In a letter sent this week to the Massachusetts State Pesticide Bureau, the Association to Preserve Cape Cod called on Massachusetts policy makers and Eversource Energy to pursue alternatives to the electric utility’s practice of using herbicides to control vegetation along its power line easements.
The letter was written in response to the release of Eversource’s 2019 yearly operational plan for its vegetation management program, which targets 13 Cape Cod towns—Barnstable, Bourne, Chatham, Dennis, Eastham, Falmouth, Harwich, Mashpee, Orleans, Sandwich, Truro, Wellfleet and Yarmouth—where herbicide spraying is scheduled to take place during this year’s growing season.
In the letter, APCC expressed concern about the potential adverse environmental and human health impacts that could result from the continued use of herbicides near Cape Cod’s sensitive natural resources areas and drinking water supplies. According to Eversource’s plan, herbicides can be applied within 10 feet of surface water bodies or other wetlands, and within 50 feet of private drinking water wells.
Glyphosate, the active ingredient in Rodeo and one of the herbicides included in the list Eversource has indicated it plans to use on the Cape, was identified as a probable human carcinogen by the World Health Organization in 2015. The other herbicides listed by Eversource for use on the Cape have also been associated with some level of health or environmental risk. They include imazapyr, metsulfuron-methyl, triclopyr and fosamine ammonium.
APCC called on Eversource, the State Pesticide Bureau and the Massachusetts Department of Agricultural Resources, which regulates the use of herbicides in the state, to be more responsive to the concerns expressed by the Cape’s elected officials and residents regarding Eversource’s use of herbicides along its rights of way and to work with community leaders on alternative, low-impact options for vegetation management on Cape Cod.
The following is the text of APCC’s letter to the State Pesticide Bureau.
March 7, 2019
Director of Rights-of-Way Programs
Massachusetts State Pesticide Bureau
251 Causeway Street, Suite 500
Boston, MA 02114-2151
RE: Eversource Energy 2019 Yearly Operational Plan for Cape Cod
Dear Mr. Edwards:
The Association to Preserve Cape Cod (APCC) submits the following comments expressing concern regarding Eversource Energy’s 2019 Yearly Operational Plan (YOP) for Cape Cod.
Founded in 1968, APCC is the leading regional non-profit environmental advocacy and education organization on Cape Cod. Supported by thousands of members from every Cape Cod town, APCC’s mission is to promote policies and programs that foster the preservation of the Cape’s natural resources. APCC focuses its efforts on the protection of groundwater, surface water, and wetland resources, preservation of open space, the promotion of responsible, planned growth and the achievement of an environmental ethic.
The YOP submitted by Eversource proposes vegetation control and maintenance using a combination of mechanical vegetation removal and herbicide application on the utility’s rights of way (ROW) on Cape Cod, which for this calendar year includes the towns of Barnstable, Bourne, Chatham, Dennis, Eastham, Falmouth, Harwich, Mashpee, Orleans, Sandwich, Truro, Wellfleet and Yarmouth. The YOP states that herbicides will be applied to control vegetation in most areas along its ROW, including within 10 feet of a surface water body or other wetland, and within 50 feet of a private drinking water well.
As has been pointed out numerous times in public comments submitted over the past several years by APCC, Cape Cod has an abundance of sensitive habitats that support rare plant and animal species. Its sandy soils are highly permeable, allowing contaminants to easily leach through to groundwater. The groundwater is hydrologically connected to the Cape’s many freshwater ponds and wetlands, and is also the source for the region’s private and public drinking water supplies. These fragile resources are found on, under and in close proximity to Eversource’s ROW.
The YOP lists the herbicides Eversource plans to use on Cape Cod as being approved by the Massachusetts Department of Agricultural Resources for use in designated Sensitive Areas. However, in reviewing the list of herbicides Eversource has specifically targeted for Cape Cod, APCC notes that these products—despite their approval for use in “sensitive areas”—have all been linked in varying degrees to human health concerns and/or risks to the environment.
The list includes:
In addition to the above-listed active herbicide products proposed for use, the largely unpublished “inert ingredients” and ingredients used as surfactants for the herbicide products are an unknown risk. According to the National Institute of Environmental Health Science, numerous studies indicate that inert ingredients, which are not labeled and considered proprietary business information, may enhance pesticide toxicity on the nervous system, the cardiovascular system, mitochondria, genetic material and hormone systems. These so-called inert ingredients may in fact be biologically or chemically active. Most of the tests required to register a pesticide are performed with the active ingredient alone, not with every ingredient present in the product.
MDAR’s own publication, “Herbicide Evaluation Technical Update No. 2: List of Approved Surfactants for Use in Sensitive Areas on Rights-of-Way – June 2010,” states: “The review of these compounds (surfactants) is limited by toxicological data gaps, particularly with regard to the endpoint of endocrine disruption. While we would prefer to have more information on toxicity, we believe that the hazards posed to non-target aquatic organisms by these surfactants are limited by a low potential for significant exposure. The modeled results represent the best available information at this time for these compounds which have a limited database of information on toxicity and environmental fate.” (Emphasis added.)
There are too many unknowns associated with the proposed herbicides and their long-term effects on the Cape’s fragile environment and human population. What is known about these products is troubling. If an adverse effect on the Cape’s environment or human health is ever detected that is linked to herbicide use on Eversource’s ROW, that information will have arrived too late to undo the harm that has occurred. Eversource’s continued use of these herbicides as part of its YOP has the potential to adversely affect the Cape’s sensitive habitats and water resources, as well as pose human health risks from exposure to herbicides, and this potential risk is enough to warrant discontinuation of their application above the Cape’s aquifer and in its sensitive habitat areas.
APCC must also point out that the practice of clear-cut mowing, which Eversource has stated is one of its alternative methods to control vegetation, can be devastating to sensitive habitats and rare species when done indiscriminately.
There are other methods of vegetation management that can and should be utilized that will not introduce toxic chemicals to the environment or result in a blanket leveling of all habitats within the ROW.
Manual removal of vegetation is one of those methods. Hand removal of targeted woody vegetation along the ROW has been successfully demonstrated by volunteer groups in several Cape Cod towns. For several years now, the Brewster Conservation Trust and the Harwich Conservation Trust have each conducted vegetation management programs on their respective Brewster and Harwich properties along the ROW. Both organizations have proven that undesirable vegetation can be effectively removed with a small group of volunteers using only hand tools. Their efforts achieved the same objective as Eversource’s Vegetation Management Plan (VMP) and its YOP, but without the risk of herbicides or the destruction of clearcutting. Eversource may view the use of herbicides versus hand removal as a cost-saving business decision, but the health of the Cape’s environment and its citizens should not be compromised based on the company’s bottom line.
APCC urges MDAR and the Massachusetts State Pesticide Bureau to be more responsive to the concerns expressed by the broad spectrum of Cape Cod citizens, elected officials and organizations opposed to the utility’s VMP policies and the recently submitted YOP. MDAR and Eversource should work closely with community leaders to actively seek out viable low-impact options for vegetation management, such as hand removal, that will not place the Cape Cod’s fragile environment at risk.
Andrew Gottlieb Don Keeran
Executive Director Assistant Director
cc: State Senator Julian Cyr
State Senator Viriato deMacedo
State Rep. Sarah Peake
State Rep. Timothy Whelan
State Rep. William Crocker
State Rep. Dylan Fernandes
State Rep. David Vieira
State Rep. Randy Hunt
Secretary Matthew Beaton, Executive Office of Energy and Environmental Affairs
Commissioner Martin Suuberg, Department of Environmental Protection
Barnstable Town Council
Bourne Board of Selectmen
Chatham Board of Selectmen
Dennis Board of Selectmen
Eastham Board of Selectmen
Falmouth Board of Selectmen
Harwich Board of Selectmen
Mashpee Board of Selectmen
Orleans Board of Selectmen
Sandwich Board of Selectmen
Truro Board of Selectmen
Yarmouth Board of Selectmen
William Hayes, Eversource Energy