New NWF Report Raises Questions on Need for Lake Michigan Diversion

Report analyzes Waukesha, Wisconsin's Great Lakes water diversion application.

02-25-2013 // Marc Smith
Great Lakes

A new National Wildlife Federation report raises questions on whether a Wisconsin community needs to divert water from the Great Lakes to meet its water needs. The City of Waukesha is applying to divert Lake Michigan water. The application is the first since the passage of the Great Lakes Compact which bans diversions of Great Lakes water and promotes wise water use within the eight states and two Canadian provinces bordering the lakes. Many conservation groups view Waukesha’s application as precedent-setting. 

“Our analysis finds that Waukesha might not need to divert Great Lakes water to meet its water needs,” said Marc Smith, Senior Policy Manger with National Wildlife Federation. “The city has options on the table that may satisfy their water needs. In short, they have not justified their need for a Lake Michigan diversion.”

The report, “An Analysis of the City of Waukesha Diversion Application,” authored by Jim Nicholas, a scientist and retired director of the U.S. Geological Survey’s Michigan Water Science Center, finds that Waukesha’s demand for water has been decreasing since the late 1980’s.  However, in their diversion application, the city projects a much higher demand that is inconsistent with historical trends.  Moreover, the report identifies that existing alternative sources of water are available and may be feasible to meet existing and future demands - opening up questions over whether or not a Lake Michigan diversion is necessary.  The report’s scope did not include costs associated with various alternative sources of water, nor the environmental impacts of infrastructure and return flows to Lake Michigan.

“Our goal for this report is to provide the Wisconsin Department of Natural Resources an objective scientific evaluation of the Waukesha diversion application.” said Marc Smith, Senior Policy Manger with National Wildlife Federation. “The report focuses on conservation measures, demand forecast, and environmental impacts of withdrawals.”

Among the key findings of the report:

  • Waukesha’s water conservation efforts have been successful in reducing water usage.  If their plans are fully implemented and successful, then the amount of water used per person each day should decrease;
  • Waukesha does not justify why they need so much water:
    • Waukesha’s per capita water use or demand is declining and has been declining for about three decades;
    • Waukesha’s demand forecast for 2050, however, assumes a significant increase in per capita water use, despite planned implementation of conservation measures aimed at reducing water use;
    • No explanation/justification is given for assuming that ongoing declines in water use will stop, much less reverse and increase.
  • Regional groundwater levels in Southeast Wisconsin are stabilizing or rising;
  • Each of the potential waters sources analyzed could provide some of Waukesha’s future water needs.  Some could meet all; and
  • Waukesha does not provide sufficient analysis of the environmental impacts of the potential water sources. 

Download the report, “An Analysis of the City of Waukesha Diversion Application” (PDF).

The diversion application is the first since the Great Lakes Compact passed in 2008.  Waukesha is eligible to apply for Great Lakes water because it lies within a county that straddles the Great Lakes and Mississippi River divide. That county, Waukesha County in southeastern Wisconsin, is located 18 miles west of Milwaukee and Lake Michigan.

“The Great Lakes Compact is clear on what is expected of any diversion application. We support the thorough review of the application by the Wisconsin Department of Natural Resources.” said Smith.  “Our report indicates that as of today, Waukesha does not show the burden of proof in this application.”

The precedent-setting application must not only stand up to the scrutiny of the Wisconsin Department of Natural Resources, but must undergo regional review by the governors of the seven Great Lakes states of Illinois, Indiana, Michigan, Minnesota, Ohio, Pennsylvania, New York and the Canadian premiers of Ontario and Quebec. Applications for exceptions in straddling counties must also be approved by all eight of the governors.

Contact: Marc Smith, National Wildlife Federation, 734-255-5413 (

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