MNNPS Comments on Revised Sand Dunes State Forest Operational Plan

In a letter to the MN DNR, MNNPS joins the Wildlife Society and Friends of MN SNAs in commenting on proposed land management changes in the Sand Dunes State Forest:

We, the undersigned organizations and the members we represent, provide the following comments during the open public comment period for the “Revised Operational Plan for the Management of Sand Dunes State Forest, 2013-2022.”

Vegetation Management Action Plan (Part A)

  • We support the decision to adopt a shorter timeframe to guide management decisions in the SDSF. We feel the plan, while doing a good job in accommodating local concerns, has the potential to set a statewide precedent; restricting what is best in the interest of the state’s resources when bowing to the “not in my backyard” pressure applied by adjacent landowners. We can’t forget that the SDSF is a state property that has been present many years before most of the residents in the area.
  • The proposed Final Harvest (clearcut) of 236 acres of oak woodland within DNR identified High Conservation Value Forest will adversely affect those features DNR identified as having High Conservation Value. An alternative prescription is advised to balance timber harvest and stand regeneration goals with those of the High Conservation Value Forest. A suggested alternative is to limit final oak-stand harvest to patches 10 acres or smaller, and leave at least 660’ buffer between neighboring patches.
  • None of the Species in Greatest Conservation Need found within SDSF require pine stands to complete their lifecycle. Specify within the plan that timber stands located within DNR identified High Conservation Value Forest not be replanted with pine, and that pine regeneration and spread be controlled in these areas.
  • Many species of plant and wildlife may be adversely affected by summer timber harvest practices. In addition, unfrozen ground is more susceptible to erosion by logging equipment. The Plan should state that timber stands located within DNR identified High Conservation Value Forest first be offered for sale with a winter harvest (December 1 to March 1, inclusive) restriction. If these stands go unsold with the harvest timing restriction, work with biologists/botanists from the Division of Ecological and Water Resources to develop an alternative prescription to allow summer harvest. Contracts should clearly identify measures to avoid and minimize impacts to features having High Conservation Value, and should include penalties for violating avoidance and minimization measures.
  • Site A on Map 10: Modify boundary to encompass the entire area of oak savanna that was treated via a commercial timber sale in the last 36 months to avoid further fragmentation within the site by burn breaks, etc. The entire area should be evaluated for site maintenance and treated to control invasive species and enhance habitat for Species in Greatest Conservation Need.

Recreation Action Plan (Part B)

  • More clearly identify Nature Viewing as an important recreational activity within the forest, and discuss current trends and economic benefits in Minnesota and beyond.
  • Develop periodic “educational tours” with emphasis on rare features in the SDSF, to be conducted annually to introduce new residents and remind visitors of these resources. The signatories to this letter could be contacted to assist DNR in such endeavors, if needed.
  • Identify the Horse Campground as an area requiring maintenance action to enhance habitat (i.e., invasive species control, reseed with native grasses and forbs) and to improve aesthetics. In addition to a popular recreational destination, this area is home to several Species in Greatest Conservation Need that may benefit from habitat enhancement.
  • The trail system within SDSF is already quite extensive. Any proposed expansion of the trail system within SDSF should undergo careful review to avoid and minimize adverse affects to rare features and other sensitive areas.
  • Implement additional signage explaining the value of the rare features within the SDSF at equestrian trailheads, campgrounds, and at locations where trails pass adjacent sensitive habitats. Signage is also important where trails enter from adjacent residential areas, since many users enter from these locations.
  • We recommend DNR monitor trail-use at, and adjacent to, sensitive areas and to identify steps to address trail usage that adversely affects sensitive areas.

Permanent School Trust Lands (Part C)

  • Explicitly commit that no additional Trust lands be added to SDSF, given the current challenges of managing SDSF for its DNR identified High Conservation Values while meeting the fiduciary Trust responsibility.
  • Clearly identify a plan to compensate and/or buyout the Trust lands located within the forest.

Forest Roads (Part D)

  • Many Species in Greatest Conservation Need occur in, or immediately adjacent to, roadsides within SDSF. For existing Orrock Township roads within SDSF that lack easements, it is recommended that DNR provide an easement to the Township for only the driving surface of the roadway and the first eight feet of the roadside (inslope). This will minimize adverse effects to rare plants and wildlife inhabiting ditch bottoms and backslopes, and provide the Township the ability to maintain a safe driving surface.
  • Specify that mowing roadsides with easements shall follow the state mowing law. As required by state law, require that reseeding of disturbed soils shall use seed mixes from native species of a local ecotype to Sherburne or Benton County.
  • To reduce traffic volume and speed, identify a plan to work with the Township to reclaim portions of 253rd Ave. NW as a gravel forest road (between 180th and the existing gravel to the east). Reducing traffic speed and volume will increase recreational forest-user safety, and reduces the likelihood of wildlife-vehicle collisions.
  • Post a sign at the entrance to SDSF on 253rd Ave. NW that the road is closed to through traffic to reduce wildlife-vehicle collisions.

Additional Comments

  • The Rusty-patched Bumble Bee (Bombus affinis), a species recently listed as ”endangered” under the federal Endangered Species Act (ESA), has recently been found within Sand Dunes State Forest. The Operational Plan should include a process through which this species receives the appropriate protection under the ESA.
  • It is important to ensure statewide stakeholders as well as local constituencies continue to be informed when making decisions regarding public use and management of the lands and resources within the SDSF.

We appreciate DNR’s willingness to engage citizens of Minnesota in the development of the Revised Operational Plan for the Management of Sand Dunes State Forest, and appreciate your consideration of the comments and recommendations included here.


Kyle Arola
Vice President
Minnesota Chapter, The Wildlife Society

Thomas E. Casey
Board Member and Conservation Committee Chair
Minnesota Native Plant Society, Inc.

Robert Djupstrom
Secretary, Board of Directors
Friends of Minnesota Scientific and Natural Areas, Inc.

MNNPS Opposes SNA Land Use Proposals

On June 14, hearings were held regarding proposed land use changes on existing SNAs. Board Member Tom Casey, representing MNNPS, testified at the hearings, opposing these proposals.

Mississippi River Islands SNA

Proposal: vacate the Dimmick Island portion of the Mississippi River Islands SNA and transfer control to MN Parks and Trails for use as campgrounds.


The proposed vacation of a portion Dimmick Island to allow an overnight campsite and other activities:

  1. Will cause significant adverse impacts to the remainder of the SNA and surrounding waters;
  2. Sets an adverse precedent and perpetuates an administrative mistake made after the SNA was designated;
  3. Is not required by a deed “condition”;
  4. Is contrary to the purposes and administrative requirements outlined in Minn. Stat. 86A.05; and
  5. Violates the requirements of the Minnesota Environmental Policy Act.

Download the Letter to DNR (6-19-17) describing the issues in further detail.

Unca Dunes SNA

Proposal: continue allowing snowmobiles and horses.


The proposal to allow horses and snowmobiles, along with the continued use of dogs:

  1. Will cause significant adverse impacts to the remainder of the SNA
  2. Rewards illegal and incompatible activities and perpetuates historic abuses;
  3. Is contrary to the purposes and administrative requirements outlined in Minn. Stat. 86A.05; and
  4. Violates the Minnesota Environmental Policy Act (Minn. Stat. 116D).

Download the Letter to DNR – Uncas Dunes SNA (6-19-17) describing the issues in further detail.


Legislative Wrap-Up 2017


This legislative session failed to do more to protect the resources that Minnesotans value. Download the full MEP Legislative Wrap-Up 2017.

Dozens of detrimental provisions were advanced. Through a tremendous effort by citizens across the state, many were dropped. But others became law. The legislature also missed opportunities to protect pollinators, invest in water protecting crop research, and adequately fund transit and transportation.


Minnesota Environmental Partnership (MEP) priorities for the 2017 legislature included:

  • Forever Green: Provide long-term funding to the University of Minnesota.
  • Protecting Pollinators: Support the MN Department of Agriculture’s goals
  • Transportation: Pass balanced, comprehensive funding that increases long-term state-wide investment in all modes of transportation.
  • Capital Bonding: Funding for clean-up St. Louis Estuary Area of Concern, modernize aging drinking and waste water systems, and the Conservation Reserve Easement Program


Numerous proposals passed and will move Minnesota backwards, while many other harmful proposals were approved by either the House or Senate, but did NOT become law; MEP and member organizations – working with citizens from across the state — successfully blocked these proposals.

Download the full MEP Legislative Wrap-Up 2017.

Governor Dayton Signs Omnibus Environment Bill SF844

Governor Dayton has signed Environment and Natural Resources Omnibus Bill SF844. The Governor Signing Statement (5-30-17), while raising some concerns, makes no mention of calcareous fens or lead shot.  MNNPS with the Minnesota Environmental Partnership (MEP) has requested the governor now take certain actions regarding these and other issues of concern (see MEP suggested signing actions (5-27-17)). MNNPS encourages members and other concerned citizens to contact the governor’s office and voice support for these actions.

MNNPS Joins MEP in opposition of Environmental Omnibus Bill SF844

The Minnesota Native Plant Society signed a joint letter from the Minnesota Environmental Partnership (MEP) opposing SF844 (“Environment and Natural Resources Omnibus Bill”).

This bill is opposed by members of the MEP because it contains many detrimental provisions that will defund programs, weaken protections, limit public participation, and subvert municipal efforts to move forward.

  • Cuts $22 million in operational funding to local Soil and Water Conservation districts resulting in a raid on the Clean Water Fund.
  • Limits citizen rights based on property ownership.
  • Jeopardizes rare calcareous fens.
  • Removes the PCA requirement to adopt air quality standards and environmental review standards for frac sand operations.
  • Begins the permit review process before the evaluation of environmental impact data is complete.
  • Allows corporations to prepare their own draft Environmental Impact Statement.
  • Allows permit applicants to buy their way into an expedited permit.
  • Interferes with science-based forest management at Sand Dunes State Forest.
  • Places a 2-year prohibition on the adoption of rules limiting lead shot.
  • Delays actions to clean-up polluted water.

The Minnesota Native Plant Society joins 25 other organizations in urging Governor Dayton to veto this bill and we encourage MNNPS members and other concerned citizens to contact the governor’s office and voice your opposition as well.

MNNPS Joins MEP in opposition of Jobs/Energy Bill SF1456

The Minnesota Native Plant Society signed a joint letter from the Minnesota Environmental Partnership (MEP) opposing SF1456 (“Jobs Growth and Energy Affordability Bill”).

This bill is opposed by members of the MEP because it fails to either grow jobs or makes energy affordable, but moves Minnesota backward on both points and prevents future progress.

  • Prohibiting local governments from banning plastic bags
  • Eliminates Public Utilities Commission (PUC) safeguards from price gauging by utilities serving rural residents who want to use solar or wind power.
  • Enables Xcel to use $54 million in Renewable Development Fund money to buyout biomass and poultry power supply contracts.
  • Weakens 1.5% Solar Energy Standard for medium sized utilities.
  • Exempts small utilities from participating in energy savings and efficiency programs.
  • Eliminates the popular Roof-top/ Made in Minnesota Solar rebate program.
  • Repeals Minnesota’s goal, framework, and planning strategy for a 100% renewable energy future.

The Minnesota Native Plant Society joins 25 other organizations in urging Governor Dayton to veto this bill and we encourage MNNPS members and other concerned citizens to contact the governor’s office and voice your opposition as well.

LCCMR Bill – HF 1265 (SF 550) – SNA and Prairie Program Slashed!

This Monday, the House Ways and Means Committee voted to adopt HF 1265 (the LCCMR bill), with the following amendments:

The A-11 amendment adds back the LCCMR recommendations for a wolf re-colonization assessment project, an acquisition to Minneopa State Park (to allow more acreage for a bison herd), a carp program, and a Metropolitan Regional Park acquisition.  Adopted by unanimous voice vote. (See attachment.)

The A-12 amendment adds language about no-net gain for counties situated in whole or in part north of Highway 2. (See attachment.) There was much discussion by committee members on the no-net gain language. Bob Meier (DNR lobbyist) explained the DNR’s concerns.  Notably, Rep. Urdahl (Republican) spoke against the amendment, citing a need to support the intent of Minnesotans who voted for a constitutional amendment to establish the environment and natural resources trust fund. Rep. Urdahl also read a letter from a constituent, who was angry about the no-net gain proposal. Adopted by a divided voice vote.

LCCMR Vice-Chair Nancy Gibson (a Governor Pawlenty appointee) testified in support of the LCCMR’s recommendations. Ms. Gibson asked to reinstate all deleted projects. (See attachment.)

Rep. Frank Hornstein (DFL) was the only committee member to point out that many of the deleted projects pertain to climate change and solar energy.

HF 1265 now goes to the House floor for a vote by the entire body.

I have also attached a 5-page spreadsheet (provided to the Ways and Means Committee).  I have added stars after the deleted projects. (After I scanned this document, note that I missed placing a star after the “Mississippi River Habitat Restoration Planning at Halls Island.”)

Of particular note is the deletion of LCCMR’s recommendation of $4.5 million for the SNA program and $3.5 million for “Native Prairie Stewardship and Prairie Bank Acquisition.”

I encourage everyone to voice their concerns by contacting their own Representative.

The companion bill is Senate File 550, which is currently in the Senate Finance Committee.  The Senate bill retains the LCCMR recommendations of $4.5 million for the SNA program and $3.5 million Native Prairie Stewardship and Prairie Bank Acquisition. I recommend that everyone contact their own Senator and the Senators on the Finance Committee and request that they retain the LCCMR’s recommendations.

In my opinion, the most important contact is Governor Dayton. Very soon, this bill will pass the legislature with many unacceptable provisions.  Therefore, please call and/or write to Governor Dayton and ask him to veto the bill if the LCCMR recommendations are not followed.

Thank you for your interest.  Please contact me any time if you have questions or comments.

Best Wishes,

Tom Casey
tom.casey AT


MNNPS Joins the Minnesota Environmental Partnership in Opposition of SF1087

The Minnesota Native Plant Society signed a joint letter from the Minnesota Environmental Partnership (MEP) opposing SF1087 (“Environmental Review Rollbacks and EQB Elimination Bill”).

This bill is opposed by members of the MEP because it rolls back and weakens Minnesota’s bedrock environmental laws, such as:

  • A provision requiring draft permits to be issued in 150 days, a “one size fits all” deadline for which no justification has been given. Note that agencies are issuing over 90 percent of all permits within the timelines set by the Legislature in previous streamlining bills.
  • A provision that allows private companies to draft environmental review documents, which will remove accountability and transparency. If an EIS is written by a private party rather than a government entity, the public will not have access to the documents relied upon for the EIS.
  • A change in the permit to mine statute that removes the option of a contested case hearing, leaving the Court of Appeals as the only choice for those raising issues about a permit to mine.
  • The complete elimination of the Environmental Quality Board, which works across agency silos to solve complex environmental problems such as frac sand mining, pollinator protection, and water sustainability. No credible reason has been given to abolish the EQB.

MNNPS joins 25 other organizations in opposing this legislation.