August 3, 2006
Ms. Sandra M. Woods
Pesticide Program
Alaska Department of Environmental Conservation
555 Cordova Street
Anchorage, Alaska 99501
Re: Alaska Railroad permit to apply chemical weed control
Dear Ms. Woods:
On behalf of the Resource Development Council for Alaska, Inc. (RDC), I am writing to ask the Department of Environmental Conservation (DEC) to approve the Alaska Railroad’s permit to use chemical weed control on its operating lands.
RDC is a private, non-profit business association comprised of individuals and leading companies from each of Alaska’s basic industry sectors — oil and gas, mining, tourism, fishing and forest products. RDC’s membership also includes Alaska Native corporations, local communities, transportation and construction companies, organized labor and a wide variety of industry-support firms. For more than thirty years these diverse interests have worked through RDC to advocate for the responsible development of Alaska’s natural resources.
The Alaska Railroad is one of the state’s most important economic engines, annually transporting approximately 500,000 passengers and 8 million tons of freight, including oil and gas, coal and aggregate. The Railroad’s ability to maintain safe, reliable operating conditions is critical not only to the state’s economy, but also to ensure both the Railroad’s employees and the public at-large are kept out of harm’s way. With 500 miles of mainline and branch track and 100 miles of yard track, it is imperative the Railroad implement an effective, long-lasting vegetation control solution.
Unchecked vegetation obstructs site lines at crossings, creates slip and fall hazards, and increases the risk of derailment by degrading crossties, rail fasteners and subgrade. Over the past twenty years the Railroad has employed a number of non-chemical methods to control weeds along its track, however, none of these methods has proved effective in addressing the problem of vegetation growth between the track and to the end of the ties. The Railroad’s proposal
to use a mix of mechanized and chemical tools to control vegetation is consistent with industry practices throughout North America and warrants the DEC’s approval.
RDC understands the proposed activity carries with it some risk and that reaction from railbelt communities has been mixed. Nevertheless, in our view the risks associated with a derailment or employee injury due to unchecked vegetation far outweigh those associated with the regulated application of approved chemical weed control products. The Railroad has conducted a thorough analysis of the options and presented DEC with a responsible plan to address its vegetation problem. RDC encourages DEC to approve the Railroad’s application as soon as possible.
Thank you for considering our comments on this important issue. Please contact me if you have questions, or if I can provide additional information.
Sincerely,
RESOURCE DEVELOPMENT COUNCIL
for Alaska, Inc.
