I am writing to express my concerns and to suggest a solution regarding an access and accommodation issue pertaining to citizens disabled with Multiple Chemical Sensitivity (MCS) and travel along public right-of-ways.  

The problems

Each year, Department of Transportation (DOT) and county Road and Bridge agencies, spray pesticides, like herbicides, along thousands of miles of highways, city streets, medians, and along bike paths and park hiking trails across the nation to control plant and tree "pests."  Of special concern, is the nationwide interagency campaign currently underway to address the problem of nonnative, invasive plants (or "noxious weeds").  Left unchecked, these "alien" plant invaders spread quickly and densely, displacing farm- and rangeland, threatening wildlife habitat, and re-ucing the usability and aesthetic value of public lands.  Some noxious weeds are also poisonous to livestock and horses.  Department of Transportation (DOT) and county Road and Bridge
agencies typically rely primarily upon the use of synthetically-produced herbicides to control unwanted vegetation.  Despite billions of dollars spent on herbicides toward this end, however, noxious weeds continue to thrive and spread.        

Many of the herbicides commonly-used to control noxious weeds along right-of-ways are associ-ted with human health conditions such as cancer, asthma, peripheral neuropathy, seizure disorders and chemical sensitivity, as well as environmental risks such as groundwater contamination and endocrine disruption in wildlife.  Serious concerns have been raised in recent years by some scientists and the Environmental Protection Agency (EPA) about pesticides causing endocrine disruption in the human population, too.  The repeated and widespread use of herbicides is also attributed to an increase in herbicide plant resistance, which, in turn, seems to encourage the more frequent use or use of stronger combinations of herbicides by public and private landowners alike.  In addition, roadside herbicide spraying can actually contribute to noxious weed infestations by reducing beneficial species and soil microorganisms and altering the natural plant succession process-all essential to the restoration and preservation of native, and otherwise, desirable plant communities.  At best, heribicides offer temporary, cosmetic relief-their use is a "band-aid" approach to an ages-old, systemic environmental problem.   

For the chemically-sensitive disabled, the practice of herbicide spraying along public right-of-ways poses a barrier to access to any number of essential daily life activities.  Because pesticides are one of the worst offending chemical incitants for chemically sensitive individuals, roadside spraying greatly hinders such routine activities as going to the grocery store to buy food, retrieving mail, attending school, going to work (if the person can work), driving to a doctor's appointment, and much more.  Roadside spraying forces citizens with MCS to live isolated and "trapped" inside their own home for long periods of time.  Many with MCS move to rural areas to avoid urban exposures to pesticides (and other chemicals) only to be faced with roadside spraying, in some cases, year round;  and this practice is increasing steadily, in light of heightened national concern over noxious weeds.   For the poor with MCS, right-of-way spraying in rural areas denies access to public programs and services that offer desperately-needed assistance, as social services agencies usually require applicants to attend interviews and fill out forms in person.   Some state DOT and county Road and Bridge agencies provide an "herbicide hotline" so citizens can call to find out where roadside spraying has occurred recently and/or where it will take place in the future.  While this service is somewhat helpful, it offers little protection to the chemically sensitive living near sprayed roadways, and still, no access to public roadways due to the spraying.   In rural areas, there may not be alternative routes one can take because either they do not exist or they have also been sprayed-a common occurrence.  This is also true of urban areas, where city medians are routinely sprayed, denying access to city streets and forcing the chemically sensitive disabled to travel out of the way to get from one point to another, if that's even an option.  

The solution

Integrated Vegetation Management (IVM), as it was originally intended, offers a proactive, long-term and cost-efficient solution to providing access and accommodation for the chemically-sensitive disabled along public right-of-ways.  IVM is based on Integrated Pest Management (IPM), a whole systems approach to pest management (in this case, the "pests" are weeds) which employs a combination of least-disruptive, least-toxic weed management strategies and methods first.  Artificial controls, such as herbicides, are used only as a last resort, after all nonchemical strategies have been tried, and then, only on a temporary and limited basis, as transition tools towards nonchemical weed management.  IPM was originally developed as a strategy to assist farmers in reducing and eliminating pesticide use.  Integrated Vegetation Management (IVM), as it is widely-known today, however, has become a watered-down version, whereby, herbicides remain the primary control tool in most agency weed management plans.  Chemical controls, mixed with other controls such as mowing, biocontrols, flaming, and handpulling are lauded as "integrated" vegetation management, when this is incorrect.  Progressive land managers understand that IVM is much more than that.

It has not helped that there is a myth perpetuated within the traditional weed management com-unity that reliance upon nonchemical IVM is not cost-efficient, feasible and/or effective.  Quite the contrary, classic IVM focuses on restoration:  the long-term, sustainable control of noxious weeds through methods which working with nature, not against it, using revegetation as an aid.  

Nonchemical control methods may seem more costly at the outset, but in the long-run, provide substantial savings in lowered maintenance and supply costs and in reduced worker, citizen and environmental liability costs, while providing benefits such as the preservation and protection of native plants, biodiversity, wildlife and wildlife habitat, wetlands protection, prevention of soil erosion and beautification.  Agencies and communities in Alaska, California, Colorado, Iowa, Illinois, Minnesota, North Carolina, Oregon and Washington have found nonchemical IVM to be effective, feasible and cost-efficient.  Progressive land managers know that classic IVM is the preferred approach to noxious weed management not only from the human health and environmental protection standpoints, but also from a plant science, ecologically-based perspective.  

I bring to this discussion fourteen years as a citizen legally disabled with Multiple Chemical Sensitivity, along with thirteen years of research and field experience in Integrated Vegetation Management (IVM).  Among the projects I have been involved in, is the Highway 285 Living

Roadsides Project, a federally-funded, model, community-based, environmental protection initiative I developed and managed which demonstrates nonchemical IVM along 31 miles of federal highway in Colorado.  The Project is highly-collaborative, bringing together public and private landowners to address the problems of noxious weeds and pesticide pollution in a proactive way.  My interest in these issues began as a result of my family becoming violently ill on two occasions while driving along state highways that had been recently sprayed with herbicides.  

Currently, I am working with Professor Timothy Seastedt, from the University of Colorado (CU) at Boulder, to develop the Sustainable Roadsides Initiative, a statewide program which will provide hands-on education and training to state and local agencies on how to design and implement nonchemical roadside IVM programs.  We are also working to establish the Integrated  Vegetation Management Institute at CU which will provide ongoing, science-based research, education and training on nonchemical IVM at the national level.  Professor Seastedt was recently recognized by Congress for his work on the use of biocontrols to manage diffuse knapweed (Centaura diffusa), a common noxious weed found here in the western United States.  

In closing, I believe the inclusion of IVM as part of the guidelines for access and accommodation under the Americans With Disabilities Act (ADA) would significantly reduce right-of-way barriers for the chemically sensitive disabled.   I respectfully request that the Access Board seriously explore the adoption of such a policy so that our public roadways, and other right-of-ways, may finally become accessible for all American citizens.

Most sincerely,

Micki Davi

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