I am writing to express my concern about herbicide spraying along roadsides, which interferes with access for people disabled by Multiple Chemical Sensitivity (MCS) as well as endangering others who may have sensitivities to components of these chemicals. I believe the Access Board to get involved in this issue, as it is a serious barrier to access for a segment of the disabled population.

Integrated Vegetation Management (IVM) has been shown to be effective as an alternative. In some towns in our area herbicide spraying has been drastically curtailed with alternatives being used successfully.  Each year, Department of Transportation (DOT) and county Road and Bridge agencies, spray 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"). 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 associated 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. More to the point, such sprayings constitute a barrier to access for people with MCS, asthma, and other people adversely affected by toxic chemical residues, such as those with respiratory and neurological disease, immune system dysruption, and epilepsy.

For people disabled by MCS, 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. 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.

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 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. 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.

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 those disabled by MCS. 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.

Sincerely,

Gary Powsner

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