I asked Rep. Mike Prax by email about the “statistically insignificant” comment attributed to him in the Daily News-Miner Sunday: “What do you base your claims about statistical insignificance, as quoted in the News-Miner, on? Please provide the statistics.”

“I suspect you are just passing along something that someone told you. If not, I hope you will clarify this.”

I received a lengthy reply from Prax’s office late Sunday. I’ll have more to say about this in future blog posts, but here’s what he said:

Mr. Cole,

Thank you for asking.

My comments were made in the context of evaluating increased vehicle length as a proximate cause of an accident. That context was not included in the News-Miner’s report.

It was based on the assumption that the vehicles Black Gold is proposing to use are able to stay within their lane while negotiating curves and corners as required by nationally recognized highway geometric design criteria – which DOT told me is – in fact the case. Given that assumption, what I learned from a high school Physics class and personal driving experience is that increasing the distance between the steering axle and the trailing axle reduces the tendency for the back of the trailer to ‘drift’ to the outside of a curve at any given road traction condition and vehicle

Other factors, such as excessive speed and incorrect vehicle loading are much more likely to be the cause of an accident than physical length. Furthermore unsafe – even illegal – driving on the part of private vehicle operators are more often the cause of an accident involving a commercial vehicle.

What the ASAH (Advocates for Safe Alaska Highways) group seems to be focusing on is that a longer vehicle is more difficult to pass - which is true, but the difference between passing a vehicle that is 75’ long and one that is 95’ foot is insignificant in light of the 1000’+ total passing distance required. (If 20’ factors into your decision on whether to pass any vehicle –wait for a safer opportunity.)

(The original email said 195 feet and 175 feet, but I corrected that here for clarification.)

ASAH also alleges that these vehicles will create a more intense ‘white out’ when there is fresh snow on the road. This phenomenon involves so many factors that it is hard to guess what will happen, but I will note that side-dump trailers poke a smaller hole in the air than a 40’ box van, so they will have less tendency to suck snow back into the driving lane at any given speed. My guess is they will create less of a snow blizzard than a typical box van, but the difference will be insignificant from a practical perspective.

ASHA’s focus on vehicle length distracts from the more significant risk caused by the increased amount of truck traffic on the Richardson Highway. But that increase is less in practice than what it seems on the surface because of mitigating factors:

If there are quite a few large trucks, which DOT claims is already the case on the Parks Highway where the total number of trucks per day is already about the same as the total number of trucks might be on the Richardson Highway if Kinross operates at max production; then other drivers are more alert to these trucks than if there are only a few and will adjust accordingly. So the total number of estimated accidents might increase, but the rate of accidents per additional vehicle will decrease significantly; so the total number of accidents won’t increase nearly as much as one who doesn’t follow safety statistics might expect. (Other drivers will be annoyed by the increased traffic, but they are almost as likely to reach their destination without being involved in an accident because they consciously or subconsciously change their driving habits.)

Large Combination Vehicles are more complicated to operate, but more skilled drivers operate these vehicles than those who operate single trailer combos or trucks without trailers. (I learned how to drive a large truck and pull a trailer simply by jumping in and practicing (a commercial license wasn’t required in the ‘70s, but I wouldn’t even consider pulling a double-trailer combination vehicle – nor would anyone in their right mind let me drive one without considerable formal dual instruction.)

Black Gold has purchased purpose-built vehicles with several safety features that are not required by regulation and is implementing additional vehicle/driver monitoring and tracking practices that are not required and not necessarily implemented by other trucking companies.

The drivers will be travelling a familiar route and carrying a relatively consistent load compared to other trucking operations. (Their operating environment could be considered comparable to the difference between a scheduled airline’s operating environment and a commercial air charter operating environment.)

If safety is the consideration, it must also be noted that the highway between Tetlin and Fort Knox poses fewer hazards than the Highway between Fairbanks and Nenana – let alone between Fairbanks and Anchorage. The only exceptionally challenging steep hill and sharp curve hazards between Tetlin and Fort Knox are the Tenderfoot Hill area and the Steese from Pedro Monument to Cleary Summit. It requires no more skill to navigate this route than is does to navigate from Fairbanks to Nenana, Nenana to Healy, or Healy to Wasilla. Furthermore, dealing with the traffic from Wasilla to Anchorage is much more challenging than dealing with the traffic from North Pole through Fairbanks to Fox.

ASAH’s other objection is that Kinross should pay for the additional wear and tear on the roads. (They fail to mention that the Tetlin Tribe – which will be benefitting from the royalty payments – will share in this obligation if their business partners are so obligated.) Admittedly, the cost of maintaining Alaska’s roads is not borne by the users. But the real question is: Why should this project (or the mining industry) be singled out?

From the perspective of the State’s General Fund, the only industries that definitely appear to ‘pay their way’ are oil and gas and international aviation. The Usibelli coal mine, some large metal mines, and some commercial fishing operations might as well; but all others operate at a net loss to the state as near as I have been able to tell. I am happy to work on resolving that problem, but that is a big project and it would be unjust to expect a single company to pay while others similarly situated don’t - if we believe in ‘equal treatment under the law’.

The bottom line is that Kinross has agreed to ‘follow the law’ and is going beyond what is required by the law to reduce the their project’s environmental and safety risk to the public.

I don’t deny that the increased truck traffic increases total accident risk, but it isn’t an ‘unprecedented’ risk when compared to the TAPS construction project - which we somehow survived. Nor is it ‘unprecedented’ in terms of the existing truck traffic currently hauling freight on other Alaskan highways.

The increased truck traffic will be annoying but it hasn’t been established that it will create more annoyance or more public safety risk than we have already agreed – by law – to accept. So it makes no sense to prohibit someone who agrees to operate within the law from using our roadways in order to reduce the risk to others who are less concerned about understanding and obeying traffic laws.

The Environmental Assessment for the project also concluded that hauling the ore to the mill at Fort Knox resulted in less environmental impact than locating the mill at the Manh Choh mine site. Furthermore, air quality models related to PM 2.5 in the Fairbanks area indicate that burning distillate fuel contributes a fairly small part to our fine particulate pollution problem.

So I can find no legally defensible reason to deny them permission to proceed.

We should instead evaluate the potential for future mining development in the interior and start to figure out how to prepare for that in a way that minimizes environmental and societal impact, because the transition from carbon based energy to ‘renewable’ energy will require significantly more metal mining activity than we currently have to endure.

If we don’t want to accommodate the inconvenience of additional mining activity, we owe it to the world to let the mining industry know ahead of time – rather than stopping mining projects as they come along, so mining companies can invest elsewhere to meet the demand to address climate change.

Sincerely,

Rep. Mike Prax

PS.

Here is a link to the NHTSA, Traffic Safety Facts web page. According to Table 4 of that report, Alaska had the lowest number of “Large-Truck Involvement in Fatal Crashes” in 2015. Only 1.1% of total fatal vehicle crashes in Alaska involved large trucks. (I realize that 1 out of 88 is a small statistical sample, so I don’t conclude much from that statistic either – but you asked for statistics.)

Mike

(Note: Regarding the Prax postscript. The Traffic Safety Facts publication is an annual one and the figures for each year vary widely. In 2021, for instance, 8.6 percent of fatal crashes in Alaska involved large trucks.) That is eight of 93 fatal crashes.)

I will post my reply to Prax separately, along with some other comments.)

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