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Foxconn Development: City of Racine, WI Water Diversion Application

Foxconn Technology Group, a Taiwanese electronics manufacturer, has announced plans to build a $10 billion manufacturing complex in Mt. Pleasant, WI that reportedly will bring up to 13,000 jobs to southeastern Wisconsin. The facility will be constructed in an “electronics and information technology manufacturing zone” that the Wisconsin legislature created in September 2017. The complex will be constructed in a portion of Mt. Pleasant that is partly inside the Great Lakes basin and partly in the Mississippi River basin.

The City of Racine, WI has applied to the Wisconsin Department of Natural Resources (WDNR) for a diversion of Great Lakes water to service the new facility. Under the application, the City of Racine would divert an average of 7 MGD from Lake Michigan to supply the new zone: 5.8 MGD for Foxconn and 1.2 MGD for other future manufacturers. Approximately 3.3 MGD of Foxconn’s water use would be returned to the Great Lakes basin, and its estimated consumptive use would be 2.5 MGD. Foxconn plans to use the water for manufacturing (3 MGD), cooling (2.4 MGD) and for sanitary purposes (0.5 MGD). Most of the consumptive use would be evaporative loss from cooling towers.

The City’s application does not seek a new or increased withdrawal from Lake Michigan, because the City currently is authorized to withdraw up to 60 MGD but typically withdraws far less (roughly 13 MGD in 2015). The application nevertheless proposes a new or increased diversion under the Great Lakes-St. Lawrence River Water Resources Compact (“Compact”) because the City seeks to “alter an existing withdrawal so that it becomes a diversion.”

The Compact prohibits diversions of water out of the Great Lakes basin unless the diversion satisfies a specific exemption. The City of Racine has applied for an exemption as a “straddling community,” but some question exists as to whether and how the “straddling community” exemption might apply to the Foxconn facility. Other issues raised by the City’s application include whether the proposed diversion would be used “solely for public water supply purposes;” and whether Foxconn’s proposed consumptive use “maximizes the return of Great Lakes water” to the Great Lakes basin.

WDNR has scheduled a public hearing on the City of Racine application on March 7 in Sturtevant, WI. Comments on the diversion application are due by close of business on March 21, 2018. More information is available at