Milwaukee Mayor Tom Barrett and Ald. Michael Murphy, the Common Council's most senior member and resident water expert, have sent the Southeastern Wisconsin Regional Planning Commission lengthy comments on the SEWRPC water supply plan.
That plan recommends diverting Lake Michigan water to the City of Waukesha, which, should it occur, would be the first allowed outside of the Great Lakes basin under the just-completed, eight-state Great Lakes Compact agreement.
Among other things, the Milwaukee officials reach this conclusion:
...the full cost of providing water is woefully underestimated. While the Plan does a good job of standardizing regional information, it does not fully reflect the full cost of improvements to Milwaukee’s system that would be necessary to supply water to the additional communities. Estimating these costs will require a better understanding of Milwaukee’s existing water system. The current Plan understates the full costs associated with serving suburban communities with Milwaukee Water Works water.Barrett and Murphy suggest that SEWRPC delay the study's recommendations' approval and take more time to make the study complete, and more authoritative, concluding that:
The water study's recommendations are based on an inadequate, regional master land use plan; omit reasonable alternatives from consideration; do not incorporate valid growth data and scenarios; leave out levels of environmental costs and - - significantly - - jump the gun, twice because; 1) there is no water crisis driving quick approval of the SEWRPC study, and 2) there are no Department of Natural Resources rules yet in place to handle Waukesha's probable diversion application.
This is but the first of what are likely to be substantive comments on the recommendations from interested parties and the general public, offering a real test of SEWRPC's willingness to absorb suggestions
Here is the complete text of the letter (Note: the comment period closes 3/16):
March 12, 2009
Mr. Robert Biebel
Southeastern Wisconsin Regional Planning Commission
W239 N1812 Rockwood Drive
Waukesha, Wisconsin 53187-1607
Dear Mr. Biebel:
The City of Milwaukee appreciates the opportunity to comment on the Preliminary Regional Water Supply Plan for Southeastern Wisconsin. As you know, Carrie Lewis, Superintendent of the Milwaukee Water Works has represented the City on the Regional Water Supply Planning Advisory Committee and many of our comments reiterate Ms. Lewis’ comments during the study period.
The City of Milwaukee supports many of the regional Water Supply Plan objectives outlined in Chapter V. However, the City of Milwaukee disagrees with the use of projected population growth and land use from the Southeastern Wisconsin Regional Planning Commission’s (SEWRPC’s) Land Use Plan as the basis for estimating future water supply needs. The City of Milwaukee continues to urge SEWRPC to consider a water supply plan that is based upon our understanding of existing groundwater and surface water resources including the constraints on those resources. The availability and quality of water resources should help local governments determine where future growth should occur and should drive land use planning rather than the reverse. The Water Supply Plan should not be based on a premise that water resource limitations be ignored because a particular area is identified as a growth area in the Regional Land Use Plan.
Even if the City agreed that land use and population are good proxies in establishing future water supply needs, we disagree with the assumption that existing land use trends will continue without adjustment for changes in land use policies, changes in population growth trends and changes in economic investments. The study assumes that historic growth patterns from the 1980s and 1990s will continue. No alternative growth scenarios were included in the water supply study. It would be helpful to include a no-growth projection in addition to the projected continuation of past population trends and land use patterns. The City of Milwaukee recommends that the Water Supply Plan not be finalized without designing and evaluating alternatives based on water resource limitations. The Water Supply Plan should also reflect several population and land use scenarios to better bracket future water supply needs.
The Plan evaluates four major alternatives. Each alternative is evaluated based on ground and surface water impacts, capital and operating costs and other environmental impacts. The Plan does not fully address hybrid approaches to meeting Waukesha and other communities’ water supply needs. For example, the Plan should consider whether there are situations where blending surface water and ground water resources coupled with water conservation may be the best alternative to meeting future water needs.
Alternatives for providing additional water to Waukesha appear to rank fairly closely and the Plan does acknowledge that additional evaluation is needed to help identify the best approach. Because Waukesha is not facing a water crisis, the City of Milwaukee recommends a more complete analysis of alternatives, including hybrids of some of the alternatives already included in the Plan.
Much of the Regional Water Supply Plan is devoted to analyzing the capital and operating costs of the four alternative scenarios. The Plan does provide standard engineering costs to compare various options to each other. However the full cost of providing water is woefully underestimated. While the Plan does a good job of standardizing regional information, it does not fully reflect the full cost of improvements to Milwaukee’s system that would be necessary to supply water to the additional communities. Estimating these costs will require a better understanding of Milwaukee’s existing water system. The current Plan understates the full costs associated with serving suburban communities with Milwaukee Water Works water.
The Plan also does not consider the full environmental costs associated with alternatives that divert water from Lake Michigan. The Great Lakes Water Resource Compact prohibits diversions with few exceptions. In the case of these exceptions, the jurisdiction diverting Lake Michigan water must demonstrate that water will be returned to Lake Michigan. Although this language may have anticipated returning flow through a sewage treatment facility discharging directly to the lake, it is apparent that one option for the City of Waukesha is to return flow as treated wastewater through a local river or stream. This study does not fully evaluate the environmental impact of using existing water bodies to return flow to Lake Michigan. There may be costs associated with impacts to both instream water quality and quantity.
The Water Supply Plan provides a good assessment of existing drinking water issues for southeast Wisconsin. It demonstrates that although there are isolated areas of groundwater contamination and drawdowns of some groundwater resources, overall, there is no water supply crisis in southeastern Wisconsin. As such, there is time to fully analyze water supply alternatives with the addition of new technical resources (new models, different paradigms) and new public policy (e.g., the Great Lakes Water Resources Compact). Specifically, the Compact requires us to be much more thorough in any analysis of alternatives based on using water from Lake Michigan outside the basin. There are specific standards in the Compact and additional standards are likely as the Department of Natural Resources moves forward to adopt administrative rules clarifying the intent of the Compact. Because of this, the Plan should not be used as justification for diversion applications since the work was conducted prior to adoption of the Compact and development of state administrative rules. Additional legal findings must be made by any applicant wishing to divert Lake Michigan water. The costs associated with additional investments in infrastructure that may be needed to ensure that return flow requirements are met and water quality is not compromised must also be assessed in any diversion application and should be fully considered in evaluating the costs of any of the water supply alternatives.
The City of Milwaukee appreciates the hard work done by SEWRPC, its consultants and the Planning Advisory Committee. However, because the Plan clearly demonstrates that there is no water supply crisis in southeastern Wisconsin, we recommend that additional analysis be conducted to reflect existing source water limitations, new modeling capabilities and alternative land use and population scenarios. We also recommend that the adoption of the Water Supply Plan be postponed until the full requirements of the Great Lakes Water Resources Compact can be factored in to alternative scenarios. This includes waiting until the Department of Natural Resources issues administrative rules to administer the Compact.
Mayor Tom Barrett
Michael J. Murphy
Alderman – 10th District