Landcare Management Advisory Committee — Portland, ME
Date: 2025-10-02
Time: 12:00

City of Portland
October 2, 2025 LMAC Waiver Committee
Agenda
The LMAC Waiver Committee will conduct this meeting
remotely via Zoom. Allow your computer to install the free
Zoom app to get the best meeting experience. If you are not
able to attend, a recording will be available in the Agenda
Center following the meeting.

Join from PC, Mac, iPad, or Android:
https://portlandmaine-
gov.zoom.us/j/81028005247?pwd=t2sitpPvAhahyo7aydYVJ
NVW04E4aF.1


Thursday, October 2, 2025 at 12:00 PM




 Waiver Committee Deliberation and Decision Regarding Application To Apply Pesticides
1.
 at 400 Woodford St
 a. Application to Request the Use of Fertilizer or Pesticide at 400 Woodford St
 b. Additional narrative and supporting research
 c. Additional photos demonstrating severity of infestation
 d. Aerial view of property
 e. Letter of Support from Neighbor
2. Adjournment




 1

City of Portland
October 2, 2025 LMAC Waiver Committee
Agenda
The LMAC Waiver Committee will conduct this meeting
remotely via Zoom. Allow your computer to install the free
Zoom app to get the best meeting experience. If you are not
able to attend, a recording will be available in the Agenda
Center following the meeting.

Join from PC, Mac, iPad, or Android:
https://portlandmaine-
gov.zoom.us/j/81028005247?pwd=t2sitpPvAhahyo7aydYVJ
NVW04E4aF.1


Thursday, October 2, 2025 at 12:00 PM




 Waiver Committee Deliberation and Decision Regarding Application To Apply Pesticides
1.
 at 400 Woodford St
 a. Application to Request the Use of Fertilizer or Pesticide at 400 Woodford St
 b. Additional narrative and supporting research
 c. Additional photos demonstrating severity of infestation
 d. Aerial view of property
 e. Letter of Support from Neighbor
2. Adjournment




 1

 Page 1
 LANDCARE ORDINANCE WAIVER APPLICATION
 Landcare Management Advisory Committee (LMAC)

APPLICANT INFORMATION

Applicant Name: ______________________________________________________________
 Nan M Solomons


Address: ____________________________________________________________________
 400 Woodford St FL 2


Email Address: _______________________________________________________________
 nan.solomons@gmail.com


Telephone Number: __________________________________________
 6174487702


Submission Date: ___________________________________________
 9/24/25


I am a: ☐ Resident ☐ Landlord ☐ Business ☐ Municipality ☐ Landscape company

Are you a licensed commercial applicator? ☐ Yes ☐ No


REASON FOR REQUESTING THE USE OF A PROHIBITED FERTILIZER OR PESTICIDE:
☐ Is an emergency and threatens the public health and safety
☐ For the control of invasive plants that pose a threat to the environment (For a list of Maine Invasive
Plants visit: http://www.maine.gov/dacf/mnap/features/invasive_plants/invsheets.htm)
☐ Required to protect buildings or structures from damage
☐ Using a synthetic fertilizer on performance turf or for new development, with one or more the following
conditions:
 I. The soil temperature is less than 55 degrees Fahrenheit and reasonable grounds exist to justify
 fertilizer use at that location and at that time;
  II. The turf is experiencing high stress due to high use and must be ready for high performance play
 when the sports season(s) begin; or
 III. A suitable organic product that meets the nutrient needs of the soil as specified in a soil test is
 unavailable.

Making the right pest identification is important and can be difficult. Resources for pest identification are
available at: http://www.maine.gov/dacf/php/gotpests/invasive-pests.htm. NOTE: Applications for
poisonous plants such as poison ivy, pests of significant health importance such as ticks and mosquitos,
and destructive pests such as carpenter ants and termites are exempted under the ordinance. No waiver
is necessary to address these pests.


Please provide a detailed account of the problem you would like to address with the proposed
fertilizer or pesticide application. Include photos of the problem/pest and of the extent of the
problem (this may be number of pests or area covered):
_______________________________________________________________________
 Not enough room to respond to this prompt. Please see Appendix A in the narrative.docx file and photos in the tree pix.docx file

____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________




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What steps did you take to evaluate alternative methods to the proposed fertilizer or pesticide
application, including but not limited to, non-fertilizer/pesticide management tactics, minimum
risk fertilizers or pesticides, non-synthetic fertilizers or pesticides, and selecting the minimum
amount of the least toxic, most effective fertilizer or pesticide necessary.
____________________________________________________________________________________
 Not enough room to respond to this prompt. Please see Appendix B in the narrative.docx file.

____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________


PROJECT INFORMATION
What are you treating? ☐ Turf ☐ Shrubs ☐ Trees ☐ Invasive Weeds

Address of proposed application: _________________________________________________________
 400 Woodford Street and 13 Montrose Ave


Please attach a map of the proposed application area (this may be a sketch, however it should be to
scale and include property boundaries, structures, and water bodies).

Is this application within 75ft. of a waterbody? ☐ Yes ☐ No

Proposed fertilizer or pesticide:
___________________________________________________________________
triclopyr


Amount to be applied: __________________________________________________________________
 As much as needed


Method of application: ☐ Liquid ☐ Granular ☐ Injection/systemic ☐ Cut stem treatment

Proposed timing(s)/frequency of use: ______________________________________________________
 One time this year.


Proposed date of application: ___________________________________________________________
 10/8/25




Please provide a detailed management plan for your proposed application, including how you will
minimize the impact of this application on abutting properties and, to the maximum extent
possible, ensure that the grant of the waiver will not be detrimental to the public’s health, safety or
welfare.
NOTE: the following applications are prohibited:
 ● Broadcast applications: the spreading of pesticides over an entire area
 ● Preemptive applications: the application of pesticides as a measure against something possible,
 anticipated or feared, i.e., as a preventive or deterrent measure

____________________________________________________________________________________
Not enough room to respond to this prompt. Please see Appendix C in the narrative.docx file.

____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________


In order for the waiver to be considered, all of the fields above must be completed. For questions, please
 contact Troy Moon in the Sustainability Office at 207-756-8362.

Completed forms may be emailed to landcare@portlandmaine.gov, or mailed or delivered to City Hall, 389
 Congress Street, Portland, ME 04101.




 Page 3
 Appendix A




A detailed account of the problem. Include photos and extent.

 The problem: My neighbor and I have had an invasion of the tree of heaven in our yards,
 primarily along the property lines. Please see the attached property map to show the
 location of the trees on both properties. Red lines indicate the property lines, yellow
 lines indicate the locations of tree of heaven on my property, and turquoise lines
 indicate the location of tree of heaven on my neighbor’s property. See the file,
 TreePix.docx, which includes photos before the tree was removed, and the current
 state showing the maturity and proliferation of the trees on both properties. I would like
 to draw your attention to the fact that the trees of heaven on my neighbor’s property are
 a full lot’s distance beyond where the tree was cut down on Belfield Street, a mere
 three years prior.

 Mark Reiland, Portland’s arborist, performed a site visit on September 10, 2025, and
 confirmed that the trees followed the root line of the removed tree. He noted that the
 trees are extremely hard to remove completely without the use of herbicide.

 History: In 2022, the City of Portland removed a mature tree of heaven, a highly invasive
 species, from the esplanade [grassy strip between the sidewalk and street] in the
 vicinity of my property line on Belfield Street. This summer, three years after the tree
 was cut down, the city removed the remains of the stump. A damaged tree of heaven
 will send up root suckers for several years (more details can be found in the About tree
 of heaven section below). In both instances of removal, the city did not educate the
 proximal residents about the likelihood of tree suckers appearing and the importance
 of pulling them while in an immature state.

 Unfortunately for my neighbor and me, the city did not follow standard operating
 procedure for removing a mature tree of heaven which is an application of herbicide,
 using the hack and squirt method, to kill the root system and waiting for the roots to die
 before cutting down the tree and removing the stump (https://extension.psu.edu/tree-




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 Appendix A


of-heaven). More root suckers are inevitable in the coming years because of improper
stump removal, and this will add to the current population of trees on our properties.

About tree of heaven: This tree has been categorized as a highly invasive species
according to the maine.gov site. See
https://www.maine.gov/dacf/mnap/features/invasive_plants/invsheets.htm. A female
tree can produce 325,000 seeds per year which can be dispersed via wind to other
areas and root suckers can be found as far as 50’ from the originating trunk
(https://ask.extension.org/kb/faq.php?id=852000). Root suckers can grow up to six
feet per year and can appear over a one to two year period
(https://mdinvasives.org/archive/species/uploadpdf/Tree_of_Heaven_Control_Pannill.
pdf ). Without intervention, it will take very little time for this tree to overtake the
properties at 400 Woodford Street and 13 Montrose Avenue, as well as gaining a
foothold on the adjoining properties.

 o Environmental Damage: The Tree of Heaven releases allelopathic chemicals
 from the bark and leaves into the soil that prevent other plants from growing,
 which stifles the existing plants. On my property, these trees are "choking
 out" valuable fruit trees (pear, cherry and peach) and pollinator plants (bee
 balm, yarrow, comfrey, and goldenrod) which are visited daily by birds, bees,
 and butterflies. The tree is also a preferred host for the invasive spotted
 lanternfly, which also damages a wide variety of plants, including fruit trees,
 by feeding on their sap. This tree’s roots can also cause structural damage
 when it is near a foundation.

 o Public Health Concerns: This tree is a high pollen producer, causing allergies
 and skin irritation. There have also been rare reports of more serious
 conditions, such as myocarditis, linked to tree of heaven exposure.




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 Appendix B


Steps to evaluate alternative methods

 While non-chemical methods are always the preferred course of treatment, the
 number, maturity, and location of the trees on the two properties would require an
 excavator, which would destroy the established gardens and would be quite costly.
 Furthermore, eradication would not be guaranteed given the tenacity of the species.
 Pulling out immature trees by hand and ensuring all root matter was extracted
 would be both inefficient and quite time-consuming. As you can see from the
 pictures in the TreePix.docx file, most trees would not be classified as immature.

 I have discussed my tree problem with two well respected organic landscape
 professionals:

 1. Chip Osborne, founder of Osborne Organics
 (https://osborneorganics.com/), who was recommended by Priscilla Skerry,
 2. Justin Nichols, who is listed on the Maine Natural Areas Program of Non-
 Herbicide or Herbicide-Plus Invasive Plant Control Businesses
 https://www.maine.gov/dacf/mnap/features/invasive_plants/nonherbicide.
 html. Mr. Nichols viewed the property at 400 Woodford Street.

 Both experts agreed that the only way to control and remove the tree of heaven is
 using herbicide, particularly given the number, maturity, and location of the trees
 on the two properties. In addition, my neighbor Rose Carter, whose abutting
 property on 13 Montrose Avenue is also affected, supports the use of herbicide to
 address the problem.

 Given the large number of trees that must be removed, the preferred herbicide is
 triclopyr which is applied to the tree trunk. There are three methods of application
 depending on the size of the tree (https://extension.psu.edu/tree-of-heaven :

 1. Hack and squirt for mature trees where many cuts are made to the tree trunk
 and herbicide is injected into the cuts




 Page 6
 Appendix B


2. Basal bark where the first 12-15 inches of the trunk including the root collar are
 sprayed with herbicide using a low velocity spray
3. Painting the cut stump with herbicide. Painting the cut stump, depending on tree
 size, does not prevent root suckering and is not as effective as the first two
 methods.

It can take two to three years, or more, to eliminate all the root suckers and dormant
seeds produced by the tree. Thus, research is underway to use non-chemical
means to control the species. These initiatives include verticillium wilt fungus,
eriophyid mite, and verticillium nonalfalfae. Unfortunately, these efforts have not
reached the commercialization stage and cannot be considered as an alternative
method to herbicide at present.
https://beyondpesticides.org/dailynewsblog/2021/12/researchers-optimistic-
about-new-biological-control-for-problematic-tree-of-heaven/




 Page 7
 Appendix C


Detailed Management Plan

 Allowing the tree of heaven to proliferate is a threat to Portland’s biodiversity, to the
 environment and to public health. An herbicide is the most effective and efficient
 way to eradicate this highly invasive species (https://extension.psu.edu/tree-of-
 heaven). Triclopyr is an effective herbicide for this tree and causes minimal harm to
 the surrounding vegetation or wildlife
 (https://www.npic.orst.edu/factsheets/triclopyrgen.html ), especially when
 considering the stifling effects of the tree of heaven on the environment. A
 Husqvarna 4-gallon backpack sprayer with a low volume nozzle will be used to
 apply triclopyr, using the basal trunk method (described in Appendix C) to the
 trunks of the tree of heaven. A second application of herbicide may be warranted in
 2026 if more root suckers appear due to the city’s stump removal in 2025. The
 properties are not near waterways or standing water, nor will it be applied in the
 vicinity of food crops or flowers.




 Page 8
Tree of Heaven Images 400 Woodford Street & 13 Montrose Ave




 These pictures were taken in 2022 prior to the
 tree’s removal. Note there is no evidence of
 trees along the property lines, specifically:
 - To the right of the gazebo
 - Behind and to the right of the people
 - Along the fence.




 Page 9
Tree of Heaven Images 400 Woodford Street & 13 Montrose Ave




Examples of on or near the foundation 400 Woodford St




 Page 10
Tree of Heaven Images 400 Woodford Street & 13 Montrose Ave




Property line 400 Woodford St. Note height and maturity.




 Page 11
Tree of Heaven Images 400 Woodford Street & 13 Montrose Ave




Examples of tree of heaven presence on 3 Montrose Ave property




 Page 12
Google Maps https://www.google.com/maps/@43.6695215,-70.2961231,50m/data=!3m1!1e3?authuser=0&...




 Page 13
2 of 2 7/28/2025, 11:38 AM
thm@portlandmaine.gov

Subject: Letter of Support for Removal of Invasive Trees at 400 Woodford Street

Dear Members of the Landcare Management Advisory Committee:

Nan Solomons (my neighbor residing at 400 Woodford Street) informed me that she will be
going before your committee this Wednesday, August 27, 2025, as part of a waiver process
to use herbicide to remove the tree of heaven (Ailanthus altissima) trees on her property. I
am writing in support of her removal of the trees. Given the invasive nature of these trees, I
suggest that she also have the 15 or so saplings on my property at 13 Montrose Avenue
treated as well. These saplings are on or near our shared property line.

I hope that you will allow the addition of these trees as part of her application. I’m over 90
and reside in an assisted living facility and am physically and logistically unable to manage
this task. I am grateful that she is willing to coordinate the removal of these adjacent trees.

Thank you for your time and consideration of this important matter.

Sincerely,

[Your Signature]

Rose Carter




 Page 14