For the last few days, I have been posting excerpts from and analyses of a ten-page list of 49 issue areas - - full text, here - - the Wisconsin Department of Natural Resources wants addressed by the City of Waukesha to cure deficiencies and clarify statements in the city's stalled-since-April application for a Lake Michigan diversion under the Great Lakes Compact of 2008.
I've been saying that the Department of Natural Resources, taking its obligations seriously and obviously mindful that among its audience are their counterpart regulators in the seven other Great Lakes states and two (as advisers only) Canadian provinces, has handed Waukesha an expensive, and time-consuming series of tasks, a virtual do-over of the application.
People tell me - - "that sure sounds like a big deal...is there a nugget in there that speaks volumes?"
Well, how about looking at just one of the 49 issue areas - - a portion of the wastewater return conundrum - - to get a measure of just what the DNR wants from the city:
Standard: s. 281.346(4)(f)3m., Wis. Stats. “The place at which the water is returned to the source watershed is as close as practicable to the place at which the water is withdrawn, unless the applicant demonstrates that returning the water at that place is one of the following: a. Not economically feasible. b. Not environmentally sound. c. Not in the interest of public health.”
"RF5. For each proposed water supply alternative, provide an analysis showing a return flow option that complies with the above standard. The current application only includes an analysis for the Milwaukee water supply alternative. In addition, the current application only provides information showing that returning the water to Underwood Creek is the least cost alternative but does not demonstrate that it is not economically feasible, not environmentally sound, or not in the interest of public health to return the water to Lake Michigan as close as practicable to the withdrawal site.
To analyze the economic feasibility of the various return flow options, you should evaluate the financial effects of these options on both water supply and wastewater ratepayers. The utility should prepare rate studies for the various return flow options using procedures that are consistent with current state and local rate setting practices.
These studies should evaluate the water and wastewater rate impacts to the average residential customer, and other representative customers, under several of the proposed financing and operational scenarios for the project (E.g., under a project financed and operated wholly by the water utility; under a project financed in part through grants or other non-water utility sources; under a scenario where portions of the operation are turned over to the wastewater utility for operation after construction, etc.).
You will likely need to retain a rate consultant to assist in this evaluation. Please contact Kristy Rogers to discuss your proposed plan prior to conducting the requested analysis for economic feasibility."