Policy and Compliance Excellence

Environmental Policy

FirstEnergy believes it is our responsibility to protect and preserve the natural environment and build a sustainable energy future for the customers and communities we serve. We are committed to fulfilling this responsibility by conducting our operations in accordance with our Environmental Policy.

We expect all employees and contractors to adhere to our Environmental Policy. We have management strategies in place to ensure we continue to abide by all regulatory compliance requirements, including an environmental management system, and we provide employee education through tools such as annual training and daily environmental messages.

Our Environmental Policy:

FirstEnergy is committed to providing customers with electricity in a manner consistent with environmental policies, laws and regulations. We achieve this by effectively managing the environmental impact of our activities, using natural resources wisely, improving our performance, enhancing our stewardship and supporting research on innovative technologies. Our commitment to environmental management includes the Board of Directors and executive management committees, as well as an employee incentive compensation program linked to environmental performance.

Environmental Oversight
and Accountability

FirstEnergy’s Environmental group oversees a range of environmental issues, from responsibly managing waste to reducing infrastructure-related risks to avian species. Our Environmental Policy and initiatives foster employee awareness, provide guidance, define responsibilities and outline our strategy for mitigating environmental impacts.

Board and executive-level oversight helps ensure the transparency and accountability of our environmental initiatives, while also ensuring those initiatives are carefully aligned with the company’s core values and Strategic Plan.

Board
Level

The Board of Directors oversees enterprise-wide risks, including environmental risks. Our Audit Committee, Corporate Governance and Corporate Responsibility Committee, and Operations and Safety Oversight Committee (all comprised of independent directors) provide oversight of different aspects of our environmental initiatives and performance. For example, the Audit Committee oversees remediation costs and environmental budgets, while the Operations and Safety Oversight Committee oversees the Environmental Excursions and Notices of Violation (NOV) Key Performance Indicator (KPI) and other indicators of environmental performance. The Corporate Governance and Corporate Responsibility Committee oversees FirstEnergy’s corporate citizenship practices, ESG approach, initiatives and policies to the extent not otherwise overseen by the other Board committees to ensure they are consistent with our long-term strategic objectives and reflective of good corporate citizenship.

Executive
Level

Led by the Vice President of Utility Operations, our executive-level management team is responsible for executing the environmental strategy and providing oversight on environmental initiatives. The Vice President of Utility Operations and executive-level team routinely provide reports on environmental progress to appropriate board committees throughout the year.

Director and Environmental Management Team

The Environmental Management team and Director of Environmental have a broad range of responsibilities that includes identifying new or changing regulations that affect our operations; overseeing all operational permits at the federal, state and local level; and overseeing initiatives that support the environmental strategy. Together with the Vice President of Utility Operations, the Director of Environmental provides regular monthly reports to the executive-level management team on environmental programs and key initiatives, as well as the status of our Environmental Excursions and NOV KPI.

Compliance Excellence

Compliance excellence is a key principle of FirstEnergy’s approach to protecting the environment and mitigating the impact of our operations. We strive to comply with all federal, state and local laws and regulations applicable across our footprint including, but not limited to, those related to the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and the Endangered Species Act.

To ensure we abide by all regulatory compliance requirements, we use an environmental management system for our generation operations that tracks those requirements and prompts responsible parties to complete each required task. We use the same environmental management system, on a more limited basis, in our distribution operations, and we also employ another similar environmental management system on the transmission side that ensures adherence to our project-based permits and compliance requirements.

Our Environmental Compliance Assessment Program (ECAP) is another vital part of our efforts to maintain compliance excellence. Through this program, we conduct rigorous internal regulatory reviews of individual sites to assess environmental compliance with federal, state and local requirements. Essentially, ECAP helps us to:

We strive to evaluate every FirstEnergy facility through the ECAP program once every other year.

Additionally, through our Environmental Threat Assessment Program, we strive to go above and beyond compliance requirements by performing site visits that help us to proactively identify and eliminate any potential environmental risks at our facilities.

These two key programs help us to maintain compliance in a variety of areas and put into action our commitment to be good stewards of the environment.

We also assess our environmental performance by including Environmental Excursions and NOVs as a KPI metric in the Operations Index of our short-term incentive program. Our Environmental Excursions and NOV KPI metric tracks any regulatory reportable air emission, water discharge or other unauthorized release that exceeds applicable environmental limitations, conditions and deadlines set by federal, state or local regulations. Our threshold, target and stretch goals for this metric are based on our previous year’s performance, with the stretch goal designed to encourage significant improvement in our commitment to making the environment better. Including these environmental metrics in our Operations KPIs enhances employees’ awareness of and attention to environmental compliance and drives continuous improvement across all areas of our business. Please see our ESG data table for our Environmental Excursions and NOVs metrics.

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