In the State of Minnesota, "each person is entitled by right to the protection,
preservation, and enhancement of air, water, land, and other natural resources located within the state." Minn. Stat. § 116B.01.

To preserve this right, the legislature prohibits conduct that may harm our
natural resources unless the offending actor proves "that there is no feasible and prudent alternative" to the harm, and the harm-causing conduct "is consistent with and reasonably required for promotion of the public health, safety, and welfare." Minn. Stat. § 116B.04(b).

Re: the Wheelock Grotto Project—

For months, the City promised to minimize harm to mature trees by "meandering" sidewalks around the trees or otherwise; in February 2025, the City began claiming that "utility and construction work and/or ... poor health" will require significant removal of trees; in March 2025, the City omitted prior references to "meandering" sidewalks from its written materials, while verbally assuring residents that it was feasible to "swoop" sidewalks around mature trees; and on March 17, 2025, the City marked 70 mature trees for immediate removal, commencing plans to swiftly remove nearly all of the mature trees on Parkview, Ivy, Osage and nearby streets before residents would have an opportunity to question City Council.

As recognized by the State of Minnesota, mature trees provide the following benefits to the plaintiffs and their neighbors: aesthetic pleasure, shade cover, protection against runoff into nearby Como Lake, shelter to vibrant birds and everyday wildlife (and endangered species like the long-eared bat), lower cooling bills, and increased property values.

Tree removal cannot be undone. While new trees can be planted, it takes decades for a sapling to reach maturity - with the beauty, shade cover, and wildlife shelter that a mature tree provides.

We urge the City of Saint Paul to postpone tree removal for the Wheelock Grotto Project until it establishes that “no feasible or prudent alternatives exist” and that the tree removal is consistent with and reasonably required for a legitimate public purpose, as weighed against “the state’s paramount concern” for its natural resources.