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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 Education 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 (EDGRS) is a recognition award that honors schools, 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 education, 

including STEM, civic skills, and green career pathways.

The award is a tool to encourage state education agencies, stakeholders and higher 

education officials to consider matters of facilities, health and environment 

comprehensively and in coordination with state health, environment and energy

counterparts. In order 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. State 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 types 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 from state authority to 

authority and how they chose to approach the award.
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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. Healthy schools 

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. Sustainability education 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 states’ 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 is any one of the following:

 a Chief State School Officer (CSSO);

 the Department of Defense 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 synthesize their evaluation of the nominee, convert it to a 508 compliant pdf, 

and email it to the Department by February 1st of each year. Honorees are announced 

on April 22nd 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, 
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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 duplication. Show specifically why any similar 

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 Effective environmental education.

Through the award, ED encourages the critical collaborations that ensure all of our 

nation's schools are healthier, safer, and more sustainable. 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 signatory 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.

Templates 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.

To 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:
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 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, schools, and postsecondary institutions that would be associated with 

such on-site verification.

 ED-GRS provides 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 Sustainability

Awardees. Without the collection, the program is unfeasible.

In order that states may nominate candidates annually, ED must collect information

annually for up to six nominees per state. This frequency cannot 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 years;

 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;
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 requiring the use of a statistical data classification that has not been reviewed 

and approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority 

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 agencies for compatible 

confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can 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 basis. 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. Summarize 

public comments received in response to that notice and describe actions taken by the 

agency in response to these comments. Specifically address comments received on 

cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on 

the availability of data, frequency of collection, the clarity of 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 is the same as in prior periods. There may be 

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 Council, Earth Day Network, National Wildlife Federation, state- and 

locally-based initiatives; schools and school communities e.g. private, charter, tribal; 

technical experts e.g. architects and designers, academics, environmental and 
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occupational health specialists; public, e.g. parents, teachers; and other federal 

agencies, including the Department of the Interior, National Oceanic and 

Atmospheric Administration, the Department of Defense, Department of Energy, and 

US Department of Agriculture, among others.

ED also conducts an annual Green Strides Best Practices Tour, during which it visits 

many of 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 payment or gift to respondents, other than 

remuneration of contractors or grantees.

Not applicable. This information collection does not involve payment 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 sensitive 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 of 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. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary 

widely because 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.
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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 estimates 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 be 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 Form 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, so 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 years, 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
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Develop Nomination Authorityspecific application and 

nomination process

30 80 2400 $45.99 $110,376

Solicit applications 30 20 600 $27.31 $16,386

Complete application

Review 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

Review 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

Complete 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 of 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 ranges 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 consult with a sample of respondents 

(fewer than 10), utilize the 60-day pre-OMB submission public comment process and 
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use existing economic or regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

Generally, estimates should not include 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 keep 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 would 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 category to the initial school category. We’ve also learned that about 

30 Nominating Authorities participate each year, 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 analytical 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 year, the press, and the public. The 

Summary of Achievement on the Nominee Presentation Form (attached) requests a 

coherent "snapshot" that describes how the school, district, or postsecondary 
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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 analysis.