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are adapted to the open habitats once maintained by fire and grazing. <br />Prior to European settlement much of Orange County was <br />predominated by prairie-like and open woodland ecosystems <br />maintained by frequen#, low-intensity, fires and grazing (by buffalo). <br />Mowing has been the standard roadside management tool for over a <br />century and is still commonly used across the US, which to a large <br />extent mimics the effects of fire and grazing by removing woody plants. <br />Herbicide use, therefore, #hreatens these remnant ecosystems within <br />rights-of--way. <br />2. Application of herbicides, even those that #arget broadleaf and woody <br />plants, can kill grasses and other monocots through soil activity. In <br />addition to refugium disruption, soil erosion is greatly increased without <br />a consistent herbaceous plant cover. <br />3. Rights-of-way are vulnerable to invasive plant colonization, which is <br />compounded when gaps are created with herbicide use. Invasive <br />plants are a serious threat to native plant communities, and their <br />colonization and spread should be discouraged. <br />4. Herbicide application often results in unavoidable, inadvertent, or <br />careless drift onto non-target plants outside the right of way. <br />(Herbicide drift is the reason that the herbicide complaint was made #o <br />the County Commissioners in the first place.) While applicators must <br />be State certified, there are inevitably mistakes made, such as <br />excessive drift and overspray. <br />5. Rights-of--way with dead or dying plants during the growing season are <br />an aesthetic concern. The NC DOT Roadside Environmental Unit's <br />mission is: "To provide roadside elements for a statewide highway <br />system that are safe, environmentally sound, attractive and responsive <br />to the public's needs." The Orange County CfE fully endorses this goal <br />and believes that a no herbicide policy best supports the Roadside <br />Environmental Unit's mission. <br />Recommendations: The CfE recommends that the County engage all <br />companies and public agencies tha# use herbicides to control woody <br />vegetation in order to determine: 1) what herbicides are used and in what <br />manner, 2) what are the limitations of returning to mechanical rights-of--way <br />clearing, and 3) the locations of rare plants, specialized plant communities, <br />and sensitive ecosystems (e.g., stream sides) that should only be maintained <br />with mowing or hand-cutting. <br />These discussions should seek #o remedia#e our concerns and lead to <br />changes in woody vegetation control practices. These talks should be <br />coordinated, if possible, with any similar existing negotiations between <br />concerned governmental agencies such as the NC Natural Heritage Program, <br />NC Division of Parks and Recrea#ion, NC DOT, and the various utilities. <br />conc~tsissioH. for tMe Esavlrvau-ueaat <br />C/o Orav~ge Couvrt~ 67cCD <br />po pox SiB~ /.~06 ,~ Revere Road <br />Hzllsborough, NG 2,~2~8 <br />~~~ 245-.250 <br />