To the Editor,

I want to thank Mr. Wahl for finally making an effort to communicate with the citizens in his area of authority. His speaking out in public is long overdue. But his commentary is more infuriating than it is enlightening for the informed public.

His attempts to minimize the scenic risk of MnDOT’s slashing the natural veneer from the face of Lake Country Scenic Byway reveals more than his disconnect from the community; it reveals his degree of disconnect from reality. True, Highway 34 will not lose its “designation” as a scenic byway—because MnDOT has control of that process! But the highway will nonetheless lose its natural scenery; MnDOT’s logging is making sure of that.

His gratuitous substitution of the “beauty” of an urban park-like landscape through the Smoky Hills by thinning the forest is an arrogant imposition of his personal views over those of the public. And to forcibly impose his preference is an abuse of government power.

His attempts to congratulate himself on past transportation projects—and to cloak himself and his family in the embrace of the community by his resident longevity—fall flat in face of the obvious.

Few have questioned Mr. Wahl and his staff’s ability to design, build or maintain a safe public driving surface. Indeed, there are many good examples of fine highway engineering throughout his district of which he can rightfully be proud.

But where Mr. Wahl’s expertise is sorely lacking is in community relations and understanding our tourism-based economy and the importance of area’s unique biological diversity.

His commentary may have been intended to repair MnDOT’s severely damaged public image and reclaim lost credibility, but it has accomplished exactly the opposite. Mr. Wahl’s repeated reliance on an isolated but tragic vehicle crash into a tree—which actually occurred outside the 55-foot clear zone—reveals a shameful manipulation of insider-jargon and the public sentiment rather than good safety design.

The unofficial “clear zone” guideline is really only 55 feet from a highway’s centerline, not 65. And to be clear, it is a totally discretionary standard, not a requirement of law. Scenic Byways all over the nation are routinely granted exceptions to this guideline in order to preserve a highway’s scenic, cultural or historic integrity.

Under Mr. Wahl this “safety” setback has suffered “margin-creep,” thus arbitrarily becoming a “clear-zone plus 10 feet or 65 feet. (Note: The tree involved in the crash he cites was in fact 64.5 feet from the center-line.)

All previous District 4 engineers over many decades have exercised prudent discretion by balancing the safety of a narrower “clear zone,” allowing iconic trees and natural forest plant communities including the Lady’s Slippers to thrive there. But Mr. Wahl has arbitrarily upset that balance, placing his own very marginal safety improvement goals over all other community and natural resource values.

Mr. Wahl’s untested theory that shade tree removal can reduce road salt pollution remains just that, a theory and a dubious one at that. With solid scientific research of its own, the Save the Trees Coalition has repeatedly challenged Mr. Wahl to support his theory with empirical evidence. He has not done so—either because he is unable to do so, or is simply unwilling. In any case, the studies MnDOT has supplied do not hold up under close analysis and actually work to disprove his theory. Therefore the forest through the Smoky Hills is being recklessly and irresponsibly subjected to an unwarranted experiment that could easily have been tested without cutting a single tree.

Mr. Wahl’s reference to working with “our agency partners” is offensive in every regard. He has alienated, defied or actually made enemies rather than partners. Area citizens, the Becker County Board, tribal organizations, conservation groups, the Tourism Bureau, a Chamber of Commerce, resort and restaurant owners, editorial boards and now even editorial cartoonists have broadly rejected, even lampooned the logging.

And let’s set the record straight: MnDOT has held one virtual and one in-person “open house,” not to gather input and consider alternatives, but just to convince the public of the superiority and inflexibility of their plans. Open houses are designed to disseminate information rather than receive public input so calling them a public meeting is misleading at best. MnDOT held a sparsely attended virtual open house in January of 2022 well after their tree-cutting plans were firm and then stayed for less than an hour leaving many questions unanswered. The second open house in September of last year was the same; some discussions and arguments, but no reconsiderations that would save the trees. Bids were let three months later. Furthermore, the Save the Trees Coalition, not MnDOT, is the group that held two well attended town-hall style meetings in Osage and Detroit Lakes designed to allow public inquiry and comment but which, it should be noted, MnDOT refused to attend.

In direct rebuttal I can state here unequivocally that MnDOT has not complied with all state and federal environmental laws. 

Environmental law compliance is squarely in my wheelhouse. To avoid deeper third-party scrutiny required by federal law that would have publicly exposed the flaws in this project’s tree-removal design, Mr. Wahl had to certify that no significant public controversy existed. As nearly everyone involved can attest, this certification was and still is grossly false. A scrupulous project designer welcomes objective scrutiny to help assure nothing is overlooked. Not this District Engineer, he has gone to great lengths to avoid it.

And Mr. Wahl is scientifically wrong when he claims selective logging of trees and planting others will increase forest biodiversity while protecting Lady’s Slippers. And he loses all scientific and even common sense credibility when he offers “special consideration” for some Red and White Pine that he will allow to be “preserved” while removing hundreds of other irreplaceable old-growth trees.

MnDOT’s project website even claims the project should receive climate change mitigation credit because younger trees grow faster and therefore will absorb more carbon dioxide from the atmosphere. This “conventional wisdom” notion, often touted by the timber industry for self-serving reasons, has been disproven by peer-reviewed published science. Old-growth forests capture and store far more carbon than clear-cut or thinned forests. Studies have shown that forests often require 40 years or more just to recover pre-logging carbon storage capacity.

MnDOT’s “significant changes” and “scaling back” on the number of trees to be removed were not concessions requested, nor would they have been accepted, by the citizenry. What was discovered is that MnDOT actually jiggered the acreage of forest impacted this way to avoid triggering closer federal (and public) scrutiny. The footprint in the Smoky Hills had to be less than 30 acres of forest cumulatively in order to avoid federal review. By “scaling back” to 100 rather than 250 feet the forest footprint was reduced from over 100 acres to precisely 29.9 acres!

Finally, to state his case, Mr. Wahl now chooses to publish a newspaper commentary that doubles down on MnDOT’s previously-disputed talking points—one that continues to keep the public at arm’s length rather than to engage with his critics in-person for a more robust debate on this controversial project. I believe I speak for many in this community when I once again invite him to have this conversation in an open public forum at a time and place of his choosing.

By Willis Mattison, Osage – Professional Ecologist, Retired MPCA Regional Director and

Advisor/Advocate for the Save the Trees Coalition