October 28, 2005
Friday

The Alaska Inter-Tribal Council (AITC) opposes the issuance of a permit to Klukwan, Inc./Long Island Trust for the aerial application of herbicides on 2,000 acres of Long Island in Southeast Alaska. AITC supports the federally recognized tribes who have passed resolutions that oppose the aerial spraying of herbicides, including Hydaburg Cooperative Association, Organized Village of Kake, Yakutat Tlingit Tribe, Craig Community Association, and others. The State of Alaska must respect the resolutions and authority of the federally recognized tribes in their consistent opposition to the aerial herbicide spraying. We submit this letter to be considered formally and entered into the public record.

Tribes are justifiably concerned that herbicidal chemical applications will have detrimental effects on the health of Alaska Native people who rely on cleat water and the safety of traditional foods. Tribes have a responsibility to pass on to future generations a world with water that is pure to drink, oceans and lakes that are safe for human use and aquatic habitat, and healthy forests that support our Customary and Traditional lifestyle. Aerial spraying of pesticides is counterproductive to promoting such a world. The State of Alaska must defer to the tribes in this matter and respect the concerns and knowledge of the local Native people who use these lands and waters for the traditional harvesting of berries, medicinal plants, fish, and wildlife.

Klukwan, Inc. proposed to spray a chemical mixture of herbicide products, Accord (active ingredient is glyphosate), Arsenal (active ingredient is imazapyr), with two additional chemicals to including In-Place and Competitor. The herbicides glyphosate and imazapyr are associated with a range of adverse health effects. The permit application does not address the potential for additive, cumulative, and synergistic effects of the chemical mixture. The permit application fails to consider the effects of the herbicidal chemical mixture on subsistence foods and the health of Alaska Native people who are dependent on the safety of traditional food. ADEC is relying on EPA s pesticide registration risk assessment process which does not account for the much larger quantities of fish and other subsistence foods that Southeast Alaska Native people consume compared with the general population in the lower-48. Furthermore, aerial spraying of pesticides is inherently inaccurate with a high risk of drift contamination of wetlands, salmon streams, and traditional harvest areas. The drift model is overly simplistic and is not sufficiently predictive given the dynamic weather and mountainous terrain. Therefore, the proposed buffer zones will not ensure protection of salmon-bearing streams, water sources, subsistence use areas, eagle habitat, and other sensitive areas.

As a matter of policy, tribal governments have determined that use and broadcast spraying of herbicides as a silvacultural treatment is detrimental to land, water, air, as well as fish and wildlife that Alaska Native people use in their daily lives. The Alaska Department of Environmental Conservation must deny the permit application of Klukwan, Inc. to aerially spray herbicides. The agency must require the corporation to use non-chemical mechanical alternatives that are both prudent and economical.

If you have concerns about this permit application, please contact Sandra Woods at the DEC. She can be reached at:

E-mail: swoods@dec.state.ak.us (Subject: Klukwan Aerial Permit)

Fax: (907) 269-7600

Mail: ADEC Pesticide Program; Attn: Sandra Woods,
555 Cordova St.
Anchorage, AK 99501

Comments must be received by 5:00 pm Monday, October 31st.

Thank you.

Steve Sumida
Deputy Director
Alaska Inter-Tribal Council
www.aitc.org
Juneau, AK - USA

Related:

Letter by Steve Sumida to Kurt Fredriksson, Commissioner Alaska DEC
Re: Klukwan, Inc. aerial pesticide spraying permit application

 

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