Here is the text in full of a letter sent to the Wisconsin DNR from US and Canadian Mayors speaking as the so-called Great Lakes regional 'Cities Initiative.' If I get a copy more easily reproducible, I will post that.
The criticisms echo earlier critiques by Wisconsin environmental organizations as well as those of the lead letter-writer, Mayor Keith Hobbs, Thunder Bay, Ontario.
To win diversion approval, Waukesha must pass consulting by two Canadian provinces and formal approvals by all eight Great Lakes state governors.
Waukesha's application, delayed after preliminary forwarding to the DNR three years ago, awaits a DNR environmental review and formal hearings in Wisconsin before it can be forwarded to the states and provinces for their own reviews.
Waukesha is facing a June 2018 court-imposed deadline to provide its customers with a water supply that complies with Federal radium standards. A Lake Michigan diversion is not the only method of compliance available to Waukesha, but it is the choice of Waukesha officials despite the many legal hurdles presented by the two-country diversion approval process, the first of its kind sought under the 2008 Great Lakes water management compact:
Wisconsin DNR DG/5 PO Box 7921 Madison, WI 53707-7921 Attn: Kassie Lang
WAUKESHA DIVERSION COMMENTS
Furthermore, even the programs that Waukesha has quantified warrant a careful look into the assumptions made. For example, Waukesha projects that approximately 63 mg in savings in 2050 will come from toilet replacements. Waukesha estimates savings of approximately fifteen thousand gallons per year for eachtoiletreplacement.24 The Public Service Commission’s Summary of 2010 Water Utility Conservation Reports shows that Waukesha only saved approximately eight thousand gallons per toilet replacement, and that none of the seven utilities surveyed showed savings of more than 12,047 gallons per toilet replacement.25
Even assuming that fifteen thousand gallons per toilet can be saved, this means that 4,200 toilets will need to be replaced.
From 2008–2011, only eighty eight toilets were replaced in Waukesha, with a $25 rebate.26 While rebates will increase from $25 to $100 under Waukesha’s plan,27 WDNR should be careful to pressure-test any assumptions made by Waukesha.
WDNR should ensure that the same objective consideration is given to all alternatives.
The Cities Initiative asks that WDNR satisfy itself as to Waukesha’s reasons for not exploring, for example, a Lake Michigan / deep unconfined aquifer combination, which would minimize withdrawals from Lake Michigan while still assuring the city of a reliable water source. Additionally, considerations of surface waters, including the Fox River (a
Proper consideration of alternatives to Great Lakes water is at the very core of the Great Lakes Compact, and the Cities Initiative urges WDNR to carefully scrutinize Waukesha’s compliance with the letter and the spirit of the law.