ED Encourages Public Comment on Plans for Green Ribbon Schools Award

The online comment period for Green Ribbon Schools is now closed. Stay tuned for program details to be announced online shortly.


ED is asking for public comment on proposed plans for the new U.S. Department of Education Green Ribbon Schools recognition program. The Department, along with the Environmental Protection Agency and the White House Council on Environmental Quality announced their intention to create the Green Ribbon award on April 26, 2011. Beginning today, ED will accept comments until September 14 and will publish the final program details by the end of the month.

The U.S. Department of Education Green Ribbon Schools will recognize schools that save energy, reduce costs, and feature environmentally sustainable learning spaces, as well as protect health, foster wellness and impart effective environmental education.  The award program will bring together three institutional roles of schools related to environment and health as it acknowledges high levels of achievement in three categories:  1) environmental impact and energy efficiency; 2) healthy environment; and 3) environmental literacy.  Put another way, the award will consider:

  • schools’ and their occupants’ impact on the environment;
  • schools’ environmental and behavioral impact on the students, teachers and others in the facility; and
  • how schools teach students about the environment and sustainability to better prepare them for citizenship and employment in the 21st century.

The proposed plan for the Green Ribbon award was developed with input from a variety of federal, state and local government agencies and a variety of other stakeholders.

Please see our Facebook page, where ED highlights resources that may be useful to schools and other participating authorities in their efforts toward Green Ribbon status: http://www.facebook.com/EDGreenRibbonSchools.

Recognition Award Criteria and Selection Infrastructure for Comment:

Proposed recognition award eligibility requirements, selection criteria and a framework to assist education authorities in soliciting, evaluating and nominating schools to ED are posted below for public comment. Proposed plans will also receive comment through standard Federal Register procedures.  We look forward to hearing from you.

The Fine Print:

This is a moderated site. That means all comments will be reviewed before posting. We intend to post all responsive submissions on a timely basis. We reserve the right not to post comments that are unrelated to this request, are inconsistent with ED’s Web site policies, are advertisements or endorsements, or are otherwise inappropriate. To protect your own privacy and the privacy of others, please do not include personally identifiable information such as Social Security numbers, addresses, phone numbers or email addresses in the body of your comment. For more information, please be sure to read the “comments policy” tab at the top of the Web page.

Please understand that posts must be related to the Green Ribbon Schools recognition award, and should be as specific as possible, and, as appropriate, supported by data and relevant research. Posts must be limited to 1,000 words. All opinions, ideas, suggestions and comments are considered informal input. ED will not respond to individual posts, and these posts may or may not be reflected in the policies and requirements of the program. If you include a link to additional information in your post, we urge you to ensure that the linked-to information is accessible to all individuals, including individuals with disabilities. Additionally, please do not include links to advertisements or endorsements; we will delete all such links before your comment is posted.

54 Comments

  1. Congratulations on developing a well thought out framework. I am particularly appreciative of the inclusion of civic engagement in the third pillar. Environmental literacy must include an understanding of systems – Earth’s physical systems, the living environment, and human systems (cultural, political, economic, social). It is also essential that students are provided opportunities to develop civic engagement skills so that they might make informed decisions about the environment and sustainability.

    With this in mind, please consider including the following in your list of resources: Excellence in Environmental Education: Guidelines for Learning (K-12) (published by the North American Association for Environmental Education) [http://eelinked.naaee.net/n/guidelines/topics/Excellence-in-EE-Guidelines-for-Learning-K-12]. These guidelines provide teachers and other educators a knowledge and skill framework, benchmarked at 4th, 8th and 12th grade, that leads towards environmental literacy.

  2. Congratulations on the development of this exciting program. I agree with the comments to include Project Learning Tree as a key resource. In New Mexico, we provide PLT trainings and PLT’s Green Schools program to our schools because they offer a comprehensive approach to greening schools by education and action. The inclusion of outdoor classrooms into the third pillar is an excellent revision to the program as presented. Outdoor classrooms, habitats and gardens offer teachers a way to engage their students outside to teach about the environment without leaving school. Thank you for the opportunity to comment and for creating the Green Ribbon Schools Award.

  3. As a 501 (c)(3) whose mission is to accelerate the adoption of building practices that result in energy-efficient, healthier and environmentally sustainable buildings the Green Building Initiative (GBI) is excited to see the Department awarding schools that save energy, reduce costs, and feature environmentally sustainable learning spaces, as well as protect health, foster wellness and impart effective environmental education.

    The Green Building Initiative encourages the department, when developing the final language for the program to recognize all third party assessment tools including Green Globes.

    Green Globes is a viable, nationally accepted green rating/assessment/certification system that has proven itself for K-12 and higher education institutions and should be included by name in the Program’s language.

    Green Globes was accepted in the Dept of Ed Green Schools language for the ARRA section of the program. In addition to being recognized in federal law, 23 states have incorporated Green Globes in law including: Arkansas, Connecticut, Florida, Hawaii, Illinois, Indiana, Kentucky, Minnesota, Missouri, Nevada, New Jersey, New York, North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Virginia and Wisconsin.

    Green Globes is the first and only green building rating system for commercial buildings that is an ANSI standard. Our new construction and existing building tools have been successfully used on numerous schools to help them to achieve sustainable design and operation.

    Thank you for the Department of Education’s past support and we hope that GBI’s Green Globes tools will be mentioned by name in the Green Ribbon Program language.

  4. AWC applauds the Department for recognizing schools that improve building environments and health for students and teachers. Wood is an essential product used in the construction of schools, and AWC strongly believe that our products provide environmentally superior performance to support a healthy environment. Wood is produced naturally using energy from the sun, and is the only major building material that comes from a renewable resource. Life cycle assessment (LCA) studies consistently show that wood is better for the environment than fossil fuel-intensive materials such as steel or concrete in terms of embodied energy, air and water pollution, and other environmental impact categories.

    Wood also lowers a building’s carbon footprint through the storage of carbon absorbed during the tree’s growing cycle, keeping it out of the atmosphere for the lifetime of the building – longer if the wood is reclaimed and manufactured into other products – and using wood instead of materials whose production requires large amounts of fossil fuel-based energy reduces greenhouse gas emissions during manufacturing. For these reasons, the use of wood from responsibly managed North American forests should be encouraged.

    School districts are also embracing the light carbon footprint of wood buildings. For example, wood products in the new El Dorado (Arkansas) High School store an estimated 3,660 metric tons of carbon dioxide equivalent (CO2e) – which trees absorbed from the atmosphere during their growing cycle. By using wood instead of steel or concrete, which require large amounts of fossil fuel energy to manufacture, the school avoided another 7,780 metric tons of CO2e. Based on the EPA Greenhouse Gas Equivalencies Calculator, this equates to the annual emissions from more than 2,100 cars.

    Unfortunately, the Department of Education’s proposed exclusive use of the U.S. Green Building Council’s (USGBC’s) Leadership in Energy and Environmental Design (LEED) rating system discourages the use of wood products, sending a negative message to the marketplace about the use of wood in green schools. Instead, to obtain the best environmentally-supportive schools, the Department of Education should encourage the use of other national building rating systems. In fact, one might expect that by encouraging competition between them, greater improvement will result. Accordingly, the U.S. government should support open competition for green building certification, favor rating systems (standards) developed through ANSI-approved procedures, and importantly encourage the use of green building programs or standards that recognize all credible forest certification systems, including the American Tree Farm System and Sustainable Forestry Initiative. Otherwise, rating systems such as LEED will result in procurement policies that discriminate against comparable forest certification systems and the environmentally-superior wood products that come from them.

  5. Thank you for the opportunity to comment on the Green Ribbon Schools draft materials. Since the first announcement of this important new program in April, and the several conference calls in the spring to shape its direction, I believe the Department of Education has made significant progress in establishing a program that will help promote the goal of environmentally sustainable schools. Congratulations!

    I have two suggestions. First, as a former, long-term school principal, I spent last year visiting environmentally sustainable schools across the country, and I believe there are many that would qualify for recognition in the pilot program for their excellence in all three areas. Consequently, I believe that all schools recognized now and in the future should meet the eligibility criteria in each and all of the three pillars—energy, healthy facilities, and environmental education. The Green Ribbon Schools should set a high national standard for environmentally sustainable schools. Second, I believe the Green Ribbon Schools program has the potential to promote the development of state-level recognition programs, thereby fostering the growth of a national recognition network in all fifty states. Therefore, I suggest that under the Eligibility section the language be modified to the following: “The Department encourages the authorities to develop or refine….”

    Thanks for the leadership in developing the Green Ribbon Schools, and good look in launching this program!

  6. I am very excited about the Green Ribbon Schools initiative!

    I hope that there would be a very strong emphasis on Air quality – both indoor and outdoor. A fume free policy – VOC free paints, no smelly markers or pens, no smelly air fresheners – (many have formaldehyde as a preservative) and no buses or cars idling.

    Green roofs can creat clean air as well as slw down storm water and save energy.

    Food Scrap composting – while students are learnig about zero waste they can learn about creating healthy soil amendments from food scraps. Then the compost can be added to their science based vegatable gardens.

    The whole atmosphere should be about sustainability – saving resources and preventing pollution.

    Everyone in the school – including school board members, maintance staff, parents, students, volunteers, teachersand prinicpals should be included in the Sustainability efforts and know the Green Goals.

    Sustainability should be incorporated into the students lessons – history, science, math, problem solving and reading throughout the school year.

    Pride will grow from the actions taken to create a Green Ribbon School and that pride can carry on with a child well into the future!

    Earth Day can not just be about 1 day – it should be understood that actions taken today will have an effect on our future days – so taking Sustainable actions every day is what we need.

    I am eager to see the final result.

  7. The American Forest & Paper Association (AF&PA) applauds the Department for awarding schools that achieve improvements in the building environment and health of students and teachers. Wood and paper are essential products used in schools – and the members of AF&PA strongly believe that our products provide environmentally superior products to support a healthy environment.

    As such, we were dismayed to review the Green Practices proposed by the Department in support of the Green Ribbons program, which discriminate against wood and paper produced by companies in the United States. In addition, several of the proposed Green Practices are not best practices when compared to wood and paper.

    The following are areas under the Environmental Impact and Energy Efficiency Pillar where we believe that the Green Practices can be improved to provide the most environmentally beneficial products and practices to be used in our schools.

    I. Reduced Greenhouse Gas Emissions — Requirement for use of LEED

    The LEED rating system provides a specific credit only for forest products that have been certified by the Forest Stewardship Council (FSC). The FSC standard initially was developed by international environmental groups to combat tropical deforestation. LEED currently provides no credits for wood products produced by companies independently third-party certified to the Sustainable Forestry Initiative® (SFI) Program standard or the American Tree Farm System® (ATFS) –two of the largest sustainable forest management systems in the U.S. These two programs account for over 75% of all certified lands in the U.S., yet do not qualify for points under the LEED rating system.

    AF&PA believes competition among forest certification systems drives continuous improvement in the systems and reduces costs for users. Governments should encourage competition between building rating systems. The U.S. Government should not interfere with certified forest product markets by adopting procurement policies that discriminate against comparable certification systems. That means that government should favor rating systems developed through ANSI-approved procedures, where available, and support open competition for green building certification. The government should encourage the use of green building programs or standards that recognize all credible forest certification systems, (including the American Tree Farm System — which is geared toward small family forest landowners — and the Sustainable Forestry Initiative).

    II. Reduced solid waste production — Paper procurement:

    The Department of Education has chosen parameters regarding procurement of paper intended to reduce waste generation. However, none of the practices will achieve the Department’s goals.

    1. Post-consumer material: Establishing a distinction between pre- and post-consumer fibers does not contribute either to increased recycling or reduced consumption. The distinction is an artifact from the mid-1980’s to encourage greater community recycling — when the rate of recycling paper was in the 30 percent range (today it is greater than 63 percent). The distinction is no longer meaningful. First, recycling is clearly a part of the American psyche and we do not need to encourage one type of material to be used rather than another. Second, there are categories of paper that are diverted from the waste stream but that are excluded from the narrow definition of post-consumer. For example, over-runs of magazines or catalogs that have never reached a consumer (i.e. they were never purchased or delivered) would not qualify as post-consumer material, according to the definition.

    If the post-consumer distinction of recovered materials must be included, we propose you adopt the ISO 14021 “Environmental Labels and Declarations: Self-declared Environmental Claims (Type II Environmental Labeling)” definition. The ISO 14021 provides a well-established, highly credible definition of post-consumer material as follows:

    “Post-consumer material – materials generated by households or by commercial, industrial and institutional facilities in their role as end-users of the goods or service which can no longer be used for its intended purpose. This includes returns of material from the distribution chain.”

    2. Tree-free fiber: Categorically preferring paper made from materials that do not originate from trees is not an environmentally appropriate practice. The determination whether non-tree-based fiber as the basis for paper is more appropriate from an environmental perspective requires analysis through the use of Life Cycle Assessments and Analysis. Examples of issues that must be evaluated are:

    • How are the fibers generated?
    • Are the rows tilled or managed using mechanisms that reduce the generation of GHG emissions?
    • What is the comparison of GHG sequestration of trees versus other crops?
    • What are the chemicals used in production and how are they managed (are they recycled?)
    • If demand for tree-based fibers were diminished, would the acreage used for tree growth remain as timber or would it be sold for development?
    • Are the same use and recycling specifications available from tree-free paper as from tree-based paper?

    AF&PA believes that when compared, tree-based paper will be environmentally superior in many, if not most, cases.

    In addition, tree-free fiber cannot be recycled with tree-based fiber. Therefore, paper made from such materials would be excluded from collection in traditional recycling programs and the schools would need to find unique opportunities to arrange for them to be recycled.

    3. FSC Requirement: As noted above, 75% of the timberland in the United States is managed under the SFI Program and the ATFS program. With only 10% of the world’s forests certified, all credible certification standards should be accepted. We suggest that the Green Practices be expanded to seek fiber from forests certified under credible sustainable forestry certification programs including the Sustainable Forestry Initiative® (SFI) Program standard, the American Tree Farm System® (ATFS), Forest Stewardship Council (FSC), and the Programme for the Endorsement of Forest Certification (PEFC).

    4. TCF and PCF: Wood fiber used in papermaking is versatile enough to allow production of paper products that meet a wide range of needs. It also contains a substance called lignin, which can cause paper to turn yellow. There are several bleaching processes, such as Elemental Chlorine Free (ECF) or Totally Chlorine Free (TCF) that are used to remove lignin and are necessary for paper products requiring whiteness, brightness, softness, and printability. Similarly for recovered fibers, brightening is needed to meet product standards. There also are several brightening processes, including Process Chlorine Free (PCF), in which no chlorine compounds are used in the manufacturing of the recycled content paper (although it is impossible to determine whether the recycled fibers were originally bleached using such compounds).

    Totally Chlorine-Free bleaching use is minimal, if at all, in the United States for a variety of environmental and economic reasons and is used by only a handful of non-U.S. manufacturers. As such, this requirement would exclude the vast majority of printing paper producers. ECF – Elemental Chlorine-Free – which is used by most mills — is recognized as “Best Available Technology” by the U.S. Environmental Protection Agency and the European Commission. Because EPA has stated that elemental chlorine free virtually eliminates chemicals of significant concern, we believe that requiring TCF is not appropriate. Instead, we suggest the following Green Practice relative to bleaching:

    “No elemental chlorine is used during processing office paper and the use of chlorine derivatives is minimized.”

    Thank you for the opportunity to review the draft materials defining the U.S. Department of Education’s Green Ribbon Schools program. We would be pleased to discuss these issues with you in further detail.

  8. We are happy and encouraged to see that the Department of Education has initiated the Green Ribbon Schools Award program. The state of Maryland has already made it a requirement to incorporate environmental literacy into its curriculum. We hope that GRS will encourage other states to do the same. Although this is the first year and pilot, we hope that DoE will continue to include and incorporate the community’s feedback as the program develop.

    •Ensure GRS uses health and justice – driven criteria, supported by science
    GRS introductory materials should embed the children’s environmental health and justice information and messages in its Introductory and other materials.

    •All schools eligible must meet required criteria in all three pillars (energy, healthy facilities, environmental education), not just one, as presently proposed. No awards for fulfilling just one pillar. (After the pilot year, should be taken into consideration.)
    ED, and EPA particularly, should not be put in the position of giving awards to schools that have, for example, saved energy, but still allow smoking indoors, or routinely spray pesticides.
    •Comment period too short. The comment period should be extended for an additional 20 days.

    Thank you for giving the public the ability to make comments .

  9. Pillar #1 should include composting efforts, as the cafeteria produces far and away the most trash in many schools. Efforts to replace styrofoam trays with compostable trays, coupled with composting bins/gardens on school grounds, are fantastic efforts that should be recognized. We need to go beyond recycling.

  10. The Green Ribbon School initiative is great. I think the Environmental and Sustainability Education should include the mention of Sustainable Design. Art and Design are an important part of our designed environment from creative innovations in product design, landscape and building design systems as well as aesthetics. Design that is efficient as well as aesthetically pleasing is important in the whole process from cradle to grave. Good communication, graphic design, photography and video are important in making the behavior changes needed for energy reduction, recycling etc. Effective posters, signage, and video do a lot of the heavy lifting in motivating and changing people’s behavior. They also help communicate good practices and success in the larger community. Therefore the Arts need to be included specifically as well as sciences in an effective interdisciplinary Environmental and Sustainability Education.

  11. We are excited that the Green Ribbon Schools Recognition Program includes a healthy school environment component. NC Prevention Partners has been helping improve school wellness environments for the past 8 years with our Zone Health School Obesity Program. Our experience with schools has shown us that they need access to tools, resources, and model policies to make effective changes. In addition, we need to provide useful tools that are evidence-based so they are doing what is known to be most effective. To this end, we have developed our own recognition program that rewards school and districts for their efforts in improving nutrition standards and physical activity opportunities. Schools access our resources through web-based assessments and webinars and answer questions that are aligned with the School Level Impact Measures (SLIMs), CDC’s monitoring set for comprehensive school health. One of the principle changes that schools are guided toward is promoting more active modes of transportation to school. We know this is an effective way of increasing physical activity in youth and there are many national resources to help implement it. Your recognition program aligns with our program goals and allows us to co- celebrate their success in providing a healthy food environment and getting students active during the school day. We also applaud your inclusion of staff wellness in your criteria for recognition. In the past 3 years, we have offered additional resources to schools through our WorkHealthy America program to drive policy, benefit, and environmental changes in nutrition, physical activity, and tobacco practices/policies to support school employees. All of these efforts, including your Green Ribbon Recognition certificate, acknowledge that changing the school environment is a crucial first step in guaranteeing the health of our population and planet.

  12. The Green Ribbon Schools Program sounds like a great vehicle to increase the visibility of the excellent work schools do with programs like PLT (Project Learning Tree) and Greenschools! I am a teacher at a small independent school and recently my sixth graders adopted trees with the K5 class. It was so cool to see the middle schoolers guide the smaller students. Today in English class, they will be researching the tree species they adopted and then blogging about their tree experience by recording what happened, sharing their research, and finally reflecting on memories they have with trees.
    I love how nature based inquiry and collaboration in outdoor classroom spaces or on environmental service learning projects can bring students of all ages together. It also facilitates teacher collaboration. The benefits of using PLT and the GreenSchools! at our school has made a positive impact on my classroom, my professional life, and my personal life. (I just ordered about 20 trees from the Arbor Day Foundation!) :)
    Anyway, I hope that the Green Ribbon Schools Program gets the support it deserves. It doesn’t cost any money to take kids outside and show them all the amazing and interdisciplinary connections that can be made.

  13. ED-GRS is an excellent idea, and the particular details are also excellent, there should be more programs like this. Big question is how do teachers get involved in the drafting of such programs in the first place, or in the actual particular improvements that will make such programs better? This comments section does not seem like the place to offer very specific ideas for improvements to help all do a better job of environmental stewardship.

  14. I agree with Gary’s comment on 9/6 that the ED will consider Green Ribbon applications on behalf of school districts. There are entire school districts which have embraced the pillars outlined in the proposal and so it would be a disservice to ask them to limit their application to one school. Creating a category for School Districts would increase the number of potential applicants.

  15. September 14, 2011
    Green Ribbon Schools Program
    U.S. Department of Education
    Washington DC

    Solicited Comments on the
    Green Ribbon Schools Program
    First Public Review Draft Documents
    Dated September 1, 2011

    Thank you for the opportunity to provide comments on the first public draft of Green Ribbon Schools Program documents. The Green Ribbon Schools Program will drive K-12 school excellence in environmental health, environmental literacy, and environmental sustainability for decades to come. It is understood this draft is offered prior to official Federal Register publication; that comments are limited to 1000 words and that a formal public comment period is customary following Federal Register publication. More detailed comments with revised draft language are provided through hyperlink at the bottom of this page.

    COMMENTS

    1) Statements in the draft can be understood to focus on STEM curriculum only and exclude the liberal arts, fine arts, social sciences, and all other courses of study of which students may benefit from aspects of environmental literacy and sustainability education.

    2) The globally recognized “sustainability triangle” is not limited to hard sciences but ascribes equal status to social responsibility and economics. Each core element of sustainability prepares students to compete in a global workforce although two of the three elements of sustainability are not mentioned in the draft.

    3) The draft requires a nominating authority which nominates more than one school to nominate at least one school with at least 40 percent of students from disadvantaged background. An unintended consequence of this may be to force nominating authorities to set aside higher achieving schools for a lower performing school due to the school’s disadvantaged status. A more equitable approach may be to require nominating authorities to nominate at least one school with at least 40 percent of their students from a disadvantaged background with each application package. This alternate approach would establish an emphasis for disadvantaged schools, provide more access to disadvantaged schools and eliminate the draft requirement that under certain circumstance nominating authorities overlook higher environmentally performing schools for lower performing disadvantaged schools.

    4) Green Ribbon Schools is a school specific recognition. However, many aspects of the program are school district or state controlled, not school controlled. A clarification statement should be included that aspects of the program in some cases may be district or state driven so as not to discourage individual schools from applying because of reliance on state or district controlled aspects.

    5) Pillar two language is focused on school district controlled operations policy such as school design, O&M, and grounds which are not school controlled. Pillar two omits “occupant practices” which are paramount to healthy schools and most often under school control.

    6) The Department defers to sources outside the Department for expertise in the three pillars of this schools program. Although agencies external to the Department have certain technical expertise, the Department should accept responsibility to synthesize such technical expertise into application practice models applicable to schools nationwide. The United States would be better served by the Department hiring uniquely qualified and dedicated staff who understand the dynamics of school operations, environmental education and sustainability theory as well as the challenges of practical application at the school and school district levels. This is necessary to generate maximum fiscal, educational or environmental returns to the Nation.

    7) The draft proposed recognition ceremony to be hosted in DC for winning schools is one example that may illustrate the Green Ribbon Program has yet to adopt an internal model of sustainability practice. Bringing school delegations to DC will create a tremendous carbon and greenhouse gas footprint attributable solely to the Green Ribbon program. A more sustainable approach could be hosting an internet recognition event where dignitaries speak, winning school slides stream allowing entire schools to participate in the ceremony via internet. This model would reach more citizens with less resource consumption leading toward the Green Ribbon School Program’s stated “net zero” environmental impact goal.

    8) Playgrounds show the highest student injury rate of any elementary school fixture, are a major facet of the outdoor learning environment though are omitted from the draft. Outdoor activity is featured within the framework but no mention of compliance with public playground safety standards ASTM 1487 or CPSC 325.

    9) Use of green cleaning products does not constitute green cleaning. Criteria should also include use of green cleaning policies, procedures and equipment.

    10) Schools that achieve energy star certification have been recognized nationally for that accomplishment and did not have to be green to achieve this status. Energy star certification and or a reduction of energy over baseline of 20% is an excellent pre-requisite but should not in and of itself make schools eligible for Green Ribbon recognition. Energy efficiency may often be accomplished as a matter of budget requirement without intentional environmental benevolence or occupant health concern and does not constitute green. Schools should at minimum in the pilot year achieve at least two of the three program pillars.

    11) Schools should certify compliance with all applicable environmental, occupational safety and health, school sanitation and fire codes. Absence of notice of violation would validate in terms of environmental and occupational. Annual inspection reports would validate in terms of school sanitation and fire codes. Can a school be green that violates storm water requirements for rain gardens, safety guidelines for art staff or fire code requirement prohibiting the storage of petroleum fuels in school air conditioning mechanical rooms? These standards fall within the Department’s human interaction stipulation.

    12) The Coalition for Healthy Schools comments are fully endorsed most notably that the Department would benefit from formal open advisory panel of experts recognized in the practice of Green Ribbon Pillars in schools.

    In closing, as the Green Ribbon School Program develops the Department will be recognized internationally as the authority for establishing national school environmental performance benchmarks, standards and metrics related to practices proven to result in improved student performance and engagement. To this end the Department should endeavor to publish practical guidance on their implementation.

    With Respect
    Submitted Electronically,
    Brian K Kasher

  16. I applaud the effort. We are moving in the right direction. I echo so much of what is already posted. However, I would like to see us go even further to encourage true sustainability in the three pillars and beyond. Could there be a star system so 5 stars is the best? or a phased approach where you receive a Green Ribbon if you meet one of the 3 criteria but then must achieve the next pillar within 3 year to receive the Ribbon again. This would encourage constant reflection and improvement toward integrated sustainability across facilities (indoor and outdoor), management, and curriculum so that we are honoring “real” movement toward sustainability. At the moment it seems that the Green Ribbon doesn’t go far enough. Should it be something that is sought after and worked towards? Not just given away for effort that doesn’t really hit the bigger goal.

  17. I would like to see more attention paid to campus trees and student gardening. Both can encourage students/staff to spend more time pursuing activities that improve individual physical, group social health and environmental health.

  18. We commend the Department for initiating the Green Ribbon Schools recognition program and also for including environmental education in your Blueprint for Reform of the Elementary and Secondary Education Act.

    We believe that the program criteria for Green Ribbon Schools should not recognize schools just for their efforts to “save energy, reduce costs, protect health and exemplify environmentally sustainable learning spaces” or environmental “educational programs that boost academic achievement and community engagement.” But rather, it should honor schools that do both and integrate the environment and energy into the curricula.

    Research shows that when the environment is used as an integrating context for learning, student achievement increases across core subjects, while disciplinary problems and absenteeism go down. Increasing environmental literacy is a proven way to expand the academic pipeline for STEM subjects and is increasingly seen as an innovative way to give students the sense of wonder and excitement so essential to encouraging scientific inquiry. What’s more, getting children outside to learn promotes a healthy lifestyle that is essential to fighting obesity and reducing symptoms associated with attention deficit disorder, depression, and stress.

    The more than 50 million citizens who comprise the No Child Left Inside Coalition are unified in our efforts to ensure that the reauthorized Elementary an\d Secondary Education Act includes opportunities for rigorous, high quality environmental education to be embedded throughout the curriculum, as an essential component to preparing college and career-ready high school graduates.

  19. The Green Ribbon program is a step in the right direction! I’m excited to see the Department of Education take a leadership role in promoting environmental education in the classroom. Environmental education not only prepares our students to respond to today’s natural resource issues, it also is proven to improve student performance in key areas like science, math, technology, and engineering.

    I was happy to see Project Learning Tree listed as one of your resources, and I’d encourage you to denote it as a key resource in your metrics, as you do the U.S. Green Building Council’s Green Schools program. PLT has been educating 75 million students since its founding and should be a key resource for schools looking for recognition in the Green Ribbon Schools Recognition program. I’d also urge you to take a look at PLT’s GreenSchools! program as another key resource. Now in over 1000 schools nationwide, it gives schools and teachers the tools to, not only educate their kids, but do it in a hands-on way, with resources for actually improving the school’s environmental performance.

    To strengthen the program, I would encourage you to be sure that education needs are met, in addition to school environmental performance needs. To be a Green Ribbon School, schools should be required to use curricula that align with state and national standards. I also noticed a bias towards high school and college and career ready standards, whereas, Green Ribbon Schools should be incorporating environmental education into every grade.

    All-in-all, this is a good step forward toward recognizing the schools that already go above and beyond to include environmental education and encouraging other schools to do the same.

  20. The Programs promotion of “tree free fiber” and the sole recognition of the Forest Stewardship Council’s forest certification and the LEED green building rating system should all be removed from the “Green Practices” list. All of these standards and practices discourage the use of forest products—especially US forest products. Science from the United States Forest Service, demonstrates that forest products are a renewable, sustainable material, the use of which can help reduce greenhouse gas emissions, water pollution, and energy use. Trees are the most environmentally friendly natural resource available and we should recognize and encourage it’s value in “greening” America through its use rather than using more environmentally “unfriendly” building materials that are non-renewable and unsustainable.

  21. Thank you for your efforts in creating a Green Ribbon Schools Award. There are many great components to the pillars listed. I too noticed the omission of the outdoor environment and would like to suggest that this be a more prominent component of recognizing a green school.
    A school is the heart of the community, a place where future generations learn, work and play. The new “Green School” movement around the nation has brought enthusiasm and concerted efforts into making schools healthier and safer, and reducing their negative environmental footprint. However, few of these programs address the lurking challenge: the outside environment. School landscapes have been largely overlooked as an environmental and educational resource even though they may make up 68% of the 10-50 acres most schools are sited on. The reality is that many such “landscapes” are actually the cause of “environmental damage”. Often they are dominated by paved surfaces and other highly-compacted areas that have become nearly-impermeable to rain. They tend to be highly managed through mowing, watering, and applications of fertilizer or herbicides. Research shows that tree canopy and course vegetation covers less than 10% of the school landscape. This percentage is insufficient to provide eco-services or social and physiological benefits; birds and beneficial insects find little habitat and students have few learning opportunities. Most schoolyards leave little to the imaginative whimsy that can inspire young environmental thinkers and stewards.
    Though children spend nearly a third of their day on school property, research shows that schoolyards dominated by concrete and turf don’t support healthy, physical, and emotional development. Schoolyards can and should provide large quantities of greenspace and green infrastructure sufficient to achieve healthy benefits, such as increased concentration, reduced stress, lower vandalism, and increase test scores.
    I would suggest actually adding a pillar dedicated to the outdoor environment at schools. Suggestions for elements to include: Design, Management and Learning. Design: Site designed to manage stormwater, increase habitat for birds, insects and amphibians, reduce impermeable surfaces, properly planted tree canopy to provide cooling and energy saving practices, increased “rough” vegetation, and preservation of existing natural features. Management practices of school sites that reduce water consumption, reduction of mowed areas, proper application of fertilizers, use of integrated pest management. Then in learning I would include outdoor classrooms as you stated:
    “It was inevitable that we’d miss something. I’ve incorporated this into the Third Element of the Third Pillar on our Framework, where it fits nicely. The additional Practice in Column D will read something like: “Schools develop outdoor classrooms on their grounds including native plantings and use them to teach an array of subjects in context, engage the broader community and develop civic skills.”

    • I concur. In terms of being “green” and more sustainable, one of the most important things a school can do is to better manage its landscape.

  22. We would like to applaud the U.S. Department of Education for creating the Green Ribbon Schools awards program. It is a wonderful opportunity to recognize the importance of environmental sustainability and education at our nation’s public and private schools, and to encourage and celebrate their efforts to becoming exemplars of sustainability. In reviewing the provided documents on the program, we noted a few points that merit additional clarification and comment:

    1. State or comparable authorities are permitted up to four nominations in this first pilot year, however, only if a designated Authority elects to submit four nominations must one of these be a private school. As 25% of all US K12 schools are private and these serve 10% of US students, we believe that Authorities should be required to nominate at least one private school rather than left to the states as an option. Many private schools are already enthusiastically involved in efforts to increase environmental sustainability within their schools and communities and ensuring their ability to participate in this recognition program would underscore a commitment to encourage sustainability efforts at all schools.
    2. The program outlines that Authorities should take into account schools’ academic achievement and achievement gaps in selecting schools for nomination. We are unsure as to how the Department proposes to measure or quantify these for private schools as these schools are not participating in current state or forthcoming Common Core State Standards assessments.
    3. As the program provides no funding for Authorities to carry out this review and nomination process, we wonder whether the lack of funding will undermine the long-term viability and success of the program.
    4. The Framework for Evaluation by Nominating Authorities outlines nicely various standards and measures to be considered in this process, but leaves some ambiguity in regard to time frames under consideration. For example, one requirement is to have “demonstrated 20% or more energy efficiency improvement/reduction in energy use.” Is this only for the current year, or can a school demonstrate this improvement over a period of time? Many schools have established energy efficiency programs, thus seeing improvements over a number of years already.

    Thank you again to the Department for its efforts in establishing this program and for the opportunity to provide comments.

  23. I applaud the Department of Education for recognizing schools that save energy, reduce costs, and feature environmentally sustainable learning spaces, as well as protect health, foster wellness and impart effective environmental education.

    However, under the “Framework for Evaluation by Nominating Authorities” one of the criteria for “Reduced solid waste production, through increased recycling, reduced consumption, and improved management, reduction, or elimination of hazardous waste streams” states that “All office paper purchased over the past year is post-consumer material, tree-free fiber, or fiber from forests certified as responsibly managed by the Forest Stewardship Council.” It’s great that you use criteria like post consumer fiber and certified forest fiber, but by only recognizing FSC certified fiber in the criteria, you are disregarding paper products certified under other credible forest certification standards like the Sustainable Forestry Initiative (SFI) and the American Tree Farm System (ATFS). Over 71% of all certified forests in the United States are certified to SFI and ATFS. This is why 100 Congressman and Governors have urged others to support all credible forest certification standards. Supporting SFI, ATFS as well as FSC supports domestic jobs, fiber and communities.

  24. If Congress has enough wisdom to compromise on President Obama’s new Work bill in which many schools will be significantly improved, the potential for energy effecient improvements and even perhaps outdoor learning labs could have a significant implication for Green Schools Awards. I whole heartly support a Green Schools Awards program.

  25. As educators, our task is to help give students the skills, tools, and perspectives to become fulfilled human beings, responsible citizens, and effective stewards of a sustainable future. We at Facing the Future believe that education about the interconnections between the environment, the economy, and society, integrated into core curriculum, is key for insuring the sustainability of our schools, our communities, our country, and the world. The framework of sustainability, and the scope of the Green Ribbon Schools program, makes school more engaging, relevant, and solutions-oriented. Today’s world demands a global outlook that considers sustainability in across the curriculum and throughout the school.

  26. I think this is a great step towards engaging students, teacher, parents, school staff and the wider community towards environmental awareness and stewardship. Our school has been part of the Eco-Schools USA program and was awarded the Green Flag Award in June 2011. It has been a great experience for all participants which includes students, parents, faculty, and the community. It was a great relationship building opportunity for everyone. Students had a great time participating in various environmental service learning projects. It was done through many subject area and all activities were connected to the current curriculum. I am all for it. Feel free to contact me if you need any ideas.
    Thanks.

  27. Additionally,most of the school buildings in this county are more than 50 years old. Also, as school budgets get tighter maintenance budgets shrink.

  28. I’m really happy that you’ve included healthy school environments as one of the Pillars. Children are more vulnerable to environmental exposures than adults because their bodies are still developing; they eat, drink, and breathe more in proportion to their smaller body size; and their behaviors (like hand-to-mouth activity) expose them to more chemicals. If the school does not have a safe and healthy physical environment, the other pillars really don’t matter since ultimately, the exposures they have in school (like PCBs, flame retardants, pesticides, etc) will interfere with their ability to learn as many are associated with impaired learning. Others, like lead and PCBs, are associated with poor impulse control, which may not directly impair learning, but may make it harder for a child to focus, thereby indirectly impairing a child’s ability to learn. In a similar way, cockroach droppings at school may trigger asthma attacks; when a child’s asthma is not in control, he/she may miss school, falling behind on lessons, thereby impeding his/her learning. Childhood exposures to chemicals, some of which are found in schools, have also been linked to adult onset diseases which then overwhelm our healthcare system and economy.

    The document titled, “Instructions for Use of Nominating Authority Evaluation Support Framework to Evaluate Schools for Nomination to ED” indicates that “authorities making nominations to ED should note that schools must also comply with federal civil rights and federal, state, tribal and local health, environment and safety statutory and regulatory requirements in order to win an award” which is provided a footnote reference to a List of Federal Civil Rights, Health, Environment and Safety Statutory and Regulatory Requirements, but I was unable to find this list. It should be more prominent in the documentation as well as in the nomination materials. One of the environmental statutes with which a school/district should be in compliance is AHERA (asbestos regulations).

  29. Entering our 4th year with our school garden where we have incorporated outdoor classes in all subjects. Sometimes you can’t measure what the students get out of it with a test, you just know. With all that is happening in the world, I am so thankful that we have a garden and a place to help the kids learn they can make better choices, and they can make a difference. I am excited about the Green Ribbon program, but not hours of paperwork/computer forms, bureaucracy, and waste. Please make it simple, streamlined, and efficient!

  30. I love that “Greening” schools is finally becoming main stream. I have served as the PTA Environmental Chairperson for my daughter’s schools for more than a decade and even spent several years putting together a book called Green School 101 to document and share the work we did. It is geared toward parent volunteers and teachers who want to take the initiative to implement any number of environmental programs and has information on everything from starting environmental clubs and recycling programs to writing grant applications and getting other parents and teachers to help out. I know there are plenty of people out there who want to “green” their schools, but unfortunately I’ve found that if parents don’t help teachers out with some of these programs, they often don’t happen. Teachers are just too busy trying to keep up with the things they already do which is too bad since every environmental program can be linked to the curriculum in some way.

  31. I am very excited about the potential here. Rewarding schools for their environmental practices and education is a great way to model behavior for future stewards (not to mention a great example of positive reinforcement!).

    My hope is for this to be taken seriously and really mean something; that it is not Just Another Label for a school district. I remember as a student attending a Blue Ribbon School – something that garnered bragging rights for a decade, whether the award was still good or granted again, but that actually meant very little to the students or the teachers. A school that earns a Green Ribbon should actively deserve it – continuously – and embody the hard work that went into establishing the benchmarks the committee developed.

  32. Of course recognition is always helpful and provides direction and goals to be acheived. However, I agree with Anna that funding and linking to curriculum are needed. The research that says that environmental topics and outdoor learning increase test scores should be motivation to include this at all schools. And in terms of funding, capital investments for energy efficiency are again going to be more difficult for schools in low-income districts where the tax base is barely enough to keep the schools functioning as they are. This creates another level of inequity.

    It would be nice if the award could come with some kind of cash award.

  33. I wish the program could be expanded to include a “Green Ribbon” district. We have 14 schools that are striving to meet and exceed the state and national goals for energy usage reduction. Energy conservation, waste reduction, and sustainable energy production have been part of a district goal for the past 3 years.

  34. The Green Ribbon program is commendable in that administrators, teachers, students, and their families may learn how to live in a more sustainable way. But speaking as a science teacher and trained biologist, the weakest link of this program is that it is not tied in any way to a school’s science curriculum. Why is there a push for “green technology” or “sustainable living?” One reason is because we, as humans, have placed great value on inventing amazing technology but have shied away from linking our “advancement” to our over-use of natural resources and the consequential decline of the natural world. Without adequate funding for a truly eco-literate education–one based on inquiry based science programming that delves into the hows/why/and links between topics such as energy, the properties of electricity, technology/engineering, ecology, and decision-making–we may make “Green Ribbon” schools, but no future “Green Ribbon” scientists or innovators. That is an unacceptable way to serve our students, our communities, and our planet.

  35. According The Economist (May 28-June 3, 2011), the human presence on the planet Earth has so profoundly changed its life sustaining eco-systems that geologists are now thinking about renaming the present era from the Holocene to the Anthropocene, the age of man. Is that not reason enough for environmental literacy to be an integral part of the K-12 curriculum? The Green Ribbon Awards Program is hardly sufficient by itself, but it is a step toward preparing students for the complex and interrelated social, economic, and environmental challenges they will face in the 21st century. I am disappointed that only 50 schools will be recognized in the first year. I would strongly encourage that all schools that make even small steps be given some kind of honorable mention.

  36. The suggestions made so far seem very helpful to me. But it appears that some have perhaps not opened all four documents to see the full scope of the initiative, as their suggestions are indeed already included.

  37. As another commenter pointed out, the failure to include green cleaning in the criteria pillars is a glaring omission. Energy efficiency, recycling and other basic/commonly-cited tenets of sustainability are certainly important, but research has shown that nothing has a bigger impact on delivering a healthy indoor environment for students, staff and school guests than cleaning. It is time for cleaning to be recognized for the crucial role it plays in “going green” and sustainability and the Department of Education holds responsibility in transforming the way school administrators view cleaning (I cringe every time I read an article about the custodial budget being cut. It is no wonder that many of the nation’s schools are in such poor condition). The Green Ribbon Schools Award should require that award recipients have a comprehensive green cleaning program, highlighted by the use of environmentally preferable products, training of cleaning professionals, and the implementation of both an effective management structure and processes that are rooted in the principles of quality, “customer” satisfaction and continuous improvement. There are even consensus-based professional standards and certification programs administered by not-for-profit organizations like ISSA – The Worldwide Cleaning Industry Association, that have achieved widespread market acceptance and can be cited. Thank you for your consideration of these comments.

    • Please see Pillar I, Element III of the Framework for Evaluation by Nominating Authorities. D:27: “All cleaning products in use are certified “green”.” We welcome suggestions to clarify that language.

      • Requiring that green cleaning products be used is certainly a good first step, but it is equally important that the cleaning services be structured to deliver professional, effective cleaning. In other words, it is simply not enough to use green products. After all, if a school is going to be “green,” it, by definition, has to be healthy. And a school can only be healthy if it is cleaned effectively. A school can use the most innocuous products available, but if they do not perform their intended function (as a result of the fact that the product does not work, because the worker is not trained in their proper use, because the cleaning of the facility is poorly managed, etc.) and the school is not clean, there is NO way it can qualify as green.

        That being said, the green cleaning requirement needs to be expanded to include a requirement that ther custodial program is based in the principles of effective management and “green” service. As mentioned, there are programs that speak to this exact issue and have been “recognized” by green cleaning authorities like the USGBC Center for Green Schools and the Healthy Schools Campaign. Thank you once again for your consideration of these comments.

  38. “Greening” schools is a no-brainer on many levels: saves money, is healthier, kids and teachers are better able to think and learn., etc. Project Learning Tree’s “green School curriculum provides excellent activities for teachers to let students lead the greening process while addressing the all-important academic benchmarks.

    One thing I see missing from these kinds of initiatives is a lack of focus on the outdoor spaces surrounding the school. “No idling” campaigns are great, but how about raingardens, native plantings, and most importantly, establishing outdoor classrooms on the grounds so that classes can do math, reading, writing, and other subjects in the context of their own local environment? Schools spend a lot of money on bussing to field trips– these costs could be alleviated if the field was right outside their door. FREQUENT experiences in nearby nature are more effective at raising environmental literacy than one or two big-deal field trips.

    For example, how many baseball diamonds does one school need? What if one was converted into an outdoor learning space? What are the cost savings for that? Let’s see: no more mowing, less erosion, less groundkeeping labor needed, etc.

    There’s an old saying: “If you don’t know where you are, you don’t know who you are.” Kids can name 10 different iphone apps but don’t know the species of tree they walk by every day into school.

    • Thanks, Laura. It was inevitable that we’d miss something. I’ve incorporated this into the Third Element of the Third Pillar on our Framework, where it fits nicely. The additional Practice in Column D will read something like: “Schools develop outdoor classrooms on their grounds including native plantings and use them to teach an array of subjects in context, engage the broader community and develop civic skills.”

    • The Green Ribbon initiative for schools will certainly help in highlighting the importance of looking at a school as a complete package from the grounds, to the workings of the building and the programs in place to deal with providing solid green practices. The Departments of Education across the Country must be the primary leads in this program if we are to entice our educational leaders to take this initiative serious and want to participate.

  39. In the evaluation form for pillar II, I don’t see anything on green cleaning or daylighting. Sure you could say green cleaning is covered under “chemical management”, but spelling out a green cleaning program would be good. Also, there isn’t anything on access to daylight, which has been proven to increase productivity and wellness. I know it is difficult to control this in existing buildings, but it should be part of the evaluation to recognize that it is paramount to having a healthy school environment. Rooms with no windows and artificial lighting are not good learning environments.

    • Credits relating to daylighting are included in both the LEED for Schools rating system and the LEED for Existing Buildings: Operations & Maintenance rating system. Daylighting has become a best-practice across the industry, and any school undergoing renovations or construction should be prioritizing it as part of their plan for indoor environmental quality. There’s a proven link between natural light and occupant health and productivity, and nowhere is productivity more important than in our schools.

  40. Thank you for openly publishing material for review and comment. The Green Ribbon program will raise the bar for schools, school administration and teachers The classroom environment itself can either support or detract from a child achieving maximum learning potentials. Teachers, custodians, maintenance team all have a significant role to play in providing an environmentally secure facility, though often are not aware of their own impact. Asthma triggers, masking agents that hide problems not resolve them, unauthorized pesticide use, cleaning chemicals from home including chlorinated bleach, excessive clutter and more are all issues brought to the classroom that interfere with a child’s ability to learn and in some cases a teacher’s ability to teach. The costs of maintaining school buildings are quite significant and often overlooked by education administrators focused on the education process. Through programmed energy conservation school budgets may be made to be more efficient channeling more funding into education and out of producing greenhouse gases harmful to us all. The children of today are much more in tune with the environment than in the past. They understand the carbon cycle and how local decisions can have global impacts for example. Through integration of sound environmental education into the curriculum we are better serving our local and global community fostering behavior changes of benefit to us all. Anyone who says teachers do not have time to participate in making their own classrooms more suitable for children to learn or that school districts cannot afford these types of initiatives are prime examples of why this program needs to exist. Case after case shows that Going Green saves school districts money and allows students to be more healthy when implemented in responsible fashion. Let’s all hope that most of our educators have not decided to stop learning! Go Green Ribbon Go!!!

  41. It’s important to remember that green schools activities don’t interfere with instruction, they can actually enhance instruction and motivate students.
    Done well, green studies, like understanding energy sources and generation and conservation, actually allow kids to develop and practice leadership skills and these place-based learning activities are more motivating than traditional, dry textbook lessons. They can also easily be integrated into several content areas, including science, math, economics, and social studies.
    Further, some of the fastest growing job sectors in the US are related to energy, energy management, resources management, and other fields directly related to green actions.
    I strongly support the Green Ribbon Schools Award program and remain available to provide assistance to the US Department of Education in any way possible.

  42. There is too much test prep to ever be able to focus on greening schools.

    Teachers do these things despite the Dept. of Ed. You guys are a thorn in our side, and completely unhelpful.

  43. I second Eddie – great idea! The three pillars in particular are well-crafted: very comprehensive, thoughtful, and appropriately ambitious. Very impressive.

  44. I humbly believe this is a great idea. I would like to see more linkage to life science, Earth, physical science, environment and health. Schools could not only save energy and reduce cost, but engage in arbor activities, agriculture, healthy eating, etc. This would be an excellent opportunity to branch out in thematic units that are proven to be most effective strategy with at-risk students. Thanks for the opportunity.

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