ENVIRONMENTAL POLICIES, OVERSIGHT AND COMPLIANCE
We believe climate change is among the most important issues of our time and have developed research-driven policies to clarify our role as a steward of the environment.
We expect all employees and contractors to adhere to our environmental policies. We have management strategies in place, including an environmental management system, to help ensure we continue to abide by all regulatory compliance requirements. We also provide employee education through tools such as annual training and daily environmental messages for employees whose work can directly impact the environment.
Our Environmental Policy
FirstEnergy believes it is our responsibility to protect and preserve the natural environment and promote a sustainable future for the customers and communities we serve. We are responsible stewards of the natural resources impacted by our operations and are committed to fulfilling this responsibility for current and future generations by conducting our operations according to the principles in this policy.
We will meet or exceed the requirements of all applicable federal, state, and local environmental laws and regulations.
We will conduct our operations through equitable, just, and transparent engagement with the communities we serve.
We are committed to minimizing the environmental impact of our operations on air, water, and land; advancing resource conservation and enhancement; and employing pollution prevention and minimization policies. We address climate change through effective, comprehensive, and innovative project planning as described in our Climate Position and Strategy. We undertake companywide sustainability efforts and provide annual environmental training, daily environmental messages, and Environmental Performance News Flash communications to all employees whose work can directly affect the environment. We do this to drive accountability for understanding and incorporating environmental responsibilities into daily activities. We also conduct audits and assessments and promptly correct work conditions that we determine threaten human health, safety, or the environment.
We proactively integrate environmental considerations into all areas of business planning and decision-making to preserve, protect and maintain the environment and to mitigate the risks from climate change for future generations. To help ensure ongoing environmental improvement, we plan, implement, and measure our performance through operational evaluations. We will also continue to promote waste reduction, environmental awareness, and biodiversity across our operations. To support these efforts, we will sustain a culture of environmental stewardship at all levels of the organization and encourage employees to identify opportunities to modify our business policies and asset replacement strategies to be more environmentally responsible.
We promote and maintain open dialogue with employees, customers, regulators, and our communities with respect to environmental, social and governance issues. We foster customer education, respond to stakeholder concerns, and enhance the environment through various FirstEnergy employee volunteer efforts, such as our tree planting and pollinator garden sustainability programs. These and other actions are part of our larger efforts to support the communities where we live and work by cultivating civic, economic, and social well-being.
Our Environmental Justice Policy
The U.S. Environmental Protection Agency (EPA) defines Environmental Justice as the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation and enforcement of environmental laws, regulations and policies. According to the EPA, this goal will be achieved when everyone enjoys the same degree of protection from environmental and health hazards, along with equal access to the decision-making process to have a healthy environment in which to live, learn and work.
In alignment with EPA's definition, FirstEnergy is committed to ensuring the opportunity for inclusive participation and the equitable consideration of stakeholders as we seek an environmentally sustainable future for the communities we serve. This will enable stakeholders to be involved in the decision-making process when our activities affect the environmental and/or health conditions in our service area.
We will strive to find strategic and collaborative solutions to better manage and mitigate environmental and/or health impacts on our communities, including underserved communities. We will also seek out and facilitate the meaningful involvement of those potentially impacted by our current and legacy operations.
With this policy as a foundation, FirstEnergy aims to add depth and clarity to our understanding of Environmental Justice in our daily business practices as we move forward in equitable support of our stakeholders.
ADDRESSING ENVIRONMENTAL JUSTICE AT FIRSTENERGY
Using industry best practices, we designed our Environmental Justice policy to better understand the interests and concerns of the communities we serve, help us more equitably support them and make them part of the decision-making process. While listening and responding to the needs of our communities is not new, this is a fresh opportunity to enhance those communications, especially in underserved or overburdened areas within our service territory.
Implementation of the program, planned for the second half of 2023, will begin with projects involving the construction of new transmission lines and substations before expanding the program to other project areas. Using GIS screening tools available through both US EPA and state agencies, we will seek to better understand the socioeconomic and environmental characteristics of the project area to identify potential Environmental Justice communities that could be impacted by the project.
Ultimately, it’s our goal to expand our Environmental Justice program to become an integral part of our everyday business. We view it as fundamental to our overall approach to FirstEnergy’s corporate responsibility and a natural extension of our core values.
FirstEnergy employees are interested and self-motivated to support and help our communities, as exemplified by our 10 Green Teams. These teams, comprised of employee volunteers, participate in a wide variety of environmental stewardship initiatives that advance environmental justice and support our mission. Since 2021, the teams planted more than 41,700 trees in public spaces, far surpassing their original goals. The planting effort will continue with a focus on economically-depressed neighborhoods within our service areas. The new trees help improve neighborhood aesthetics, provide shade and ultimately create a sink for carbon dioxide. In addition, fruit trees planted by our Green Teams will produce fresh fruit for local residents.
ENVIRONMENTAL OVERSIGHT AND ACCOUNTABILITY
FirstEnergy’s Environmental group focuses on environmental compliance and oversees a range of environmental issues, from responsibly managing waste to reducing infrastructure-related risks to avian species. The policies we’ve established, and their related initiatives, foster employee awareness, provide guidance, define responsibilities and outline our strategy for mitigating environmental impacts.
With these policies as a foundation, 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 strategy and core values.
The board of directors oversees enterprisewide risks, including environmental risks. The Audit Committee oversees remediation costs, environmental budgets and material environmental risks. 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. Additionally, in coordination with the Corporate Governance, Corporate Responsibility and Political Oversight Committee, the Operations and Safety Oversight committee oversees environmental strategy, initiatives and policies, including in the areas of climate change and environmental protection.
Led by the senior vice president of Operations and the vice president of Utility Operations, the director of Environmental and the Environmental Management team are responsible for executing the environmental strategy, providing management oversight of environmental initiatives and compiling reports on environmental progress for 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 managing environmental compliance; 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.
We also incentivize 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 EESG data table for our Environmental Excursions and NOVs metrics.
Compliance excellence is a key principle of FirstEnergy’s approach to protecting the environment and mitigating the impact of our operations. Various levels of oversight help ensure that we are complying 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 help ensure compliance with all environmental regulatory requirements, we use an environmental management system for our power generation operations that tracks our regulatory 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 a similar environmental management system on the transmission side to help ensure 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:
- Identify and correct any instances of noncompliance.
- Help managers gain a thorough understanding of the specific environmental compliance requirements of particular facilities.
- Identify practices and circumstances that make facilities vulnerable to noncompliance.
- Increase awareness of individual accountability for environmental compliance and environmental stewardship.
- Provide independent inspections verifying environmental compliance.
We intend to evaluate every FirstEnergy facility through the ECAP program every three years.
Additionally, through our Environmental Threat Assessment Program, we aim to exceed 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.