Protecting Lake Levels

In April 2026, FRIENDS learned of two water right change applications associated with the Stratos/Wonder Valley data center project in Box Elder County.

Change Application a54385 proposed to convert an existing agricultural water right — 1,900 acre-feet per year from Salt Wells Spring Stream in Hansel Valley, Box Elder County — from irrigation use to industrial use for a natural gas power plant and data center under the project name "Wonder Valley."

Salt Wells Spring Stream feeds into the same hydrological system as Locomotive Springs Wildlife Management Area — a state-managed wetland 2 miles from the project site that has already lost 80% of its spring flow to groundwater pumping.

Change Application a54536 proposed to convert an existing water right — 11 acre-feet per year of spring water in Hansel Valley, Box Elder County — from ranching/domestic use to industrial use for a natural gas power plant and data center also under the project name "Wonder Valley."

The project's technical representative publicly claimed they would need 3,000 AF on-site and 10,000 AF near Snowville. The State Engineer should not approve any of these individual applications without a complete water budget for the proposed development.

FRIENDS filed a protest against the first change application on April 30, 2026. 

In May 2026, the Stratos/Wonder Valley data center project WITHDREW both water rights change applications filed with the Utah Division of Water Rights. This came after a record-breaking number of Utahns filed protests against them.

However, the developers have continued to seek water rights for the project.

Read our protest.

Key Points:

• This application lacks sufficient detail about proposed water consumption.
• Approval of this application would increase depletion, impair existing water rights, and impair the more beneficial use of preserving Great Salt Lake.
• There is no evidence that the proposed plan is physically or economically feasible.
• The proposed use will be detrimental to public welfare.

You don't need to be a lawyer. It takes about 5 minutes. There is a $15 filing fee.

There is a $15.00 filing fee to submit a protest online. Have a credit or debit card ready before you start.

Step 1: Go to the Utah Division of Water Rights protest portal. The direct URL for filing is: https://waterrights.utah.gov/protestOfApplication/protestOfApplication.asp

Step 2: In the first field — "Water Right, Change, or Exchange Number" — type exactly: a55167

Step 3: Click the "Get Info" button. The form will auto-populate the "Action to be protested" field with the application details. Confirm it shows Change Application a55167.

Step 4: Fill in your personal information:

• First Name — Your first name
• Last Name (or Company Name) — Your last name — or your organization's name if filing on behalf of a group
• Care Of — Leave blank unless filing on behalf of someone else
• Mailing Address — Your street address
• City, State, Zip — Your city, state, and zip code
• Phone — Your phone number
• Email Address — Your email address — you'll receive a confirmation here

Step 5: For "Are you requesting a hearing?" — select YES. This is important. Selecting Yes preserves your right to participate if the State Engineer schedules a formal hearing on this application. You are not committing to attend — you are preserving your option to do so.

Step 6: In the "Please state your reasons for protesting" box, type your protest statement. See the talking points section below — copy and paste any of those statements, or write your own. The box accepts plain text. You do not need legal language.

Step 7: If you want to attach a PDF (optional), you can upload one using the "Choose File" button. Most people don't need to do this — your written statement is sufficient.

Step 8: Check the electronic signature box at the bottom.

Step 9: Click "Continue to Payment" and pay the $15.00 filing fee. Once payment is confirmed, your protest letter will be generated. Print or save it for your records. Your protest is not complete until payment is confirmed.

The process is NOT complete until payment is confirmed and the protest letter is generated. If you stop before the payment step, your protest has not been filed.

If you prefer not to pay the online fee, you can email your comment as a Letter of Concern directly to the Division:

Email to: This email address is being protected from spambots. You need JavaScript enabled to view it.

Subject line: Protest — Change Application a55167

Include: Your full name, mailing address, phone number, email address, and your protest statement. State whether you are requesting a hearing (yes is recommended).

Note: Emails may take longer to process; send as early as possible.

We suggest using this Protest template created by Tim Blackham and Jared Parkinson with Water Law PC. Fill it out, then copy it into your written statement or upload it as a PDF attachment.

Here are some additional points you can use:

Short version (copy and paste this if you want to keep it simple):

"I protest Change Application a55167. The proposed water use for a multi-gigawatt power plant and data center is not adequately described or justified in the application. Source springs in this area are connected to Locomotive Springs Wildlife Management Area — a declining spring-fed wetland on the north shore of the Great Salt Lake that has already lost 80% of its flow to groundwater pumping. I request the State Engineer require a complete water budget and independent hydrological analysis before approving this change. I am requesting a hearing."

Additional points you can add:

—  The application proposes 11 acre-feet per year for a 7.5-gigawatt power plant. Federal EIA data shows natural gas power plants at this scale consume hundreds of thousands of acre-feet per year. The application does not explain how 11 acre-feet is sufficient and does not provide a complete water budget for the power plant's consumptive use.

—  The project's technical representative publicly stated at the April 27, 2026 Box Elder County Commission meeting that the project has approximately 3,000 acre-feet on-site and 10,000 acre-feet under contract near Snowville. The 11 acre-feet in this application is less than the amount claimed publicly. No corresponding change application for Snowville water has been identified in public Division records. The State Engineer should identify and consolidate all water rights associated with this project before acting on this application.

—  The application does not describe patterns of historical use and how the proposed change will affect the timing and volume of return flows.

—  This year, Utah received the lowest snowpack in recorded history. Approving a change application for industrial power generation without a complete hydrological analysis is contrary to the public interest in protecting the Great Salt Lake and its inflows.

—  The data center application states that flushing water will "return to the natural hydrologic system and ultimately to the Great Salt Lake." The application makes no equivalent claim for the power plant's consumptive losses. The power generation use is the dominant use and it has not been adequately analyzed.

As wastewater treatment standards become more stringent and wastewater discharges become cleaner, some municipalities in the Great Salt Lake Basin are applying to reuse their wastewater discharge as a source of secondary water, primarily for irrigation. Because wastewater discharges represent a significant portion of Great Salt Lake's inflows, the 2023 amendments to Utah's Wastewater Reuse Act require municipalities in the Basin to file a water replacement plan along with their reuse application.

Some of these municipalities have taken the position that they have a right to reuse their wastewater discharge without replacing those inflows. This stance directly conflicts with recent legislative efforts to preserve and restore Great Salt Lake.

In response, we are challenging applications that lack a sufficient replacement plan. To date, we have filed protests on reuse applications totaling more than 150,000 acre-feet of water. Click here to read our protest.

These protests demonstrate our alignment with the Utah State Engineer's interpretation of the statute as requiring a water replacement plan for all applications. This interpretation is consistent with ongoing legislative efforts to protect Great Salt Lake and the substantial investments made by the state to address declining water levels.

By insisting on comprehensive water replacement plans, we aim to ensure that wastewater reuse projects do not undermine ongoing conservation efforts and the long-term health of Great Salt Lake. This approach recognizes the delicate balance between meeting municipal water needs and preserving the unique and vital ecosystem of the Lake for future generations. We will continue to advocate for responsible water management practices that safeguard the future of Great Salt Lake and the countless species and industries that depend on its health.

In November 2022, Utah Governor Spencer Cox issued a proclamation "Suspending New Appropriations of Surplus and Unappropriated Waters in the Great Salt Lake Basin." This proclamation, aimed at protecting the declining water levels of Great Salt Lake, covers both surface and groundwater sources feeding the Lake. However, the interpretation and implementation of this proclamation have become a point of contention, leading us to take action.

The State Engineer has interpreted the proclamation as excluding groundwater inflows to the North Arm (Gunnison Bay), which has resulted in a steady stream of water right applications for new groundwater appropriations pumped from aquifers that feed into the North Arm. We argue that this interpretation is inconsistent with the proclamation's intent and harmful to the Lake's ecosystem.

The importance of groundwater to Great Salt Lake has been underscored by recent scientific findings. While in the past, the State considered the groundwater contribution to Great Salt Lake to be relatively insignificant – estimated at around 75,000 acre-feet per year – recent studies by the Utah Geological Survey have increased this estimate to 560,000 acre-feet, a staggering 750% increase. This revelation highlights the vital role that groundwater plays in maintaining the Lake's water levels and overall health.

In an effort to protect this essential water source for the Lake and to encourage the State Engineer to interpret the proclamation correctly, we are challenging applications for new groundwater appropriations that we believe violate the provisions of the proclamation. Click here to read one of our Water Right Application protests.

Our protests meticulously detail why these applications should be rejected, addressing issues such as the lack of unappropriated water in the Great Salt Lake Basin, potential impairment of existing rights, and detriment to public welfare. By challenging these water right applications, we aim to ensure that the intent of the Governor's proclamation is upheld, and that the critical groundwater sources feeding Great Salt Lake are protected for the benefit of the Lake's unique ecosystem and the communities that depend on it.

Listen to a Division of Water Rights hearing for one of our protests from 1/30/25.