FirstEnergy’s enhanced CCC herbicide specification provides metrics that support its commitment to achieving sustainable, compatible, early successional plant communities by ensuring the products necessary to support that commitment are being used correctly.

Closed Chain of Custody Improves IVM Process

May 14, 2018
FirstEnergy uses a multilevel effort to capture the benefits of this best management practice.

Utility vegetation professionals are tasked with responsibly accomplishing business objectives in the face of increasing pressure from regulatory, safety, environmental and financial challenges. Custom blending and herbicide closed chain of custody (CCC) are effective best management practices (BMPs) for utility vegetation management (UVM). Implementation of CCC BMPs has had a positive influence on the industry by improving safety, accountability and stewardship.

While knowledge of CCC and its benefits exists among its stakeholders — utilities, applicators, suppliers and distributors — implementation and the tracking and reporting of the documentation cycle of BMPs has not been entirely successful. FirstEnergy Corp. recently tackled the deficiencies it was experiencing with implementation of CCC BMPs and is now on track to gain full advantage of the program.

Contract Specifications

The FirstEnergy transmission vegetation management (TVM) team strives to incorporate BMPs into its vegetation management program to achieve business objectives related to safety, reliability, federal and state compliance, financial awareness and social responsibility. Through its supply chain efforts, the utility was able to use contract specifications to promote innovation, improve processes and reduce errors associated with field data collection and invoicing while improving transparency.

Standardizing specifications, which incorporate the Utility Arborist Association’s BMPs, enabled FirstEnergy to track contractor product purchases, verify amounts of herbicide applied and link product usage to specific locations on the rights-of-way (ROW). FirstEnergy adopted a CCC specification for herbicides that sets clear expectations for the distributor, resulting in a focused effort to ensure compliance and continuous improvement by everyone involved in the process. 

Historically, the FirstEnergy TVM group had a CCC process for many of its contractors, but it was not always used because of the lack of standardization and audit capability that now puts all of FirstEnergy’s contractors on a level playing field. The revised process has enabled the utility to consolidate its purchasing process, which ultimately has led to capturing cost efficiencies and re-establishing a better support link with its supply chain. By implementing a new comprehensive process, FirstEnergy has been able to enhance the benefits of the BMPs while improving its ability to reconcile contractor time sheets and application volumes. This has led to significant improvement in FirstEnergy’s integrated vegetation management (IVM) process.

In 2015, FirstEnergy began developing a plan to fully capture the potential of the CCC BMPs. A charter team was formed that included members from the TVM group and supply chain services. The team wrote comprehensive contract specifications that focused on efficiency, quality assurance and CCC compliance in three key areas:

• Operational capacity to supply blended product

• Knowledge, capability and software to provide key analytics

• Technical support services.

FirstEnergy’s TVM team socialized the CCC BMPs across the utility’s service territory in 2016, introducing contractors and employees to the new expectations, and encouraging a necessary culture shift to ensure successful implementation. In February 2017, FirstEnergy bid and awarded a three-year contract to the vegetation management solutions team at Crop Production Services Inc. (CPS), solidifying one aspect of leveling the playing field for contractors.

Health and Safety

Health and safety is essential to all business activities at FirstEnergy. The goal is to provide a safe and healthy work environment for employees and contractors working on the system. Implementing the CCC specification has eliminated open mixing and transferring of concentrate products in the field, reducing the risk of exposure to employees, contractors, the public and the environment. The continuous improvement and oversight of health and safety goals are further enhanced through improved training, tracking and reporting in the CCC verification process.

At the same time, the CCC specification has improved the TVM program’s transparency and standardization significantly by reducing program variables. As a result, FirstEnergy, its contractors and CPS were able to help applicators focus on safely and efficiently controlling incompatible vegetation. From a contract specifications standpoint, the utility recognized one of the primary benefits was leveling the playing field for applicators and the supplier partner. This improved consistency led to more efficient evaluation of vegetation control (efficacy), applicator performance and supplier performance while clarifying the need for technical support and training for the applicators.

FirstEnergy also streamlined the approved herbicide treatment formulation list to improve efficiency. Prior to this change, a myriad of treatment options using similar modes of action targeted similar vegetation types, creating a complex selection of herbicide formulations. This led to increased variability in the quality-control process for evaluating the efficacy and control of the target vegetation. FirstEnergy worked closely with all stakeholders to standardize treatment options and provide maximum efficacy and flexibility.

Consolidating the approved mix code list down to 22 mixes was a significant reduction that improved the quality-control process. The 22 formulations include options for all application techniques for BMPs while considering wetland requirements. It also provided the opportunity for significant savings by capturing economies of scale and reducing labor costs associated with herbicide handling and storage. The products from CPS’s Aqumix facility used by FirstEnergy’s TVM contractors are consistent across the entire system thanks to a precision blending technology that removes the variability of field mixing.

Another critical aspect of FirstEnergy’s specification is the use of only branded products in the custom blend process. This enables continued manufacturer guarantees and support for the contractors, and limits the unknowns that may be associated with the use of generic products.

Documentation Cycle

The UVM industry recognizes the need for a strong base of metrics to assist managers in validating program results. Coincidentally, one of the components of UAA’s BMPs expressed the need but did not define the process for tracking the movements of herbicides throughout the CCC process. Historically, FirstEnergy tracked herbicides on the system by documenting the returnable refillable identification number (RRID#) affixed to each container; however, that information was not of full value for FirstEnergy or its contractors.

The key to CCC program success is a data-collection system connecting all the associated application data to the RRID# and closely tracking the product in each container throughout the cycle, from the mixes being blended to the treatment area where they are applied. Accordingly, FirstEnergy worked with the CPS vegetation management team first to understand the utility’s workflow process and then to integrate an accurate data-collection process for CCC.

The first step was using FirstEnergy’s existing time-sheet system and linking its herbicide application data to the RRID#, which began the process of closing the chain of custody loop. The next step in the process was to incorporate real-time data collection and timely reporting of the movements of each product from distributor to location on the ROW. FirstEnergy sought to improve accuracy by using a digital platform to minimize the inherent errors generated by the traditional manual methods of recording contractor field records into company time sheets.

The CPS vegetation management team helped to meet FirstEnergy’s needs by developing VMUtil, a customized mobile interface that integrates the utility’s TVM work prescriptions, manageable acres and end-use reporting information. The initial field deployment test of the interface in 2017 was successful. The software is a stand-alone data-collection platform that provides real-time georeferenced data to field verify the content of every returnable/refillable container used on FirstEnergy’s system.

Focused on data collection from the active application site, VMUtil is designed as a tool for crew leaders and foremen. The app is supported by a web-based data-processing platform for metric reporting and user data management. A refined version of VMUtil will be available for use by FirstEnergy’s contractors for the 2018 herbicide application season.

The VMUtil software also was designed to automate the state-required daily chemical reports for contractors in each of the seven states in which FirstEnergy operates. This will aid the contractors by eliminating data-entry requirements, helping them to be more efficient and accurate as they complete their regulatory requirements as applicators.

True-Up Process

The proof of success of any program is the ability to validate results. The validation capability of CCC audit metrics provides a true-up process that has enhanced the FirstEnergy TVM manager’s ability to document the efficient management of the utility’s business objectives. Throughout development and implementation of the CCC program, the true-up process has been refined to improve confidence in the metrics and understand better the story the data depicts. In its final form, the true-up process provides an audit mechanism and customized metrics that reconcile the products purchased, location of application on the ROW and associated billing to FirstEnergy.

The true-up process to date not only has improved the oversight of FirstEnergy’s program through increased transparency but also greatly reduced the number of errors associated with time-sheet entries, application reports and invoice generation. The complete implementation of VMUtil by all of FirstEnergy’s contract applicators in 2018 is the final step in completing the required CCC documentation. This automation is expected to increase accuracy as well as reduce the time spent by contractor supervision and FirstEnergy staff in the time-sheet approval process.

Contractor and crew performance measures are now supported by metrics from the CCC process using the new program. For example, active monitoring of herbicide gallons applied versus herbicide gallons purchased by each contractor has led to efficiencies in the inventory and ordering processes. Metrics are actively assisting quality-control efforts to identify issues quickly, such as inaccurate time-sheet entries that could indicate under or over billing, improper task code usage and work plan deviation.

In addition, CCC metrics enable contractors to unlock data so they can more efficiently monitor crew activities and better manage inventory. For example, metrics indicating application rates per acre fell below effective control levels could lead to proactive actions that result in minimizing retreated acres the following year. The contractor also captures efficiencies from the traditional CCC benefits of improved inventory management (product tracking), minimized inventory movement and reduced labor costs.

Continuous improvement in FirstEnergy’s program has been an ongoing process of identifying challenges and addressing them in the implementation of the CCC herbicide specification. The first full year of implementation, in 2017, resulted in even greater improvements related to safety, accountability, efficiency and environmental stewardship because of the additional focus and support provided by FirstEnergy’s CCC herbicide specification. Program success is reliant on enhancing active training and education, and embracing feedback from stakeholders on program challenges and successes.

Commitment to Sustainability

FirstEnergy is committed to protecting the environment while delivering safe, reliable electricity to 6 million utility customers in the Midwest and mid-Atlantic regions. In keeping with its balanced, long-term objectives, the utility continually is looking for ways to minimize the impact of operations on the environment.

The TVM team is proud to support this commitment to sustainability through implementation of FirstEnergy’s herbicide CCC program. Over the past two years, FirstEnergy has accomplished the following:

• Created a safer work environment for employees and contractors

• Significantly reduced the waste stream associated with contract applicators ordering, shipping and mixing herbicide products

• Eliminated 60,000 pounds of cardboard and plastic sent to landfills

• Prevented more than 150,000 gallons of diluted pesticides and other substances from being introduced into the environment when cleaning equipment and containers, which otherwise would have taken additional time, labor and equipment to dispose of properly

• Created efficiencies throughout the program that generated hard and soft dollar savings

• Created efficiencies in time management that were reinvested into training and supporting FirstEnergy representatives as well as contractor personnel

• Provided enhanced metrics that validate compliance and document FirstEnergy’s commitment to sustainable vegetation management by tracking and reporting historical and real-time data on IVM treatments.

FirstEnergy considers effective messaging by employees and contractors regarding the importance of vegetation management to be very important. The TVM team actively communicates the advantages offered by the CCC program, including improved safety, sustainability and environmental responsibility. Publicly sharing the benefits of the program is a component of FirstEnergy’s overall commitment to show the utility is doing everything it can on its ROW to be a good steward of the environment while providing safe and reliable electric service to customers.

Final Remarks

In partnership with the CPS vegetation management team, the FirstEnergy TVM group has endeavored to create an industry-leading process for continuously improving a UVM program through CCC. The process’s foundation is standardized contract specifications that create transparency. It is reinforced by field services support, accurate and timely data collection along with a true-up process that provides validation of improved performance, safety, compliance and efficiency.

The process improved FirstEnergy’s ability to quantify IVM and provides metrics demonstrating the utility’s commitment to stewardship and sustainability, which can be used for more effective messaging. Based on the outcomes, FirstEnergy will continue to use closed chain of custody as a BMP and challenges the industry and peers to consider adopting a similar process. ♦

Shawn Standish is the transmission vegetation program manager for FirstEnergy Corp., where he is responsible for the utility’s transmission vegetation management activities related to federal and state compliance, new transmission construction projects, training staff and contractors, emerging technologies, contract strategies, and FirstEnergy’s TVM work management solution that staff and contractors use to document work activities. In his current role, Standish has worked for FirstEnergy for 13 years, primarily in leadership positions. He graduated from The Pennsylvania State University with a degree in forest science and presently serves on the North American Transmission Forum’s vegetation management core team.

Keven Ireland is the director of business development for Nutrien Solutions, formerly Crop Production Services Inc. Ireland has worked for Nutrien for more than 22 years and held numerous leadership positions. In his current role, he is responsible for strategic planning that works to improve Nutrien’s market position and financial growth. His current work responsibilities focus on administering marketing programs with a view to developing new services, products and technologies designed to assist in facilitating long-term strategic goals for execution in the field. Ireland also serves on the ROW Stewardship Council board of directors.

Greg Cox is the business and technology development manager for Nutrien Solutions, formerly Crop Production Services Inc. He has been in vegetation management for more than 25 years and worked for CPS/Nutrien for nearly 15 years. His broad experience ranges from field supervision to project planning and program management. Cox’s current role is teaming with vegetation management professionals to implement innovative solutions and technology to tackle challenges. He is a forestry graduate of Oregon State University.

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