Micki Davi | April 16, 2002 |
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