Photo above: 30 foot boom sprayer in use at Lyndabury Orchard (taken from ACC meeting on August 10th, 2022)

The Amherst Conservation Commission (ACC) wishes to control invasive and noxious plants such as Asiatic bittersweet and poison ivy on town lands – including those managed by the ACC, Recreation, and Public Works. While this is a laudable goal, part of the management plan includes the broad use of herbicides over many acres of town property and adjacent private properties along the public right-of-way. According to the permit filed with the NH Department of Environmental Services, these herbicides include:

• Rodeo (glyphosate)
• Accord XRT II (glyphosate)
• Escort XP (metsulfuron methyl)
• Polaris (imazapyr)

Most alarmingly, Rodeo and Accord are glyphosate-based products – the same chemical in Roundup. Glyphosate is a highly controversial chemical that has been under intense scrutiny in the United States and internationally. In a 2015 study, the International Agency for Research on Cancer (IARC) found that glyphosate was likely carcinogenic in humans. Currently, both France and Germany are phasing out the use of glyphosate due to health concerns – including a possible link to non-Hodgkin lymphoma. While exposure to metsulfuron methyl and imazapyr do not appear harmful in laboratory animals, long-term affects on human health should be questioned. Just as in the PFAS disaster unfolding in Amherst and elsewhere, we should not wait until everyone has had dangerous levels of exposure to start preventative action.

To be clear, it is not just abutters and visitors to town lands that are at risk. The ACC has been granted a permit to spray herbicides along the right-of-way on these roads:

• Route 101 (Greeley Hwy)
• Route 101A (Milford Street)
• Route 122 (Amherst Street)
• Austin Road
• Boston Post Road
• Broadway
• Camp Road
• Corduroy Road
• Courthouse Road
• Cricket Corner Road
• Dodge Road
• Eaton Road
• Holly Hill Road
• Homestead Road
• Horace Greeley Road
• Lyndeborough Road
• Lynch Farm Road
• Manchester Road
• Merrimack Road
• Nathan Lord Road
• Old Jailhouse Road
• Old Manchester Road
• Old Nashua Road
• Pond Parish Road
• Ponemah Hill Road
• Schoolhouse Road
• Spring Road
• Walnut Hill Road

This means that anyone living along these roads could have herbicides sprayed on their properties without their knowledge or consent.

The risk to residents of Amherst are twofold. The ACC can spray herbicides all the way up to their property line, including right up to the water’s edge of nearby waterways. The state permitting process only considers proximity of public water systems in the approval process. No concern is given to the proximity or depth of nearby private wells. Therefore, with many town residents relying on private wells for their water supply, contamination of the groundwater by these herbicides is of grave concern.

Secondly, visitors to Conservation lands are coming into contact with herbicides without knowing it. Recently, the Amherst Conservation Commission has agreed to increased signage during application, but this will not be enough for families to avoid contact on treated properties. For example, the half-life of glyphosate is between two to 197 days depending on soil conditions.

Finally, as protector of conservation land, the ACC should re-examine the ecological impact their actions are having on the very environment the are attempting to protect.

• In 2015, an EPA analysis found glyphosate usage can adversely impact aquatic plants, herbivorous birds, reptiles, terrestrial amphibians, and terrestrial mammals
• In a 2021 biological evaluation, the EPA concluded that glyphosate “Likely Adversely Affects” 93% of federally listed threatened or endangered species.
• Researchers have found negative associations between glyphosate use and monarch butterfly population size, due to its association with the widespread decline of milkweed.

As a result of ecological concerns, the Center for Biological Diversity and the Center for Food Safety recently petitioned the US Fish and Wildlife Service to stop using agricultural pesticides in National Wildlife Refuges, and concern for insect populations is one of the factors leading to Germany’s opposition to continued glyphosate use.

Other means of invasive-species control exist, such as mowing, mechanical removal, flame or steam weeding, and organic pesticide alternatives. Too often, the ACC has relied on toxic chemical treatment for reasons of cost and convenience. The risks of this approach to residents of Amherst are unacceptable, and the alternatives must be embraced.

We hereby request the following action be taken by the ACC, and the Board of Selectmen that appoint them:

1. Commit to embracing the alternative means of invasive species control listed above, with all other options thoroughly exhausted before any form of non-natural pesticide is considered
2. Stop the abuse of the public right-of-way by committing to not spray pesticides of any kind on private property in Amherst without owner consent
3. Post clear, visible signage about any pesticide treatment on town land – including organic pesticides – for the duration of the time that it takes for the pesticide in question to break down
4. Receive consent from all abutters before any form of pesticide treatment is applied to town lands