postsecondary nominees
. State agencies are provided sample applications for all three ty pes of nominees for their use and adaptation
. Most states adapt the sample to their state competition
. They use a two -page Nominee Submission Form as a cover sheet. The burden varies greatly f rom state authority

to authority and how they

chose to approach the award.2 The recognition award is part of a U.S. Department of Education (ED) effort to identify and communicate practices that result in improved student engagement, academic achievement, graduation rates, and workforce preparedness, and reinforce federal efforts to increase energy independence and economic security
. Encouraging resource efficient schools, districts, and IHEs allows administrators to dedicate more resources to instruction rather than operational costs. H ealthy s chools and wellness practices ensure that all students learn in an environment conducive to achieving their full potential, free of the health disparities that can aggravate achievement gaps. S ustainability e ducation helps all students engage in hands

- on learning, hone critical thinking skills, learn many disciplines and develop a solid foundation in STEM subjects. It motivates postsecondary students in many disciplines, and especially those underserved in STEM subjects, to persist and graduate with sought after degrees and robust civic skills. So that the Administration can receive state s’ nominations, ED seeks to provide the Nominee Presentation Form to states

– essentially a cover sheet for states’ evaluation of their nominees to ED

– in three versions; one for school nominees, another for district nominees, and a third form for postsecondary nominees
. 2. Indicate how, by

whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. ED requests data from state nominating authorities that have evaluated schools , districts, and postsecondary institutions according to the following categories: 1) reducing environmental impact and costs ; 2) improving health and wellness ; and 3) teaching effective environmental education
. This information will be used at the Department to conduct final review to select the awardees. A nominating authority i s any one of the f

ollowing:

 a Chief State School Officer (CSSO);  the Department of Def ense Education Activity (DoDEA); and  the Bureau of Indian Education (BIE)  State Higher Education Executive Officers Nominating authorities submit according to the Nominee Submission Procedure. They s ynthesize their evaluation of the nominee, convert it to a 508 compliant pdf, and email it to the Department by February 1 st of each ye ar. Honorees are announced on April 22 nd of each year. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of responses,3 and the basis for the decision of adopting this means of collection. Also describe any consideration of using information technology to reduce burden. ED
- GRS receives email service submission only, though many states use online applications to select their nominees
. 4. Describe efforts to identify d uplication. S how specifically why any s imilar information already available cannot be used or modified for use of the purposes described in Item 2 above. ED
- GRS is the first comprehensive and coordinated federal policy in the three institutional roles of schools related to environment, health and education. The award acknowledges the work of schools in reaching high levels of achievement under three areas:
o Reduced environmental impact and costs ; o Improved health and wellness ; and o E ffective environmental education
. Through the award, ED encourages the critical collaborations that ensure all of our nation's schools are healthier, safer, and more sustainab le. ED’s complementary Green Strides initiative uses an annual report, blog, newsletter, social media and tour to facilitate the sharing of best practices and resources. The Green Strides Webinar Series and resources page provide all schools, districts and institutions of higher education free information on the tools that help them move toward the Pillars of the recognition award to follow the footsteps of the ED

- GRS honorees. The award is not tied to any

one program or standard, but instead encourages all schools, districts and institutions of higher education to use all of the many helpful resources available to them. The initiative developed from an 80
- entity s ignatory

request, as well as from ED’s interest in a coordinated, coherent federal policy regarding environment, health and education. It is the first of its kind. T emplates of applications, scoring rubrics and press releases are provided to new states to avoid duplication of efforts on the part of Nominating Authorities
. 5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83

- I), describe any methods used to minimize burden. T o minimize burden , ED has simplified a range of requirements to be addressed in the applications from among the wide range of potential requirements and provided technical assistance to support the information collection request
. These efforts include:4  ED provides sample applications for nominating authorities , should they wish to have model infrastructure on which to base their call for submissions, review and selection of nominees within their jurisdiction.

 Nominating authorities are asked to provide only documentary

assessment, not on- site verification ; this avoids a time

- and

- effort burden on states, districts, school s, and postsecondary institutions that would be associated with such on

- site verification.

 ED
- GRS provide s technical assistance to schools , districts, and postsecondary institutions to support the dissemination of best practices and established metrics through its Green Strides page
.
 ED offers technical assistance calls for participating nominating authorities. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden. If ED cannot collect information regarding the evaluation of schools nominated to ED , it will have no basis for recognizing U.S. Department of Education Green Ribbon Schools , District Sustainability Awardees, and Postsecondary S ustainability Awardees
. Without the collection , the program is unfeasible. In order that states may

nominate candidates annually, ED must collect information annually f or up to six nominees per state. This frequency c annot be reduced, although submission is totally voluntary

and some states choose to submit fewer nominees . ED expects to continue to make awards annually
. 7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, grant- in

- aid, or tax records for more than three ye ars;

 in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;5  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;

 that includes a pledge of confidentiality that is not supported by a uthority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily

impedes sharing of data with other agenc ies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency c an demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law. Not applicable. There are no special circumstances for this collection. Respondents submit information on a voluntary b asis. Respondents are not required to retain records or submit statistical or confidential information or proprietary trade secrets. 8. If applicable, provide a copy and identify

the date and page number of publication in the Federal Register of the agency ’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. S ummarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. S pecifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability

o f data, frequency

o f collection, the clarity o f instruction and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years
– even if the collection of information activity i s the same as in prior periods. There may b e circumstances that may preclude consultation in a specific situation. These circumstances should be explained. ED received significant public and federal agency input on the substance of the award
. It has adapted the award based on input following each of the first three years . The ED
- GRS team has consulted with and heard from the major education associations e.g. teachers, principals, school boards; states, e . g . chief state science officers and existing state green schools programs; national NGOs e.g. US Green Building C ouncil , Earth Day Network, National Wildlife F ederation , state - and locally

-based initiatives; schools and school communities e.g. private, charter, tribal; technical experts e.g. architects and designers, academics, environmental and6 occupational health specialists ; public, e.g. parents, teachers; and other federal agencies, including the Department of the Interior, National O ceanic and Atmospheric Administration , the D epartment of Defense , D epartment of Energy, and US D epartment of Agriculture , among others
. ED also conducts an annual Green Strides Best Practices Tour, during which it visits many o f these honorees and receives input from states, districts, schools, stakeholders, and postsecondary institutions
. From the feedback ED has received , interest is high for this recognition award to continue. Notices for the 60 day

and 30 day

comment period will be published. 9. Explain any

decision to provide any p ay ment or gift to respondents, other than remuneration of contractors or grantees. Not applicable. This information collection does not involve pay ment or gifts of any kind. 10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy
. Not applicable. Confidential information will not be collected. 11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent. Not applicable. This information collection will not include s ensitive and/or private questions. 12. Provide estimates of the hour burden of the collection of information. The statement should : Indicate the number of respondents, frequency o f response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. C onsultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely b ecause of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.7 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in item 13 of OMB Form 83

- I. Provide e stimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not b e included here. Instead, this cost should not be included in Item 14. **Annual Burden Hours** The burden is on two sectors: 1) the Nominating Authorities and 2) the applicants (schools, districts, and postsecondary institutions) . The activities they will conduct are described below, the estimated burdens for each provided separately, and the total burden then presented. The Nominating Authorities will develop their state

- specific (or comparable authority

- specific, etc.) application and nomination process, solicit applications, review applications, select nominees and submit documentation of evaluation of the nominees , along with a Nominee Presentation F orm to ED. The schools , districts, and postsecondary

institutions will review the state - specific application form, collect information to complete the form , and complete and submit documentation to the Nominating Authority. Nearly all states adapt the sample application and are not creating their application from the ground up, but rather adapting a template. ED does not require a standardized application from all Nominating Authorities because state education agencies needed some flexibility on their evaluation of nominees to ED. For this reason, s o long as state education authorities document evaluation in all three Pillars and all ten Elements of the award, ED does not mandate state applications look a certain way . States have appreciated the flexibility and adapted their award to local needs. Furthermore, there is nothing in our criteria that requires them to run a competition with application process, though nearly all are selecting nominees to ED through a competition that requires some sort of application
. In the past three ye ars, roughly 30 states have participated, so we have reduced the burden estimates in the pilot year, when we assumed that all would choose to do so
. The number of applicants to states is roughly 10 . ED has also included in its estimate the work of those who will review the application in depth and decide not to apply
.

**Annual Hour Burden on Nominating Authorities Processing Step**  **Responses Hours**  **Per Step**  **Annual Hours**  **Cost/**

**Hour Annual** 

**Cost**8

Develop Nomination Authority

specific application and nomination process 30 80 2400 $45.99 $110 , 376 Solicit applications 30 20 600 $27.31 $16 , 386 Com plete application Revie w applications from schools, districts and postsecondary institutions 30 300 25

0.25 750

75 $27.31 $27.31 $ 20,482

$ 2,048
Select nominees 30 6 180 $45.99 $ 8,278 Submit nominees to ED 30 2 60 $32.73 $ 1,963 **Totals 330**  **4,065 $159**  **, 533**  **Averages 110**  **1,355 $53,177**  **Processing Step Responses**  **Hours Per**  **Step Annual**  **Hours Cost/** 

**Hour Annual** 

**Cost** Revie w nomination form 2,000 2 4,000 $45.99 $183,960 Collect information to complete the form 1,000 6 6,000 $32.73 $196,380
Com plete and submit form to Nominating Authority 1,000 4 4,000 $45.99 $183,960 **Totals 4,000**  **14,000 $748,260**  **Averages 1,333**  **4,666 $249,420**  **Annual Total and Average Burden** Total burden on Nominating Authorities **330 4,065**  **$159,533** Total burden on schools **4,000 14,000**  **$748,260 Total burden**  **4,330 18,065**  **$907,793 Average burden**  **1,443 6,021**  **$302,597** 13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.) The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions o f methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities. If cost estimates are expected to vary widely, agencies should present range s of cost burdens and explain the reasons for the variance. The cost of contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may c onsult with a sample of respondents (fewer than 10), utilize the 60
- day pre - OMB submission public comment process and9 use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate. Generally, estimates should not inc lude purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or ke ep records for the government, or (4) as part of customary

and usual business or private practices. Total Annualized Capital/Startup Cost : $ .00 Total Annual Costs (O&M) : $ .00 Total Annualized Costs Requested : $ .00 See cost burden in item 13 table. 14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that woul d not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. There is limited federal start-up or maintenance cost to this collection of information
. The program budget is under $20,000 and only has one FTE. 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83

- I. The award is now going into its third cycle. We have added a district and a postsecondary

c ategory to the initial school category
. We’ve also learned that about 30 Nominating Authorities participate each ye ar, receiving roughly 300 applications in total among them. ED generally receives less than 100 nominees. This results in an adjustment in burden and responses of 330 responses and 18,065 hours respectively. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. Summaries of each of the honorees are detailed in an annual Highlights Report
. This is shared with other schools, candidates for next ye ar, the press, and the public. The Summary o f Achievement on the Nominee Presentation Form (attached) requests a coherent "snapshot" that describes how the school, district , or postsecondary10 institution is representative of the nominating authority ’s highest achieving green school efforts. 16. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. Not applicable. The OMB control number, expiration date , and related information will be displayed on the Nomination Presentation Form
. 17. Explain each exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83

- I. Not applicable. No exceptions are requested for this submission. **B. Collection of Information Employing Statistical Methods** 

Not applicable. The information collected will not employ statistical methods for gathering or analys is.