Electric utilities spend somewhere between $6 billion and $8 billion annually on vegetation management across the United States. That number is not going down, especially with the growing demand of more energy combined with inflation and labor constraints.

Here's the part that rarely gets said bluntly: For a significant portion of utilities, that spend is not buying what it should. It's buying temporary results on a repeating cycle — mow, grow back, mow again — while the ROW gets denser, the woody growth get harder to clear, and the budget climbs every year without a corresponding improvement in reliability or long-term management outcomes. Sorry, but that isn’t a long term solution.

That is what a mechanical-only program does. And it is still how too much of the national grid is managed. Some have embraced IVM and their programs show that success. Others, have ignored it, and they continue to do the same thing, hoping for a different result.

IVM — integrated vegetation management — has been the recognized industry standard for decades. ANSI A300 standards reference it. NERC FAC-003 transmission vegetation management requirements are built around its principles. The Utility Arborist Association has advocated for it for years. Backed by decades of research, IVM principles provide environmentally friendly and economically responsible solutions to utility vegetation management teams across the country.

And yet, if you ask honestly how many of the estimated 21 million acres of electric and gas T&D ROW in the lower 48 states are maintained under genuine IVM programs, the answer is not what it should be. Many utilities advertise IVM in their corporate responsibility reports while the majority of their acreage is still managed on a mow only cycle.

That gap matters more now than it ever has. Because two federal programs — the Monarch CCAA and the newly authorized Bumble Bee CBA — have made IVM adoption not just a best practice question, but a regulatory exposure question. And the window to get ahead of it is closing.

Why Mechanical-Only Programs Keep Getting More Expensive

This is not complicated biology, but it is biology that most procurement decisions ignore.

When you mechanically cut a mature woody stem and leave the root system in the ground, the plant does not start over. It draws on years of stored carbohydrate reserves in the root structure and sends up new growth — basal sprouting — at a rate no seedling could match. The larger and older the root system, the more aggressive the regrowth response. Research confirms that trees and brush controlled purely by mechanical cutting demonstrate an exaggerated growth response for at least several years after treatment. You did not slow the plant down, but you did reset it with a head start. That’s why we all hear the phrase in our industry -  “we just cleared this section last year, but look how fast it grew back!”.

Utility ROW compounds this problem because of the unique conditions a cleared transmission or distribution ROW creates. The edge of the adjacent forest is a continuous seed source — wind-dispersed, bird-dispersed, and animal-dispersed seeds rain into the cleared ROW every season. Mechanical disturbance of the soil surface activates a buried seed bank that can sit dormant for years waiting for exactly that opening. Full sun exposure after clearing turns the ROW into optimal growing conditions for the most aggressive woody species. And the organic matter from decomposing mulch feeds the next generation coming up behind it.

The result is a ROW that comes back harder and denser with each mechanical cycle, not easier. The root systems get more established over time. The stems get more numerous. The cost per acre to maintain goes up due to this and also inflation.

IVM interrupts this cycle at the root — literally. Targeted herbicide applications, timed to the plant's active translocation window when carbohydrate movement is downward toward the root, address the stored energy reserve that is driving the regrowth response. Broadleaf-specific chemistry moves through the vascular system and into the root structure, suppressing the plant's ability to resprout rather than just removing the above-ground structure.

The long-term economics of this are not ambiguous. Published analyses of 20-year vegetation management programs consistently demonstrate that IVM programs produce cost savings of 25% to 57% compared to repeated mechanical mowing alone. One utility managing 5,500 miles of transmission ROW across 60,000 acres moved to an IVM-based program and replaced mowing — which was running $100 to $150 per acre — with herbicide application at $70 to $80 per acre, with longer treatment intervals and improving ROW conditions year over year.

The ROW does not stay unchanged. It is either being managed toward a stable, low-maintenance outcome with compatible plant communities, or it is being managed on a treadmill that gets harder to run every year. IVM is the path to the first. Mechanical-only is the treadmill. It’s your choice on which program your team chooses.

What the Monarch CCAA Actually Means for Electric Utilities

The Monarch Candidate Conservation Agreement with Assurances — the Monarch CCAA — is a voluntary federal program administered by the U.S. Fish and Wildlife Service, specific to energy and transportation ROW. It was finalized in April 2020. More than 40 organizations from across the energy and transportation sectors worked together to develop it.

The structure is straightforward. Utilities and ROW operators that enroll agree to create, enhance, and maintain habitat for monarch butterflies on their enrolled ROW acres as part of their normal vegetation management operations. Conservation measures include things like adjusting the timing of vegetation management to reduce impacts during peak monarch activity, incorporating native flowering plants and milkweed where practical, and using IVM practices that support pollinator habitat as part of the broader management prescription. The beauty of this is, the best way to cost effectively manage your ROW is exactly what it to be engaged in the Monarch CCAA program. It’s how you should be managing your ROW, regardless.

In exchange, the USFWS provides formal regulatory assurances — specifically, an enhancement of survival permit that authorizes incidental take of monarch butterflies that may result from normal ROW operations on enrolled lands if the monarch is federally listed under the Endangered Species Act.

That last sentence is the important one.

Monarch butterflies are present on virtually every mile of transmission and distribution ROW in the lower 48 states during migration. Standard clearing, mowing, and herbicide operations create incidental contact with monarchs and their habitat. Without CCAA enrollment, that contact becomes potential ESA liability the moment a listing is finalized.

In December 2024, the USFWS formally proposed listing the monarch as a threatened species under the ESA. A 90-day public comment period closed in March 2025. A final ruling was expected by December 2025, but the Department of Interior moved the monarch's rulemaking to "long-term action" status, pushing a final decision to fall 2026 at the earliest by current estimates.

That is not an all-clear. It is a window — and the enrollment period for the CCAA closes the moment a final listing rule takes effect. There is no retroactive enrollment. Utilities that are in when the listing drops are covered. Utilities that are not in are not.

New York Power Authority has already enrolled its transmission ROW. VDOT enrolled its highway ROW specifically because the regulatory requirements associated with a potential federal listing would lead to extensive and costly delays of general operation activities such as maintaining vegetated ROW and modernization construction activities. The utilities that have moved on this did so because they understand that the cost of enrollment is minor relative to the regulatory exposure of not being enrolled when a listing arrives.

The Bumble Bee CBA: A Newer Program, Same Logic, Even More Urgency

If the Monarch CCAA is the program utilities have had four years to think about, the Bumble Bee CBA is the one most have not gotten to yet — and it was just authorized. Good news is that it’s not much different in terms of the requirements. If you are doing the Monarch CCAA, you should also be doing the Bumble Bee CBA.

The Nationwide Conservation Benefit Agreement for Bumble Bees on Energy and Transportation Lands — the Bumble Bee CBA — was authorized by the USFWS under an Enhancement of Survival Permit on May 1, 2026. It covers 11 bumble bee species across the contiguous 48 states, including two that are already federally listed as endangered: the rusty patched bumble bee and Franklin's bumble bee. The remaining nine are at-risk species facing documented population declines.

The program was developed by the University of Illinois at Chicago in collaboration with the Wisconsin Department of Natural Resources, the USFWS, and representatives from the energy and transportation sectors — the same team that built the Monarch CCAA. It is designed explicitly to work in concert with the Monarch CCAA. Utilities that are already enrolled in the Monarch CCAA have a direct pathway to add bumble bee coverage.

The mechanics mirror the Monarch program. Enrolled utilities implement conservation measures on their ROW — primarily maintaining habitat that supports bumble bee foraging and nesting, which means native flowering vegetation, reduced mowing in areas where that's practical, and IVM-based management that preserves compatible plant communities rather than stripping every non-woody plant from the ROW. In exchange, enrolled utilities receive formal assurances that they will not be required to change ongoing management activities if covered species become listed in the future.

As of this writing, the program has been authorized but enrollment is just opening. No areas are enrolled yet. The utilities that move early on this are the ones that get ahead of it — not the ones responding to a listing after the fact.

The rusty patched bumble bee is already listed as endangered. That is not a pending action. It is current law. The question for ROW operators is not whether to think about bumble bee exposure — it is whether to have coverage or not.

Why IVM and These Programs Belong in the Same Conversation

Here is where this comes together in a way that changes how utilities should be thinking about their vegetation management programs.

IVM is not just the right agronomic approach to ROW management. Under both the Monarch CCAA and the Bumble Bee CBA, IVM practices count directly as conservation measures. Selective herbicide application that preserves native forbs, grasses, and flowering plants while suppressing incompatible woody species is exactly the type of management these programs are built around. Adjusting herbicide timing and species selection to maintain milkweed and native flowering plants is both good IVM practice and a qualifying conservation action under the CCAA.

This means utilities implementing genuine IVM programs are already doing much of the work these agreements require. The enrollment step formalizes it and provides the regulatory protection.

Conversely, utilities running mechanical-only programs are stripping ROW of the native plant communities that monarchs and bumble bees depend on, creating exactly the kind of bare, disturbed ground that promotes the fast-growing incompatible woody regrowth they are trying to manage, and doing it without the IVM practices that would make CCAA and CBA enrollment straightforward.

The mechanical-only approach costs more per acre, produces worse long-term outcomes, eliminates the habitat these programs require, and leaves the utility without coverage when the listing clock runs out. IVM costs less over time, produces better ROW conditions, maintains the habitat, and supports enrollment in programs that protect the utility from future regulatory exposure.

A well-designed IVM program and a Monarch CCAA and Bumble Bee CBA enrollment strategy are the same program, executed together.

What Utilities Should Be Doing Right Now

Luckily, the case for action is not complicated.

If your vegetation management program does not include targeted herbicide applications as a primary tool for woody species control — if your default approach to maintaining ROW is mechanical cutting on a cycle — the first step is building a credible IVM program. That means species assessment, treatment prescription by section, herbicide selection matched to the plant community you're managing, application timing built around translocation windows, and documentation of outcomes over time. It means managing the ROW toward a stable plant community, not perpetually resetting it.

If your IVM program is in place, or as you are building it, the enrollment conversation for the Monarch CCAA should be happening now. The window is open. Fall 2026 is the current best estimate for a final listing decision, potentially longer.

The Bumble Bee CBA enrollment should be part of the same conversation. The program is new, enrollment is just opening, and the utilities that move early are the ones building the habitat documentation and management history that makes the program most valuable.

Electric utilities manage some of the most significant stretches of native habitat left in the eastern United States. The ROW has always been an asset that could do more than simply keep the lights on. IVM, the Monarch CCAA, and the Bumble Bee CBA are the framework for realizing that value — while also managing the regulatory exposure that comes from not having it in place when a listing arrives.

The window is open. The programs exist. The case for moving on this is clear. Your ROW doesn’t need woody growth for obvious reasons (outages) but why not participate in this common sense conservation/habitat measure the provides you further assurances for maintenance activities. It’s a no-brainer.