MWLA Letter to Our Legislators on Proposed Statute Relating to Wakesurfing and Wakeboarding

Senator Mary Felzkowski, Senate District 12   

November 20, 2023
Re: LRB 3518
Senator Felzkowski,

Thank you for taking an interest in the concerns related to wakeboating and wakesurfing activities in Wisconsin.  The Board of Directors of the Manitowish Waters Lakes Association (MWLA) joins with the Manitowish Waters Town Board in opposing LRB 3518 in its current form.  The Town Board appropriately addresses the loss of local control in LRB 3518. In considering water quality and safety concerns, the Board of the MWLA offers the following observations related to the deficiencies in LRB 3518 and is based on the research cited:

LRB 3518 in its current form requires wakeboarding and wakesurfing to be done greater than 100 feet from an anchored boat.  This is an insufficient safety restriction.

  • A 2015 Water Sports Industry Association (WSIA) study[i] reported data concerning the height and energy of waves created during different modes of boating operation.  100’ from the path of a boat in a cruising non-wake surf mode the waves created were 9.95 inches high.  The same boat in a wake surfing mode created waves 19.88 inches high, more than twice as tall.
  • This is a significant safety concern and the 100 foot restriction of LRB 3815 is insufficient.

 LRB 3518 in its current form prohibits a wake boat in wakesurfing mode from operating within 200’ of shore.  This is an insufficient limitation.

  • Enhanced wave heights potentially create safety issues at shorelines, on docks and in boats on the water.  Enhanced wave energy and power potentially erode shorelines, release phosphorus from lake bed bottoms, and decimate near-shore native aquatic plant life and fishery habitat.
  • A 2022 peer reviewed study by the University of Minnesota St Anthony Falls Laboratory[ii] provided evidence comparing the height, energy and power of wakes produced by a boat in wake surfing mode with those produced by a runabout boat and a ski boat. For wakes produced by boats in wake surfing mode to attenuate to the level of wakes produced by a non-wake boat 200’ from shore, the boat in wake surfing mode would need to be:
  • Greater than 500 feet from shore for maximum wave height;
  • Greater than 575 feet from shore for total wave energy;
  • Greater than 600 feet from shore for maximum wave power.
  • The 200 foot restriction is insufficient to protect our shorelines.


LRB 3518 in its current form indicates a desire to address “pressing safety and conservation concerns” but does not address the risk of increased transfer of aquatic invasive species in the ballast tanks of wake boats.

  • The State of Wisconsin allocates millions of dollars annually for surface water grants, many of which go to efforts to control and monitor aquatic invasive species.
  • A 2016 study done in Fremont Wisconsin with researchers from the Sea Grant Institute and the University of Wisconsin Extension[iii] sampled the ballast tanks of wake boats and found an average of 8 + gallons of residual water remaining after attempting to empty the ballast tanks in the normal manner. One boat was found to have 22+ gallons of residual water.  The larval form of the aquatic invasive zebra mussels were found alive in the residual water of some of the boats.
  • A 2018 doctoral thesis[iv] done at the University of Minnesota compared the likelihood of transferring aquatic invasive species across five different boat types.  Wake boats with ballast tanks were included in the study.  The conclusion of the research reported “recreational equipment that contains one or more ballast tanks poses the greatest likelihood of moving high numbers of veligers” (the larval form of zebra mussels).
  • State statutes prohibits the spread of aquatic invasive species by watercraft. Ballast tanks of wake boats cannot be fully drained using conventional boat operator methods at boat landings and cannot be accessed for inspection. 
  • LRB 3518 does not address the deficiency in the current statutes that wake boats present.  This threatens transport and the further spread of aquatic invasive species.

Wisconsin residents and visitors are blessed with lakes and rivers that while providing scenic beauty and recreational opportunities also provide an important foundation for the tourist economy.  The Board of Directors of the MWLA welcomes your desire to address safety and the need for protection of our waters when considering wakeboarding and wakesurfing recreation.  As LRB 3518 is deficient in addressing the above water quality and safety concerns, the MWLA Board joins the Manitowish Waters Town Board in opposition to this bill as it is currently presented and encourages reconsideration of LRB 3518.  The research citations provided may be an assist as you contemplate modifications to the bill.


Greg Holt, President Manitowish Waters Lakes Association

[email protected]; P.O.Box 286, Manitowish Waters, WI, 54545

[i] Goudey, C.A. and L.G. Girod. 2015. Characterization of wake-sport wakes and their potential impact on shorelines. Watersport Industry Association, Orlando, Florida.

[ii] Marr, J. A. Riesgraf, W. Herb, M. Lueker, J. Kozarek, and K. Hill. 2022. A field study of maximum wave height, total wave energy, and maximum wave power produced by four recreational boats on a freshwater lake. University of Minnesota, St. Anthony Falls Laboratory, Project Report 600, Minneapolis.

[iii] Campbell, T., Verboomen, T., Montz, G., & Seilheimer, T. 2016. Volume and contents of residual water in recreational watercraft ballast systems. Management of Biological Invasions, 7(3), 281-286.

[iv] Doll, A. 2018. Occurrence and survival of Zebra Mussel (Dreissena polymorpha) veliger larvae in residual water transported by recreational watercraft. Master’s thesis. University of Minnesota, St. Paul.