You don't need to be a lawyer. It takes about 5 minutes. There is a $15 filing fee.
Guide by Deeda Seed
WHAT THIS IS ABOUT
The Stratos/Wonder Valley data center project has a water rights change application on file with the Utah Division of Water Rights. Change Application a54385 proposes 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."
The application is currently unapproved and several protests have been filed.
The protest deadline is Tuesday May 5, 2026 — the day after the Box Elder County Commission vote.
Why this matters:
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. The project's own technical representative publicly claimed 3,000 AF on-site and 10,000 AF near Snowville, yet only 1,900 AF has been filed. The numbers don't add up, and the State Engineer should not approve this application without a complete water budget.
HOW TO FILE ONLINE — STEP BY STEP
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: a54385
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 a54385 / Water Right 13-4148.
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.
ALTERNATIVE: FILE BY EMAIL (FREE)
If you prefer not to pay the online fee, you can email your protest directly to the Division:
Email to:
Subject line: Protest — Change Application a54385, Water Right 13-4148
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: Email protests may take longer to process. File as early as possible before May 5.
WHAT TO WRITE — TALKING POINTS
Write in your own words. Any genuine concern about public interest counts. Here are specific points you can use — pick one or several:
Short version (copy and paste this if you want to keep it simple):
"I protest Change Application a54385 on public interest grounds. The proposed water use for a multi-gigawatt power plant is not adequately described or justified in the application. The source stream, Salt Wells Spring Stream, is 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 1,900 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 1,900 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 1,900 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 proposed change converts seasonal agricultural use (April through October) to year-round industrial use (January through December). This is a fundamentally different pattern of demand on a spring-fed aquifer system and will affect the timing and volume of return flows.
— Utah is at 19% of normal snowpack — the lowest 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.
AFTER YOU FILE
Share this guide. Post it. Forward it. Text it. The more protests on record, the stronger the signal to the State Engineer and to commissioners that the public is watching this application.
Share Grow the Flow's guide via Instagram.
PROTEST DEADLINE: Tuesday May 5, 2026
BOX ELDER COUNTY COMMISSION VOTE: Monday May 4 at 4:00 p.m. | Box Elder County Fairgrounds, Fine Arts Building | 320 N 1000 W, Tremonton, Utah
Read a recap of the Box Elder County Commission meeting on April 28.
