It began the way I believe many bicycle tours do, or at least should. I was aimlessly studying a map of the state when I saw a dirt road that connected to a gravel road, which led to the railroad tracks, which could be followed to this road, which winds its way up to that county road, which-ah hah. I had just discovered that it's possible to ride all the way around Great Salt Lake.
‘Discovered' may be too strong a word, but I don't think so. I bounced the idea off a few non-cyclist buddies, to which the general reply was "The military owns the land out there and they'll never let you through." In January I took a drive out there and found a public road that went through the Air Force property, so I knew it was possible.
Next I tried the idea on some cycling friends. When invited, they just stared at me incredulously and finally said "no." Finally I asked Mark Muir, whom I met in Seattle three years ago. He was another Utah expat who missed the stark desolation of the Great Basin as much as I did so it was easy to convince him to come. That's how it began, two Utah natives setting out to rediscover the bastard-child of Utah's natural resources. We were ready to take on what may be the first circumnavigation of Great Salt Lake by bicycle. We wanted to see the lake for what it is and for what our society has done to it. We wanted to feel the desolation of the desert and see the impact of the industries along the shoreline. We wanted to swat the flies and smell the stink.
And we needed to do it all in one weekend, which led to the name of our expedition: Ride around Great Salt Lake in one weekend, or RAGSLOW.
Our first day of riding set the theme for the entire ride. We spent most of Friday afternoon hastily mounting racks and panniers to our bikes and packing them with gear. Our 2:00 pm departure time was pushed back to 6:30 that evening. We had wanted to get in about fifty miles that day but were happy to make it to the Great Salt Lake State Marina just west of Saltair. On the way we met up with a group of six riders from the Bonneville Bicycle Touring Club. We rode with them for several miles and told them about our trip. As we arrived at Saltair and said goodbye, one of them portended "I hope you have enough water." So did we.
If Friday's late start was a dark cloud looming on the horizon, then Saturday's ride was the tempest in her fury. We paid for our hasty preparation all day long.
The problems started before we left the marina. My front tire was flat. I had Slime® in my tubes so I thought I could just pump it up and continue. I made it about a hundred yards before it went flat again. The slime was the problem. Some of it had dried up in the stem, preventing the stem from sealing properly.
I laid my bike on its side without removing the panniers to change the tube. The weight of my load must have bent my rack slightly because when I started riding again my fender was rubbing on the rear tire. I fiddled with it for another fifteen minutes before I gave up and removed the fender. I strapped it on top of my panniers next to my defunct Slime® tube.
The goal of our ride was to circle the lake by riding as close as practical to the shoreline. So this meant we took the road along the railroad tracks just north of Interstate-80. It seemed like a good idea based on our map.
About five miles down this rocky road the interstate bends to the south around the lakeshore while our road continued straight. There was water on both sides of us and we were engulfed by a flock of seagulls. Somehow over the noise of the birds Mark heard some jarring noises coming from his rack. One of the bolts that held the rack to the frame had vibrated loose. Well-prepared bicycle tourists have extra bolts stowed away for this sort of emergency. We borrowed one of the bolts holding on Mark's water bottle cage instead.
My rack had the same problem a few minutes later. This was the first of four times that my rack came off that day. My bike doesn't have braze-ons on the seat stays for mounting a rack so I used some pipe clamps purchased at a hardware store. I'd used this method on several tours before; in fact, I was using the same clamps from previous tours. When my rack started making noises I saw that I had not only lost a bolt down near the hub, but one of my pipe clamps had broken too.
I used the bolt from the broken pipe clamp to replace the bolt I had lost on the rack. Then I connected both frame supports to the one remaining pipe clamp. Once again, well-prepared bicycle tourists have extra pipe clamps stowed for emergencies like this.
When I-80 rejoined the railway we decided to leave the rocky railway access road and ride on the freeway. Here Mark discovered the first of two broken spokes his rear wheel suffered. Well-prepared bicycle tourists have extra spokes stowed for emergencies like this. This time we were prepared with extra spokes.
We rode about twenty miles on the freeway and got honks of support from a passing car with a bike rack on the roof. We turned north on the road to Rowley and the US Magnesium plant with its thick yellow cloud of chlorine gas. US Magnesium removes magnesium chloride from Great Salt Lake water to produce magnesium metal. In the process they release millions of pounds of chlorine into the atmosphere and are the top producer of dioxins in the country, according to EPA's 2004 Toxics Release Inventory. We were happy to have tailwind blowing the toxic plume away from us as we approached.
North of US Magnesium we turned west again and climbed over Wrathall Pass in the Lakeside Mountains. The last pipe clamp holding on my rack broke on the way down the pass. My panniers dragged on the road before I could stop. Some guys in a Union Pacific truck stopped as we were fixing it to see if they could help. We had the rack reattached by then and didn't need help, so they warned us that some Indians were camping near Lakeside, about 20 miles away. I don't know what they meant by that, but we were going to camp at Lakeside anyway.
With the gear problems we'd had you might think we staggered the last 20 miles into lakeside to set up camp. But that's not how it happened. The dirt road through the military land was smooth like pavement. The sunset was brilliant and the Indians turned out to be Basque sheepherders. We set up our tent between the railroad tracks and Strong's Knob, one of the small islands in the lake. We cooked cheese ravioli and watched the Avocets feeding on the shore. The noise of the wind and passing trains kept us awake for a while but soon exhaustion set in and we slept.
On Sunday we turned west from Lakeside toward Hogup Siding and the pumping station built after the 1983 flood to control the lake level. We rode on another rocky railroad causeway and were again passed by some Union Pacific workers in a truck. They stopped and asked "Are you lost?" This was a legitimate question considering how out of place we must have looked. I smiled and asked "is this the way to Wendover?" In hindsight, I should have asked them for some water.
We chose to ride a dusty two-track along the lakeshore instead of an improved road through the Hogup Mountains because we wanted to stay within sight of the lake. The dusty two-track had been trampled by cows and was the roughest road we rode on the whole trip. We could have walked as fast as we were riding. We questioned passing up the improved road through the mountains, but our reasons for undertaking this adventure were views of the lake and the desolation. This dusty two-track gave us both.
Our water supplies were running low when we finally met up with an improved dirt road west of Dolphin Island. We left Salt Lake City carrying about six liters of water each and were lucky to have camped at the State Marina on Friday night where they had running water. We were twenty miles from the ghost town of Kelton, which our map said had a flowing well. Thankfully, road to Kelton was straight and smooth otherwise we might have run out of water.
I had an inch of water in my bottle when we arrived at the Kelton cemetery. Mark's water bottle was half full. We strolled through the cemetery and read the historical signs put up by the Bureau of Land Management before we looked for the well. We figured it would be an island of greenery in this sea of sage. Instead it was a mirage. The well was still there, but it was full of cobwebs. I couldn't see water down in the pipe, and had nothing to retrieve it if any was there. We had to continue east to Locomotive Springs, fifteen miles away.
Some teenagers in a pickup truck drove by and gave us their last bottle of water. I drank half of it before they had driven out of sight. It made the last few miles to the springs easier.
After pumping water from Locomotive Springs we rode east along the historic railroad grade to Monument Rock. We camped that night on the salt flats at the base of the rock and contemplated riding across the smooth surface all the way to Promontory Point.
We woke up early Monday morning to a light rain and the necessity of riding all the way to Salt Lake City before nightfall. We had twenty miles of gravel road over the Promontory Mountains before we got to Golden Spike National Historic Site and paved roads. We didn't spend long at Golden Spike because we were looking forward to a huge lunch at Idle Isle in Brigham City, the third oldest restaurant in Utah.
Our stomachs were slightly distended when we rode out of Brigham City so we labored through the first few miles of highway 89 through Perry, Willard, Plain City and Hooper. We made one last stop at the Great Salt Lake Shorelands Preserve southwest of Clearfield where The Nature Conservancy has preserved 4,000 acres of marshes, ponds and mudflats with a mile-long boardwalk running through them to a 30-foot observation tower overlooking the lake. It's a peaceful place for birders, kids and cyclists.
The last 25 miles were a race against the sun with North Temple in downtown Salt Lake as the finish line. We crossed it shortly after 8:00 that evening, shook hands in front of Crown Burgers and sprinted for the light rail. People on the train looked at us a little funny. I wanted to explain to them what we had just done, but I thought they would not understand the significance of it. Something inside us had turned around. We set out to rediscover an underappreciated natural resource. We had seen the treasures of Great Salt Lake and experienced the harsh realities of its stark landscape. We had felt the desolation and knew the irony of being parched on the shore of a desert oasis. Yet we already longed to be out there again. We had turned the pedals but it was the lake that had turned on us to show us its unique beauty.
Salt Lake City
Great Salt Lake State Marina
Great Salt Lake State Marina
Salt Lake City
PLEASE NOTE: This article first appeared in the May 2006 issue of Cycling Utah (http://www.cyclingutah.com/may/May2006Issue.pdf)
Thanks to everyone who participated in this year's International Coastal Cleanup.
On Saturday, September 15, over 60 volunteers removed 2,444.4 lbs. of trash and debris from the shoreline of our inland sea.
Thanks to generous sponsorships from Autoliv and BudgetDumpster, FRIENDS was able to expand this year’s cleanup and work at two primary sites: the Lee Creek Natural Area along the Lake’s south shore and the eastern shoreline of Antelope Island.
Of the debris volunteers removed were mattresses, televisions, a toilet, and a copy machine, as well as countless plastic bottles, plastic straws, shotgun shells, and cigarette butts. Hazardous waste was separated and disposed of responsibly.
While it is unfortunate that some people continue to use Great Salt Lake as a dumping ground, this event helps promote Great Salt Lake’s hemispheric importance, and inspires others to preserve and protect it.
Thank you to our many individual volunteers and our community partners: Compass Minerals, Great Salt Lake Audubon, The Nature Conservancy, Utah Division of Forestry Fire and State Lands, and Utah Division of Wildlife Resources.
To read more about The Ocean Conservancy’s efforts, click here.
To read more about BudgetDumpster, click here.
"Once in his life a man ought to concentrate his mind upon the remembered earth. He ought to give himself up to a particular landscape in his experience; to look at it from as many angles as he can, to wonder upon it, to dwell upon it.
He ought to imagine that he touches it with his hands at every season and listens to the sounds that are made upon it.
He ought to imagine the creatures there and all the faintest motions of the wind. He ought to recollect the glare of the moon and the colors of the dawn and dusk." - N. Scott Momaday
Enhance your enthusiasm and love of Great Salt Lake by becoming a member of FRIENDS today.
Your generous support makes it possible for us to continue to work hard to protect and preserve the Great Salt Lake Ecosystem.
A subscription to our printed quarterly newsletter and FRIENDS' e-news
Invitations to members-only events:
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If you have any questions, please contact us at firstname.lastname@example.org or 801-244-5633.
9/7/13- current lake level 4194.8’
There is no question that expansion of minerals extraction on the Lake poses a threat to the Lake ecology and functional use for everyone, especially in its current low level state. As with all resources, prudent and responsible management is required to sustain that resource for the benefit of all concerned. As sailors, our first concern is how deep is the water.
-Jerry Harwood, Rear Commodore, Great Salt Lake Yacht Club
The summer of 2013 was brutal. Salt Lake City broke the mold when temperatures reached 95 degrees or higher on 52 days. As the West continues to experience widespread impacts from another perennial drought, the U.S. Bureau of Reclamation made history by announcing that it would be cutting water releases from Glen Canyon Dam. The U.S. Department of Agriculture declared all 29 counties in Utah to be either “at risk or a disaster area. And since May 1st, the average elevation of Great Salt Lake hovered in a narrow range between 4196’ – 4194.8’ . A range that is characterized in the Great Salt Lake Level Matrix developed by the Division of Forestry, Fire and State Lands as a transition zone. A zone where boating, brine shrimp harvesting, salinity exchange between Gunnison Bay (North Arm) and Gilbert Bay (South Arm), and bird island habitats – among other attributes of the Lake - begin to experience impacts.
These conditions set the stage for a series of water hearings that Governor Herbert scheduled this summer around the State to gauge public opinion on the use, development, and conservation of water in Utah. In theory, the hearings would inform the administrative and legislative development of policies and practices that would curtail our gluttonous water habits. An Executive Summary hasn’t been released yet, but a Water Summit is scheduled for late October. In Lake terms, with increased water demands and decreased snowpack, FRIENDS is concerned that Lake levels will trend downward permanently. In fact, experts have discussed lowering what is referred to as “average” Lake level (currently 4,200’) to reflect this trend. Let’s hope that the consensus of expression that came from this endeavor reflects a serious concern about the role climate change is playing on our landscape, in the hydrosphere and the Great Salt Lake watershed.
But what does any of this have to do with a revised expansion proposal from Great Salt Lake Minerals Corporation? And how is it relevant to Great Salt Lake as a Public Trust that belongs to all of us?
Great Salt Lake Minerals Corporation is a subsidiary of Compass Minerals International located in Overland, Kansas. It is one of 6 mineral extractive industries operating on Great Salt Lake. It is North America’s largest producer of potassium sulfate - a commercial fertilizer. The company currently operates 45,000 acres of solar evaporation ponds on the Lake. The ponds are divided almost equally between Bear River Bay in the northeast corner of the Lake, and Clyman Bay to the west in Gunnison Bay (the North Arm).
The process for extracting potassium sulfate begins in the North Arm where salinity levels are near saturation (approximately 26%). Lake water is pumped into a series of evaporation ponds where it undergoes preliminary evaporation during which selected salts drop out and remain in the Clyman Bay ponds. The rest of the brine is pumped across the Lake in the Behren’s Trench to the Bear River Bay facilities on the east side where two years later, potassium sulfate is harvested and shipped to market. GSLM processes about 6 million tons of salt per year. Excess salts that are not salable (approximately 4.5 million tons) are flushed back into the southern portion of Bear River Bay and make their way into the open waters of Great Salt Lake.
On July 9, 2013, Great Salt Lake Minerals (GSLM) submitted an amended permit application with the U. S. Army Corps of Engineers for a revised expansion proposal. The company is hoping to expand the footprint of its existing evaporation pond complex in Great Salt Lake so that it can increase the production and its global market share of potassium sulfate. Because this expansion involves impacts to waters of the U.S. (that’s Great Salt Lake) and wetlands, under the Clean Water Act, a 404 permit is required by the Corps. An Environmental Impact Statement (EIS) is also required.
The good news about the 2013 expansion plan is that Great Salt Lake Minerals has worked in earnest with the conservation community to modify an earlier 2009 proposal. This modification is a testament to the company’s willingness to sit down and address some of our major concerns with the expansion. And although this proposal suggests significant reductions in the scale of the expansion and additional water needs, the Lake isn’t out of the woods yet, For an ecosystem that is already under stress and relies on precipitation, instream flows and water remaining within the system questions about the Lake’s ecology, salt balance, hydrology, wildlife habitats, water quality and recreational use still remain.
But let’s compare the two expansion plans so you can understand what has changed and what the potential impacts to the system are. And remember, GSLM is one of 6 existing mineral operations on the Lake. And currently, the only one of the 6 whose expansion goals has been announced.
In the original 2009 proposal, the company wanted to expand its operations by 91,000 acres - 8,000 of those acres in Bear River Bay which is designated an Important Bird Area by National Audubon Society because of its unique habitat value and high bird use. In conjunction with more dikes and evaporation ponds that would cover the surface of the Lake, and can influence surface evaporation, the project would consume an additional 353,000 acre feet of Lake water annually. This is above the 150,000 acre feet of Lake water the company currently uses.
A three-phased approach would have been implemented to accomplish the expansion. First, production facilities near Bear River Bay would be upgraded. Second, the exterior walls of dikes of the existing footprint would be sealed to improve efficiency by 60 percent. And third, the actual physical expansion of 91,000 acres between both sides of the Lake would occur all at once.
Now things look quite different. The 91,000 acres has been reduced to 37,497. This was achieved in part by the acquisition of a SITLA (School Institutional Trust Lands Act) lease parcel of 24,000 acres consisting mostly of uplands (approximately 15,000 acres). No additional development in Bear River Bay will occur. And the company will not request a water right for an additional 353,000 acre feet of Lake water. Salts that were sequestered in the Clyman Bay ponds will be moved back into the Lake using a progressive reclamation approach. And if approved by the Corps, the physical expansion of the company’s footprint would occur in three 8-10 year phases based on monitoring, data collection, and evaluation through an adaptive management approach. The public will have an opportunity to comment at each increment of the process to help determine whether the next phase of expansion can go forward.
This is all very positive. These changes reflect GSLM’s goal to minimize impacts to the Lake but only because FRIENDS and other partners in the Coalition to Keep the Lake Great objected strongly to the original proposal. So why do we still have concerns if the proposed expansion is now smaller and the additional water right is not needed?
As we all know, Great Salt Lake is a Public Trust resource that belongs to the people of Utah. The Utah Division of Forestry, Fire and State Lands has jurisdictional responsibility to manage our Public Trust sustainably and in perpetuity for future generations. Since 2009 when GSLM first proposed its expansion, we have gained tremendous insight about the Great Salt Lake Ecosystem and the relationship between Lake levels and ecosystem services thanks to the benefit of some additional tools at our disposal.
These tools include two reports generated by Governor Herbert’s Great Salt Lake Advisory Council in 2012. The first entitled Economic Significance of the Great Salt Lake to the State of Utah tells us that the Lake contributes $1.3B annually to the economy of Utah and provides over 7,700 jobs. The second report -The Definition and Assessment of Great Salt Lake Health, evaluated various ecological targets that comprise the Great Salt Lake Ecosystem to determine their particular state of “health or viability.” Many of those targets face stresses which the study ranked high to very high. One of the key contributors to those stresses is reduced Lake levels that cause a variety of impacts to the system such as changes in salinity, increased vulnerability to island nesting birds, the proliferation of phragmites, and stress to the brine shrimp population in Gilbert Bay.
But probably the most instructive tool is the Great Salt Lake Level Matrix, which was born out of the most recent revision process of the Great Salt Lake Comprehensive Management Plan (GSLCMP). It’s the Lake’s Rosetta Stone that provides a schematic perspective on volumes of water in the Lake, how that translates into a range of Lake elevations, and in turn, how physical features, ecological targets and ecosystem services are impacted. The Matrix classifies a low Lake level as 4,188’ – 4,197’. This brings us back to GSLM’s proposal, mineral extraction in general and existing consumptive water rights on the Lake.
It’s important to remember that Great Salt Lake does not have a water appropriation or water right for its own beneficial use. As an ecosystem that is both hemispherically important to millions of migratory birds and brings in billions of dollars each year to the economy of Utah, this is a problem. At our 2010 Great Salt Lake Issues Forum we talked about keeping the Lake wet. One strategy to achieve this would be to establish a conservation pool for the system. In order to sustain the array of uses and ecological targets for a viable system, all consumptive water right withdrawals would be curtailed at a specific Lake level. New proposals for Lake uses would be tabled and existing water uses would be significantly scaled down until Lake levels go back up. Reservoirs use this same principle.
According to the Matrix, at an elevation of 4,194’ there are 10.2 million acre feet of water in the Lake. At 4,193’ there are only 9.6 million acre feet – a 600,000 acre feet difference. The revised GSLCMP indicates that there are 334,845 acre feet of perfected water rights held by mineral companies on the Lake, and approved but undeveloped rights of over 300,000 acre feet. If the Lake elevation was at 4,194’ and all of the perfected and approved water rights were consumed, the elevation of the Lake would drop a full foot to 4,193’. Flows between the North and South Arm would cease. And Gunnison Island – an American White Pelican rookery - among other islands where birds are protected by surrounding water would become accessible by land for predators and human disturbance. It’s important to note that although GSLM has withdrawn its application for an additional 353,000 acre feet of water, by sealing its dikes to increase efficiency, the net consumption of water by the company at low Lake levels will increase over time as will the likelihood that at levels below 4,195’ resources will be impacted.
In our comments to the Corps on the 2013 expansion proposal, FRIENDS and Coalition members stated that if the proposal is approved, then brine extraction by Great Salt Lake Minerals should cease when the Lake level is at 4,194’. Which in fact should be the case for all water consumption of our Lake. Remember the conservation pool idea.
But this is just one example of water resource pressures that threaten the future of Great Salt Lake. While it is becoming obvious to many of us that we need to stop withdrawing water from the Lake at low Lake levels to avoid a tragedy of the commons, it continues to be a political nonstarter. FRIENDS believes there is no other choice. We must work to achieve solidarity with Lake users and upstream users to preserve and protect our Public Trust for future generations. In the words of Hunter S. Thompson ,“When it comes to things like this, you don’t fool around.”
“UPRR has stated that the proposed bridge is designed to maintain flows under “worse case” scenarios, yet this condition is impossible to define without context. The needs of mineral extraction, the brine shrimp industry, and the Great Salt Lake Ecosystem must all be considered before “worse” or best case scenarios can even be defined. UPRR has designed the bridge to mitigate flow, yet salt and mineral exchange is far more critical and this cannot be understood by the maintenance of flow alone.”
- The Utah Division of Water Quality in comments sent by the State to the U.S. Army Corps of Engineers on the proposed railroad construction
Each year, the Great Salt Lake Technical Team generates a list of “hot topics” for Great Salt Lake research proposals. Funded by the Division of Forestry, Fire and State Lands in the Department of Natural Resources, the research proposals are supposed to help the Division make “defensible” management decisions in support of maintaining the Great Salt Lake Ecosystem - in perpetuity - as a public trust for the people of Utah. (You can read more about the GSL Tech Team and hot topics at (http://www.ffsl.utah.gov/sovlands/greatsaltlake/gsltechteam.php)
The “hot topics” not only reflect the ecological complexities that comprise this unique and dynamic system, but identify imminent factors that could affect those dynamics. Factors with potential consequences that could impair this hemispherically important ecosystem that contributes $1.3B annually to the GDP of Utah. (I love that number).
Topics you would expect to see include, brine shrimp, water use and climate change, mercury, salinity balance, wildlife habitat, mineral extraction and phragmites. However, a welcome addition to the 2014 Hot Topics List just released by the GSL Tech Team is the “Potential causeway modification impacts.” A controversial project that involves the U.S. Army Corps of Engineers, the Union Pacific Railroad, and Great Salt Lake. This proposal has gone through twists and turns since February 2011. And it has generated great concern from federal and state agencies, the brine shrimp and mineral industries, and FRIENDS because of impacts the reconstruction of the railroad causeway could have on the ecology of the Lake. (For more background about the project visit www.fogsl.org ).
The proposal was initiated in 2011 by Union Pacific because of a history of structural problems the railroad was experiencing with two existing 15’ wide culverts. The west and the east culverts provide bi-directional flows between Gunnison Bay (North Arm) and Gilbert Bay (South Arm) of the Lake. Subjected to constant freight loads and located in the deepest part of the Lake where background seismic activity occurs in the lakebed, the culverts were cracking and sinking. Despite efforts to repair them, the railroad requested a Nationwide Permit (NWP) from the U.S. Army Corps of Engineers to streamline the process to close the culverts. To mitigate for the loss of flow, the railroad proposed the construction of a 150’ bridge (which morphed into 180’) on the west side of the causeway near an existing breach where the Lake is more shallow.
If you didn’t know better, you might think that what the railroad is proposing to do to address the safety issue and restore the bi-directional flow sounds like a good idea. However, if you know anything about the Lake and the historic imprint the causeway has created both on the Lake’s surface and to its system, then you can understand why these stakeholders, and in fact all of us should be concerned. We should expect a thorough analysis and rationale for the location, the structure, and the monitoring and mitigation of this work before it can move forward.
Much like the Wicked Witch of the West said as she contemplated removing Dorothy’s ruby slippers, “ These things need to be done delicately.” We need to be sure that the dynamics and complexities of the ecosystem are accounted for. We need to be certain that other Lake uses aren’t jeopardized. And we need to be clear that the onus must be on the railroad to prove that any causeway modifications will do no harm to our public trust.
Among the written comments submitted by stakeholder interests to the Corps was a letter from a mineral extraction operation in the South Arm. It raised numerous questions about basic assumptions in the design documents that were a part of the pre-construction application process for a NWP. There wasn’t enough data to either prove or disprove the engineering assumptions that were being proposed. And the assumptions also seemed to suggest that the calculations were based on a finite point in time, and did not consider the ongoing dynamic system response of the Lake as it comes to equilibrium.
With a request for the Nationwide permit pending, the Corps weighed the collective input it received from the Union Pacific Railroad, the agencies, industry and FRIENDS. Using its discretionary authority it notified the railroad in a letter on March 15, 2012 that the work would require authorization under a Standard Individual Permit. This would cast a wider net of stakeholder involvement, improve the analysis of the project, and bring additional tools to the table that would include updating the U.S. Geological Survey Salt Balance Model. At the same time, the Corps would work with the railroad to develop options that would address the culvert issue.
Pushback from the railroad on the Corps’ decision led to a meeting in Sacramento with the District Regulatory Division that proved fruitful for Union Pacific. On August 29, 2012, the Corps reversed its decision, authorized a Nationwide Permit, and gave the railroad permission to close the west culvert asap. However, the railroad still needed to resolve differences with the Division of Forestry, Fire and State Lands over an easement issue on sovereign lands. And it would need Corps approval of a Compensatory Mitigation and Monitoring Plan before the east culvert could be closed and the bridge construction begin. That’s one for Union Pacific – zero for the Corps.
The west culvert was closed on November 10, 2012. It required several dump trucks with fill and 60 cement trucks (570 yards of concrete) to plug it up. By Thanksgiving, Union Pacific was expected to submit its Draft Mitigation and Monitoring plan for review by the Corps but took an extension until January 4, 2013. Which brings us to where we are today.
Alas. After careful review of the draft Plan by the Corps and federal and state agencies, it appears that Union Pacific once again failed to get high marks for being thorough. Differences persist between the Corps and the railroad about the roles and responsibilities in the monitoring process and performance standards. There are different expectations about when monitoring should begin and how long the railroad is required to monitor to achieve success criteria. Real time water quality data to capture seasonal climatic and lake circulation patterns was not addressed. There was no mention of monitoring reports. And insufficient details in the adaptive management plan, bonding and reclamation plan put the dot on the “i “ in the word “inadequate”.
In short –things are right back where they started. Union Pacific has failed to work in earnest with the Corps to address agency and stakeholder concerns about potential impacts to the Lake and its water quality. And the railroad has still not resolved the easement issue with the Division of Forestry, Fire and State Lands.
Throughout this entire ordeal, state agencies, industry, FRIENDS and even EPA have advocated for a Standard Individual Permit to ensure that the project will not make matters worse for the Lake. Had the Corps stood its ground when it first asserted that such a permit would be required, we wouldn’t be in the fix we’re in today. But wait! There’s more.
After much deliberation, the Corps realized that under the parameters of a Nationwide Permit it was not able to determine whether the proposed project would cause no more than minimal adverse effects to Great Salt Lake. As a consequence, once again invoking its discretionary authority, it notified Union Pacific in a letter (February 21, 2013) that the project will be processed through a Standard Individual Permit. The last I heard, the Corps and railroad will be meeting in mid April. On Tuesday, April 23, the Corps will provide a update to the Great Salt Lake Technical Team on the Union Pacific causeway application process. Keep your fingers crossed.
What you can do: Be prepared to engage in a broader stakeholder process on this issue.
“We can only do what we can do with what we can do.”
- Kathleen Anderson, Regulatory Assistant, U.S. Army Corps of Engineers
On November 30, 2012, the Union Pacific Railroad must submit a “final compensatory mitigation and monitoring plan” to the U.S. Army Corps of Engineers for approval. This plan is a necessary component of Union Pacific’s work to repair the railroad causeway that crosses Great Salt Lake. The plan is part of the terms and conditions as defined by the Corps in its authorization of a Nationwide permit (NWP-14) issued on August 29, 2012.
More on this later, but first a little background -
The railroad has been seeking a Nationwide permit since 2011 because the West and East culverts in the causeway have had a history of reoccurring cracks. Concerned that this could be cause for the interruption of train traffic across the causeway or -- even worse – a derailment, Union Pacific was anticipating a fairly streamlined approval process with a favorable decision by the Corps to proceed. In place of the culverts, the railroad was proposing to build a 150’ long concrete-pile supported bridge on the western end of the causeway - known as the Rambo alignment - where the lakebed is more stable. Theoretically, this bridge would maintain the flows and salinity exchange between the North and South Arms of Great Salt Lake that the culverts currently provide.
Confident that authorization would be granted, Union Pacific was anticipating that the construction of the bridge would take place from June 2011 to September 2011 - a fairly ambitious timeline, to say the least.
FRIENDS has been tracking this issue since February 2011, when Union Pacific first submitted a preconstruction notification (PCN) to the Corps. This PCN was part of a pre-application process for a Nationwide permit. A number of factors must be considered for a project to qualify for a Nationwide permit. A preconstruction notice is required. Total permanent impacts must be under ½ acre with only minimal individual and cumulative adverse effects on the aquatic environment. The Corps must then review the project proposal to ensure that the adverse environmental impacts are minimal, and that there is no significant change to the hydrology of the receiving water body. Finally, the Corps must determine that mitigation for those impacts is appropriate under Special Conditions which mandate specific environmental requirements in order to minimize impacts under section 404 of the Clean Water Act.
If the impacts cannot be minimized, or if the project is contrary to the public interest, it may not be able to proceed under a Nationwide permit and would thus require either a regional General permit or Standard Individual permit. This would expand the process to include the development of an Environmental Impact Statement with various alternatives under NEPA (National Environmental Policy Act) based on the purpose and need of the project, and provide opportunities for the public to comment. It would also require a 401 Certification from the Utah Division of Water Quality to guarantee that Utah waters are protected from impairment. In other words, it would provide the opportunity for a full public process.
Although a Nationwide permit does not require external agency coordination or public comment, the Corps responsibly hosted a series of meetings and phone conferences with state and federal agencies during this pre-application process. They did so again in July 2011 when the railroad submitted its formal application. In both cases, the goal was to identify any major concerns with the project. All these state and federal agencies have some form of jurisdictional and stewardship responsibilities for Great Salt Lake, including environmental protection, management of our sovereign lands, wildlife resources, water quality, and other beneficial uses of the Lake. The U.S. Geological Survey Utah Water Science Center, the Great Salt Lake Advisory Council, the Great Salt Lake Technical Advisory Group, mineral evaporation operations, the brine shrimp industry, and FRIENDS were also involved.
After careful scrutiny of the proposal and in formal written comments to the Corps, the consensus of opinion was that there was insufficient analysis of the bridge design and location, and a general lack of confidence in the modeling Union Pacific used to predict the bi-directional flow of salts from north to south once the culverts were closed and the bridge constructed. The proposal also raised concerns about impacts to migratory waterfowl, impacts to mineral extraction industries, the potential to increase the amount of methylmercury in the system, unknown effects on the brine shrimp, and whether a Nationwide permit was the appropriate permitting option.
It is also unclear whether or not Union Pacific actually has an easement to build the bridge. According to the Division of Forestry, Fire and State Lands, which has jurisdictional responsibility for managing Great Salt Lake, Union Pacific is unable to provide documentation that verifies a right to an easement for the Rambo section of the causeway where the bridge would be located. Until this issue is resolved, the railroad does not have permission to build the bridge on sovereign lands. On October 16, 2012 the Division had still not been contacted by Union Pacific.
Because the bridge design will have a significant influence on the ecology of the Lake, it is critical that the potential effects of any new openings, or any closure of existing openings in the railroad causeway be simulated in a coherent manner. The prevailing perspective from the agencies and other Great Salt Lake stakeholders is that the best tool for the job is the Salt Balance Model developed by the U.S. Geological Survey Utah Water Science Center. However, this model hasn’t been updated since the report was published in 2000. Although the cost of updating the model is significant, the cost of constructing a bridge that proves to be detrimental to this hemispherically and economically important ecosystem is much, much higher.
Our position has always been that a train derailment because of structural failure of the culverts would be tragic and should be avoided. However, it is important to remember that we have a divided Lake today because the railroad causeway has made it so. And although the railroad would argue that the culverts were never intended to provide salinity exchange between Gunnison and Gilbert Bays, when they weren’t clogged with detritus from the Lake, they did in fact facilitate some exchange. This is a good thing because if you think about it –in a 21 mile rock-fill causeway that is essentially impermeable –the 3 existing openings (2 culverts and a breach) provide only about 330’ of potential bi-directional flow. If the USGS Salt Balance Model can deliver important insight for building the best bridge compared with a single calculation offered up by the railroad, then it would be prudent to update the model.
In a March 15, 2012, letter to Union Pacific responding to the July 2011 application for a Nationwide permit, the Corps exercised its discretionary authority to require that the application be processed for authorization under a Standard Individual Permit. It also recommended that the railroad consider updating the USGS Salt Balance Model while continuing to develop options that will temporarily stabilize the culverts. This recommended course of action was countered when Union Pacific requested a meeting on August 1, 2012 with the District Regulatory Division in Sacramento to discuss reconsideration of its Nationwide permit proposal and Preconstruction Notification.
On August 16th Union Pacific sent a letter to the meeting participants confirming the key points that were discussed. In the letter, the railroad asserts that its responsibilities and interests are limited to keeping the trains moving across the causeway. It contends that updating the Salt Balance Model would require a costly adaptive management approach for constructing the bridge. And it believes that the “best available current information” would suffice. It also argues that since the proposed bridge is not necessary to facilitate train operations on the causeway, the only reason it is willing to construct it is to accommodate “other interests.”
In partial response to that meeting, the Corps authorized a Nationwide permit (NWP-14) on August 29, 2012. This permit was authorized before the Final Compensatory Mitigation and Monitoring Plan is approved so that Union Pacific can move forward with an emergency closure of the West culvert of the causeway because of imminent structural failure. To compensate for this closure, Union Pacific is required to construct a 180’ long concrete pile-supported bridge on the west end of the existing causeway. It must also fulfill special conditions prescribed by the Corps to address appropriate monitoring tools and adaptive management measures to minimize impacts on the circulation of salts between the North and South Arms of Great Salt Lake.
Sadly, this Nationwide permit authorization directly contradicts the Corps’ statement of discretionary authority that was expressed in its March 15, 2012 letter to Union Pacific.
So where are we now?
When Union Pacific submits its Plan to the Corps it is likely that the state and federal agencies will have another opportunity to provide input – not that it seems to matter very much. And it will be interesting to see how the easement issue is resolved. Will Forestry, Fire and State Lands hold the line? Throughout this entire ordeal Union Pacific has taken a condescending and myopic approach to making any concessions that could benefit the Lake even though it is responsible for the impacts to the Public Trust that exist today. I am reminded of the signature quote from the 1967 Paul Newman film Cool Hand Luke –“What we’ve got here is failure to communicate.” Let’s hope in this case there’s a better outcome.
What you can do:
More information about this issue, including correspondence obtained through a Freedom of Information Act request (FOIA) filed September 17, 2012 can be found at www.fogsl.org. Stay tuned!
Spring 2012 Executive Director's Message
“If through scientific and economic analysis we can show the benefits that the natural environment offers, and show that the economic value is not zero, this gives policy makers a vehicle for addressing our fragile ecosystems."
- Edward B. Barbier, Professor of Economics, University of Wyoming
The road toward protecting Great Salt Lake for future generations is not as straight or as smooth as we might like it to be. As long as we have a management regime that is designed to facilitate multiple-use and sustained yield principles, there will be a tug of war between preserving the ecological integrity of the system and expanding development of the Lake’s resources to generate more jobs and more output.
That’s why it was terrific news to read the two studies commissioned by Governor Herbert’s Great Salt Lake Advisory Council (Advisory Council) in 2011. The studies, which were presented to the Natural Resources Appropriations Subcommittee during the 2012 Legislative Session generated insightful and compelling data about the importance of the Lake. Data that can help the Division of Forestry, Fire and State Lands (the Division) - responsible for managing the Lake - as it continues to grapple with this dynamic tension. And data which most certainly should inform the management strategies in the revisions of the Great Salt Lake Comprehensive Management Plan and Mineral Lease Plan, which are in final draft form and inviting public comment until April 26th.
The studies – “Economic Significance of the Great Salt Lake to the State of Utah” prepared by Bioeconomics, Inc., and “Definition and Assessment of Great Salt Lake Health” prepared by SWCA Environmental Consultants, confirm that the health of Great Salt Lake and the direct economic benefits of the Lake are inextricably linked. And that the total economic output that the Lake contributes to the State of Utah’s GDP through recreation, mineral extraction and the brine shrimp industry is $1.3 billion annually. Review the studies at: www.gslcouncil.utah.gov
Thanks to the Nature Conservancy of Utah for funding the studies,
the significance of these findings is that we have finally initiated a scientific and economic analysis of the Lake to justify its overall value as an ecosystem worth protecting. Big briny hugs, everyone!
The studies also emphasize that further work is required in both areas to develop a more comprehensive understanding about the synergy that exists between the Lake’s ecological health and the array of uses that generate output, income and employment. But because the Advisory Council can only serve in an advisory capacity, it cannot affect policy or management practices. Only the Division of Forestry, Fire and State Lands can do that.
Right now, cumulative permitted uses of the Lake are unaccounted for. The Division has no plan to determine what the long-term vision of ecological health of the Lake is supposed to be. And except for the insights that were gained from the Great Salt Lake Health study, there is no way of knowing whether or not the ecological integrity of the system is in peril.
That’s why FRIENDS believes that this is an excellent time for the Division to adopt a prudent management approach for the Lake. It should shift its management focus from resource use and development to resource protection and preservation. Such an approach would ensure that nothing is left up to chance about where we are headed with the future of Great Salt Lake. A tool that could help with this is the Great Salt Lake Health study.
This study was conducted by a blue ribbon panel of Great Salt Lake experts working with a process called Conservation Action Planning. Lake health in this case refers to ecological health which is determined by how well the lake functions to support significant bird populations, brine shrimp and reeflike stomatolitic structures.
Working with the lake in its current physical form – causeways, dikes and impounded wetlands – the panel considered each of the 4 bays – Gunnison, Gilbert, Farmington and Bear River. They chose to define health for eight ecological targets in and around the lake up to an elevation of 4,218’. (Historic average surface elevation is 4200’ asl).
The targets were selected because they represent the full range of biological diversity (different bird species, microbial life, salinity, and habitats) of the Great Salt Lake ecosystem. The ecological targets are: open waters of the bays, unimpounded marsh complexes, impounded wetlands, mudflats and playas, isolated island habitats for breeding birds, alkali knolls, grasslands and agricultural lands. Using these targets, each bay was rated for its current state of ecological health from very good to poor.
Although the findings indicate that the current ecological health of the Lake is relatively good, some bays are doing better than others. And many of the targets could not be thoroughly evaluated because of insufficient data, which means that more research is necessary to fill those important information gaps.
The study identified a number of existing and future stresses that could not only degrade these conditions, but have far reaching implications that “threaten the integrity of Great Salt Lake habitats and the ability of migratory bird species to use the Lake ecosystem.” These stresses include reduction in lake levels that can cause a variety of impacts on the brine shrimp population, island nesting birds, and salinity. Phragmites - an invasive plant that thrives during low lake levels and degrades habitats. And the loss of alkali knolls – important shrubby mudflats.
So where do we fit into all of this in our role as stewards for Great Salt Lake?
Submitting comments by the April 26th deadline on the revised Great Salt Lake Comprehensive Management Plan and Mineral Lease Plan is the first step. Emphasize that the public must be involved in the heart of the process for evaluating new and renewing proposals for resource development. Insist that site specific planning be a part of each proposal before it is submitted. And urge the Division to initiate the development of a long-term plan that will ensure ecosystem health and biotic integrity for Great Salt Lake. The plan should include goals, conservation targets, threats, monitoring strategies, and appropriate actions that will protect and sustain the trust resources of the Lake.
Together we can work toward a future for the Lake that is both environmentally and economically beneficial for all of us. We have the tools to do it and the numbers to prove it.
Over the past 4 years, FRIENDS has been extremely fortunate to have Emily Gaines working with us as our Education and Outreach Director. Through her dedication and hard work, Emily has inspired all of us to be better Lake educators and Lake advocates. She was truly a gift to FRIENDS and Great Salt Lake. We wish her all the best in her new position with the University of Utah. Thanks Em!
We should bill the lake for what it is—a place of grandeur and solitude, which nourishes our thoughts and heightens our sensitivity to nature. Seen in that light, the brine flies become a fascinating curiosity more than an annoyance. The Great Salt Lake offers a wilderness experience, not a beach party, and no amount of promotion and development will change that.
Dean L. May, Images of the Great Salt Lake
Save the dashing of the waves against the shore absolutely nothing is heard. Not the jumping of a fish, the chirp of an insect nor any of the least thing betokening life, unless it be that very rarely a solitary gull is disturbed in his midnight rumination and flies screaming away. All is stillness and solitude profound.
Captain Howard Stansbury, The Stansbury Expedition