p.o. box 300752 ■ jamaica plain, ma 02130
General Manager Richard A. Davey
Massachusetts Bay Transportation Authority
10 Park Plaza, Suite 3910
Boston, MA 02116
Secretary and Chief Executive Officer Jeffrey Mullan
Massachusetts Department of Transportation
10 Park Plaza, Suite 3170, Boston, MA 02116
February 4, 2011
Dear General Manager Davey and Secretary Mullan:
As part of its five year Vegetation Management Plan for 2011-2015, submitted August 2010 in compliance with 333 CMR 11.00, MassDOT intends to eradicate vegetation using herbicide treatments along MBTA’s Rapid Transit System rights-of-way. MassDOT intends to apply six different herbicides along the railway tracks in Boston, Braintree, Brookline, Cambridge, Malden, Medford, Milton, Newton, Quincy, Revere and Somerville.
The use of herbicides to control weed growth along rights-of-way is an unnecessary risk to public health and the environment. Herbicides are toxic to living organisms, and their use has been linked to a wide range of health problems, including cancer, reproductive harm, and endocrine disruption. Herbicides sprayed by MBTA can and do come into direct contact with residents - particularly in high minority, urban communities, where residents and parks are often in close proximity to the train tracks - and have the potential to migrate into waterways as well.
Effective, non-chemical alternatives are readily available to control weeds along rights of way. We, the undersigned organizations, oppose herbicide use along rights-of-way by MassDOT, and ask that MassDOT commit to a no-spray policy for the following reasons:
We urge you to stop spraying starting in 2011 for several reasons:
- Herbicides are harmful to living organisms. Herbicides, like all pesticides, are designed to kill, and they can harm more than just their intended targets. MBTA plans to use glyphosate (Accord, Round Up), imazapyr (Arsenal), metsulfuron methyl (Escort), triclopyr (Garlon 4), sulfometuron methyl (Oust), and fosamine ammonium (Krenite). All of the herbicides intended for use have been linked to negative impacts on human health and/or the environment.
- Glyphosate is one of the most widely used pesticides in the country, and a study in 1999 by the American Cancer Society linked glyphosate exposure to non-Hodgkin Lymphoma.#
- Imazapyr moves readily in soil and can persist in soil for over a year.#
- Metsulforon methyl is classified as highly mobile and can travel through soil with water and enter groundwater. It can also move with runoff and enter surface water.#
- In laboratory tests, triclopyr caused an increase in the incidence of breast cancer and reproductive problems.#
- Enough sulfometuron methyl to kill desirable vegetation can persist in soil for a year after application.#
- Fosamine ammonium has been linked to kidney damage.#
- Pesticide spraying is an environmental justice issue that deserves attention here, since urban communities are often in close proximity to railway tracks. It has been well established that working class communities and communities of color in Massachusetts are disproportionately burdened with environmental toxins due to the unequal distribution of such hazards as toxics waste sites and commercial/industrial polluters. Pesticides may be an additional contributor to the toxic burden and health burden in many of these communities. #
- Non-toxic options are available, including mechanical methods like weed-cutting machines and hand-cutting tools, to adequately control plant overgrowth along rights-of-ways.
We request that MassDOT commit to a no-spray policy on the MBTA. Please contact us at 617 522-0205.
Margaret Connors, Co-Founder, Neighborhood Pesticide Action Committee,
Taryn Hallweaver, Eastern Massachusetts Community Organizer, Toxics Action Center, Sylvia Broude, Organizing Director, Toxics Action Center,
Lizzi Weyant, Staff Attorney, MASSPIRG,
Lee Matsuda, Action for Communities and the Environment (ACE),
Melissa Hoffer, Vice President and Director of Healthy Communities and Environmental Justice Conservation Law Foundation,
Rafael Mares, Staff Attorney, Conservation Law Foundation,
Marsha Cooper, Green Decade - Newton,
Erica Mattison and Rick Reibstein EJ Task Force of the Jewish Alliance for Law and Social Action (JALSA),
Linda Hillyer, Chair of the Multiple Chemical Sensitivity (MCS) Project of Boston Self Help Center
cc John Auerbach, Massachusetts Public Health Commissioner
Jeffrey Sanchez, State Representative
Sonia Chang Diaz, State Senator