Northeastern Minnesotans for Wilderness, in addition to being lead organization and founder of the Campaign to Save the Boundary Waters, also conducts other work, including data collection and scientific assessments, and preparation and submittal of technical comment letters on projects being proposed or reviewed by state and federal agencies. Three recent examples of NMW's work are described below.
2020-2021 Sulfate Sampling Effort for Birch Lake
Northeastern Minnesotans for Wilderness (NMW) manages and conducts a monitoring program including water sample collection and testing. On June 28, 2021, NMW completed a report presenting NMW’s water quality data for the years 2020 and 2021 relevant to Birch Lake and sulfate (SO4), the pollutant that is known to damage wild rice and to fuel the production of methyl-mercury, the form of mercury that bioaccumulates in insects, fish, and species higher in the food web including humans, bats, river otters, eagles, etc.
In total, the results from 104 water quality samples show significant impairment in Birch Lake. NMW sent its report to the U.S. Environmental Protection Agency during a federal comment period regarding Minnesota wild rice waters impaired for sulfate.
The Minnesota Pollution Control Agency (MPCA) is responsible for listing waters that do not meet federal water quality standards for pollutants, including sulfate, but the MPCA has never listed wild rice water as impaired for sulfate, though it is manifest that many waters are impaired. In 2015 the Minnesota Legislature passed a law containing a provision barring the MPCA from discharging its duties with respect to sulfate under the federal Clean Water Act. The U.S. EPA announced in the spring of 2021 that it would step in to carry out the duties MPCA would not, i.e., list wild rice waters in Minnesota as impaired for sulfate. The EPA invited the public to submit comments including data that might help EPA determine which Minnesota wild rice waters should be listed as impaired.
NMW’s June 28, 2021 report presented the sulfate concentrations in 104 water samples collected by NMW as determined by a qualified testing laboratory. Nearly all of the samples show sulfate concentrations above 10 mg/L, the state and federal water quality standard for wild rice waters in Minnesota.
* * *
NMW works with strong allies and partner organizations to accomplish shared goals. NMW thanks our partners Center for Biological Diversity and the Izaak Walton League - Minnesota Division, and our ally WaterLegacy, for their excellent work and help in preparing and submitting with NMW the two documents described below.
WaterLegacy & NMW comment letter to U.S. EPA
On June 30, 2021, NMW joined WaterLegacy in submitting a comment letter to the U.S. EPA presenting water quality data to the EPA, including NMW’s report “2020-2021 Sulfate Sampling Effort for Birch Lake,” and making the case that Birch Lake and a number of other wild rice waters should be listed as impaired for sulfate.
NMW-Center for Biological Diversity-Izaak Walton League Minnesota Division comment letter to the U.S. Forest Service on the Tofte Landscape Project Draft Environmental Assessment
On July 16, 2021, NMW, the Center for Biological Diversity, and the Minnesota Division of the Izaak Walton League of America submitted detailed comments to the U.S. Forest Service on the Tofte Landscape Project, an extremely large, 15-year logging and forest management license which requires the public to submit actionable comments before details are final on what exactly the U.S. Forest Service is proposing to log; by the time final details are available, the opportunity to submit actionable comments has passed. Among the comments made in the comment letter is that this scheme violates the National Environmental Policy Act.