3/16/2026 - Requested by LID's to be part of Official Minutes - City Council - Regular - Minutes Subject: Important Context for Cities Regarding Lake Improvement Districts(LIDS)on Lake
Minnetonka
Mayor, Council Members, and City Staff,
We are writing to share some firsthand experience and lessons learned regarding Lake Improvement
Districts (LIDS)on Lake Minnetonka.This comes from months of direct involvement, public meetings,
agency correspondence, and community outreach related to proposed LIDS on Minnetonka bays.
Our goal is simple,to make sure city leaders have the full picture before being asked to approve or
administer a LID.
LIDs are not a small or temporary decision. Once formed,they create long-term consequences for
residents,cities, and the lake itself.
Here are several points every city should understand up front.
1. LIDs do not represent all constituents
A LID can be formed by petition with a simple majority of a defined group, but its impacts extend
well beyond that group. Many residents who oppose a LID still end up taxed, bound by its decisions,
and exposed to its risks. In reality, LIDS often divide communities rather than unify them.
2. The petition process lacks transparency and informed consent
The petition process to form a LID does not require that any of the information outlined below be
disclosed to residents before they are asked to sign.There is no requirement to explain the long-
term tax implications, liability transfer, environmental risks, chemical use,or the city's
administrative role. In practice,these facts are rarely shared during signature gathering.As a result,
many residents sign petitions without fully understanding what they are agreeing to.
3. Demonstrate local need and avoid duplication
Minnesota Rule 6115.0960, subpart 2 requires that a LID request demonstrates a clear local need
that cannot reasonably be addressed through existing voluntary lake associations or existing state,
watershed,or regional lake management entities. Lake Minnetonka is already managed by the
LMCD, DNR, MCWD, Lake Associations, and other agencies with broader authority, resources,
experience, and expertise. Creating a new bay-level taxing district without first demonstrating that
existing structures are insufficient undermines the intent of the rule and risks duplicating efforts
rather than solving root problems. Cities should require clear evidence that a LID is necessary,
appropriate,and the only viable option before granting approval.
4. City involvement where the city has no jurisdiction
Lake Minnetonka is a state-owned public water body managed by the LMCD and the DNR, not
individual cities.Yet LIDs place cities in the position of collecting taxes, managing funds, assuming
administrative responsibility for projects that occur outside city jurisdiction. Cities should ask
themselves whether it makes sense to devote staff time, legal resources,and administrative
oversight to a body whose work is not a municipal responsibility.
The city's responsibility stops at the shoreline)
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5. Precedent matters
Approving one LID opens the door for many more. Once cities signal support,other bays are
encouraged to follow the same path.This can quickly multiply administrative burden,taxation, and
risk across an entire city.
6. Liability shifts away from the State
This is one of the most misunderstood aspects of LIDS. Once a LID is formed, liability for its actions
shifts away from the State of Minnesota and the DNR and onto the LID itself,the city,and the taxed
property owners. If a LID is ever dissolved, remaining liability falls to the city. See DNR rule
6115.0980.
That is a significant risk for any municipality.
7. Permanent taxation with limited participation
Once approved, a LID creates a permanent taxing structure. While increases technically require a
public vote, real-world participation is often very low. Major financial decisions can be made with
only a small fraction of affected property owners present.
8. Special Taxing District
When selling real estate in Minnesota,you generally must disclose whether the property is subject
to an HOA(homeowners' association), CIC(common interest community), or similar community
governance and any related obligations,and you must disclose material facts about special taxing
districts such as a LID or assessments that affect the buyer's use, enjoyment,or costs associated
with the property.
9. Chemical herbicides become the default
In nearly every case we've examined, LIDs quickly become a vehicle for expanded chemical herbicide
use. Products such as Diquat, Fluridone, and ProcellaCOR are commonly used.
These chemicals are pollutants. Some are now classified as PFAS compounds by the Minnesota
Department of Agriculture and are already scheduled for phase-out or bans.There is little long-term
data on cumulative impacts in shallow bays where families swim,fish, and recreate.
10. Habitat loss and unintended consequences
Chemical treatments do not remove plants,they kill them in place.That leads to decomposition,
nutrient release, lower oxygen levels, algae growth, and loss of fish habitat. Native weeds are critical
for spawning,cover and forage, and water clarity. Once lost,they are difficult to restore. It's better
to have invasive vegetation than no vegetation at all!
This has direct impacts on fishing,wildlife, and overall lake health.
Local MN DNR fishery management has had limited to no involvement in herbicide permitting
decisions for lake Minnetonka to date.A lack of inter-department coordination and communication
within the MN DNR to make fully informed habitat management decisions has contributed to the
current over treatment situation and is beginning to be addressed.The Lake is a top 10 Bass Lake in
the Central US, excellent panfish and walleye fishery, and the most important Muskie fishery in the
Southern half of the state. Lake Minnetonka is a Key piece in the$6.5 billion dollar MN fishing
industry.That high status is entirely dependent on fish habitat; meaning underwater vegetation for
oxygen production, cover for prey species and small fish, and spawning habitat is essential.
11. LIDs often lack clear plans or measurable outcomes
Many LID proposals lack baseline data, phosphorus budgets, monitoring plans,or defined success
metrics. Without baseline data,there is no way to know whether treatments are helping or making
conditions worse,yet taxation continues regardless of results.What we do know is that controlling
phosphorus at the watershed should be the highest priority. If phosphorus is not controlled,
vegetation and algae will rebound because high phosphorus is causing most of the vegetation and
clarity problems we see in the lake today.
12. There are safer alternatives
Mechanical weed removal,diver-assisted suction harvesting(DASH), shoreline buffers, reduced lawn
fertilization,education,and better stormwater practices are proven, lower-risk approaches that do
not require creating a new taxing district or expanding chemical use.
In closing
Cities should proceed with extreme caution before supporting any LID on Lake Minnetonka. Granting
taxing authority and assuming administrative responsibility for projects on a state-owned public lake
carries long-term financial, legal, and environmental consequences.
Once formed,a LID is difficult to reverse.The taxation is permanent.The liability is real.The
environmental impacts can be irreversible.
Before any city agrees to sponsor or administer a LID, it should require full transparency, demonstrated
statutory necessity, measurable environmental objectives,and clear evidence that existing lake
associations and governing agencies are insufficient to address the concerns being raised.
Lake Minnetonka is one of Minnesota's most valuable natural resources. Decisions that affect its long-
term health, habitat, and public use deserve careful scrutiny and broad consensus, not narrow petition
thresholds.
We respectfully urge you to evaluate any future LID proposal with these considerations in mind.
We are happy to provide documentation, agency correspondence, meeting records, and additional
information upon request.
Thank you for your service to your community and for your thoughtful consideration of this matter.
Respectfully,
The Lake Minnetonka Advocates Team
Resources and more information:
PFAS: Pesticide Active and Inert Ingredients
https://www.mda.state.mn.us/environment-sustainability/pfas-pesticide-active-inert-ingredients
MN Department of Agriculture PFAS in Pesticides Final Report 02/01/2025
https://www.Irl.mn.gov/docs/2025/mandated/250302.pdf
PFAS ProcellaCOR in Lake George
https://Iakegeorgeassociation.org/sites/default/files/2024-02/LGA-ProcellaCOR-Position-Paper.pdf
Be careful what you wish for when managing aquatic weeds
https://www.canr.msu.edu/news/be careful what you wish for when managing aquatic weeds
Controlling Phosphorus Concentrations and its effects
https://files.dnr.state.mn.us/eii/factsheets/phosphorus concentration.pdf
Minnehaha Creek Watershed District Water Quality
https://minnehahacreek.org/explore/water-quality/
Diquat Chemical Fact Sheet
NOAA: https://www.noaa.gov/sites/default/files/legacy/document/2020/Oct/07354626838.pdf
Diquat Safety Sheet:
https://www.apparentag.com.au/documents/msds/83557 APPARENT DIQUAT 200 MSDS 1.pdf
This is ProcellaCOR(Florpyrauxifen-benzyl):
https://Pubchem.ncbi.nlm.nih.gov/compound/Florpyrauxifen-benzyl
https://www.mda.state.mn.us/sites/default/files/inline-files/Florpyrauxifen-benzVl.pdf
APA should pause ProcellaCOR permits to assess herbicide's safety(based on Minnesota MDA info)
https://www.adirondackexplorer.org/almanack-commentary/apa-should-pause-procellacor-permits-to-
assess-herbicides-safety/
Test your blood for Per-and Polyfluoroalkyl substances(PFAS)
https://www.health.state.mn.us/communities/environment/hazardous/docs/pfas/indbitest.pdf
How herbicide treatments in Lake Ellwood Wisconsin caused the fish population to crash
https://www.in-fisherman.com/editorial/weed-removal-bass-population-removal/lSS597
Phasing out nonessential use of PFAS chemicals
https://www.pca.state.mn.us/sites/default/files/gp4-03.pdf
Impaired waters, E.coli, and drainage of Lake Minnetonka (graphic 1-2).Too much total phosphorus
https://www.pca.state.mn.us/sites/default/files/wq-iw11-17e.pdf
The fight against forever chemicals (U of M)
https://twin-cities.umn.edu/news-events/fight-against-forever-chemicals