Alaska Railroad Herbicide Permit

August 26, 2009

Ms. Stephanie Stewart
ADEC Pesticide Progra
555 Cordova St
Anchorage, AK 99501

Dear Ms. Stewart:

The Resource Development Council of Alaska, Inc. (RDC) is writing to ask the Alaska Department of Environmental Conservation (ADEC) to approve the Alaska Railroad’s application for a permit to use herbicides for vegetation management on track located between Indian and Seward.

RDC is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism, and fisheries industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

The Alaska Railroad is truly an asset in this state, employing over 700 people year-round. Additionally, the Railroad transports over 540,000 passengers and over 6 million tons of freight each year. Much of this freight includes coal, fuel, aggregate, and building materials for projects around the state, making the Railroad a vital service to RDC members.

With approximately 650 miles of mainline and branch track, the Railroad’s ability to maintain safe and reliable conditions is imperative to keep employees and the general public protected during operation. Despite efforts to manage vegetation through non-chemical methods, dangerous growth in the 90-mile stretch between Indian and Seward has led the Federal Railroad Administration (FRA) to demand improvements to the track, or risk it being shut down. In fact, between 1997 and 2008, the FRA issued 947 defects and 74 violations against the Railroad. In June 2009 alone, the FRA issued an additional 171 defects and 47 violations for safety issues and concerns related to vegetation. These violations carry hefty fines and further threats of track closures and speed limits, ultimately affecting the Railroad’s customers. While the FRA acknowledges the Railroad’s efforts to control vegetation without chemicals, the risks of obstruction, derailments, and slip and fall hazards are too great to not require increased vegetation management for continued operation.

Given these recurring warnings and violations, it is imperative the Railroad be permitted to implement an effective vegetation management solution. We support the Alaska Railroad’s proposal to apply a general-use, water safe herbicide combined with nonionic surfactant. This method has been evaluated by a University of Alaska research team and proven to have no adverse effects on humans, fish, or wildlife. These “weed killers” are regulated and approved by other state and federal governments, and their application would be conducted by licensed, experienced contractors under the Railroad’s supervision. Railroad employees and the public would be fully informed of the herbicide use and locations in which it would be applied.

The safe movement of trains is the number one reason to implement an integrated vegetation management program that includes herbicide use. The Railroad has conducted a thorough analysis of all management options, and has presented ADEC with a responsible plan to address the problem. It is for this reason RDC encourages ADEC to approve the Railroad’s application as soon as possible.

Thank you for considering our comments.

Resource Development Council for Alaska, Inc.