Racine's Application for a Diversion of Water for the Foxconn Facility
 

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The DNR is currently accepting comments from the public on the City of Racine’s request to divert 7 million gallons of water from Lake Michigan to the proposed Foxconn facility. The comment period will close in one week on March 21st.  The Great Lakes Compact Implementation Coalition has some concerns about the precedent that this application will create around taking our precious Great Lakes water for private industrial use.

While many of the details are still missing, we do know a few facts and some of them are troubling.  

  • First, this facility will not be located within the Great Lakes Basin, but rather in the “straddling” community of Mount Pleasant.  The City of Racine is the applicant, rather than Mount Pleasant.  This is troubling because cities within the Basin with extra capacity do not qualify to request a diversion.  Under the spirit and intent of the Great Lakes Compact, cities within the Great Lakes Basin are able to apply for additional capacity, not diversions.  This is to protect the primary tenant of the Great Lakes Compact: a ban on diversions except in rare and unique instances.  The City of Racine has the capacity to provide water to Foxconn without requesting larger withdrawal amounts, but it cannot provide the water without permission for a diversion since Mount Pleasant is outside the Basin.  Given the twisting of the application process, review by the Regional Body should be triggered. 
     
  • Second, the water delivered to Mount Pleasant will not be diverted for public consumption, as required by the Great Lakes Compact, but rather to a private, foreign corporation.  A key tenant of the Great Lakes Compact is to protect Great Lakes Water for the public. 
     
  • Third, the Foxconn proposal says that nearly 40% of the 7 million gallons would be lost to the manufacturing process, and not returned to the lake.  Another key tenant of the Great Lakes Compact is that water taken must be returned, less consumptive use.  But when does consumptive use, not related to public use, become so great that it has a cumulative negative impact on the Great Lakes?  What happens when we have 20-30 Foxconn’s around the Great Lakes failing to return water at such high levels?  This is precedent setting and concerning.
     
  • Fourth, there is no specificity about how the water will be used, treated, or managed, or whether Foxconn will be exempt from certain permitting requirements. 

Over 40 million people rely on the Great Lakes for drinking water, and only 1% of that lake water is renewed by rain and snow melt. The Great Lakes Compact was enacted to protect this water for current and future generations.  Wisconsin signed on to this international agreement governing consumptive use and water diversions from the Great Lakes. This proposal does not meet the spirit of the Great Lakes Compact for the reasons listed above. The application is being made by Racine and not by the straddling community of Mount Pleasant, the water diverted will not be used primarily for public water supply, and there has not been a review of whether the cumulative consumptive use from this precedent setting diversion will negatively impact the Great Lakes over time.

The DNR needs to be held accountable and to handle this project according to the spirit and intent of the Great Lakes Compact.  Please let the DNR know about your concerns and ask the DNR to deny the application as it stands and protect our water for future generations.  

Email comments to: DNRRacineDiversionComments@wisconsin.gov

Hard copy comments can be sent to:
DNR Drinking Water and Groundwater Program DG/5
Attn: Adam Freihoefer
PO Box 7921
Madison WI 53707-7921

The Compact Implementation Coalition, collectively representing tens of thousands of Wisconsinites, has a long history of working on the Great Lakes Compact. From ensuring the adoption and implementation of a strong Great Lakes Compact to aiding the Wisconsin Department of Natural Resources in the promulgation of administrative rules to implement the Compact, it has consistently advocated for the strongest protections available for the resource, in keeping with the spirit and the letter of the Compact.