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are adapted to the open habitats once maintained by fire and grazing. Prior to European settlement much of Orange County was predominated by prairie -like and open woodland ecosystems maintained by frequent, low- intensity, fires and grazing (by buffalo). Mowing has been the standard roadside management tool for over a century and is still commonly used across the US, which to a large extent mimics the effects of fire and grazing by removing woody plants. Herbicide use, therefore, threatens these remnant ecosystems within rights -of -way. 2. Application of herbicides, even those that target broadleaf and woody plants, can kill grasses and other monocots through soil activity. In addition to refugium disruption, soil erosion is greatly increased without a consistent herbaceous plant cover. 3. Rights -of -way are vulnerable to invasive plant colonization, which is compounded when gaps are created with herbicide use. Invasive plants are a serious threat to native plant communities, and their colonization and spread should be discouraged. 4. Herbicide application often results in unavoidable, inadvertent, or careless drift onto non - target plants outside the right -of -way. (Herbicide drift is the reason that the herbicide complaint was made to the County Commissioners in the first place.) While applicators must be State certified, there are inevitably mistakes made, such as excessive drift and overspray. 5. Rights -of -way with dead or dying plants during the growing season are an aesthetic concern. The NC DOT Roadside Environmental Unit's mission is: "To provide roadside elements for a statewide highway system that are safe, environmentally sound, attractive and responsive to the public's needs." The Orange County CIE fully endorses this goal and believes that a no herbicide policy best supports the Roadside Environmental Unit's mission. Recommendations: The CIE recommends that the County engage all companies and public agencies that use herbicides to control woody vegetation in order to determine: 1) what herbicides are used and in what manner, 2) what are the limitations of returning to mechanical rights -of -way clearing, and 3) the locations of rare plants, specialized plant communities, and sensitive ecosystems (e.g., stream sides) that should only be maintained with mowing or hand - cutting. These discussions should seek to remediate our concerns and lead to changes in woody vegetation control practices. These talks should be coordinated, if possible, with any similar existing negotiations between concerned governmental agencies such as the NC Natural Heritage Program, INC Division of Parks and Recreation, NC DOT, and the various utilities. CammLss&ow /or the Fl v. mnm C✓a Or,,ge C..td 6 D Po sox ei 1S 6 -R rze✓ert Bard Ha harough NC23238 (9V) 2 2syo