November 16, 2021

Comments on Water Resources Plan

After extensive review of the Division of Water Resources' draft Water Resources Plan, attendance of the virtual open house hosted on October 20th, and discussion about what we see and don’t see included, below are comments that FRIENDS of Great Salt Lake will be submitting to the Division of Water Resources as part of the public commenting process. We've emphasized how critical it is that when we talk about water in the second driest state in the nation, we need to be honest in the way we portray this limited resource, and recognize our collective duty to move forward in a responsible and effective way to address the obvious challenges that come with it. 


FRIENDS of Great Salt Lake - Water Resources Plan Comments

Dr. Wayne Wurtsbaugh's Comments

Public comments will be accepted through Monday, November 15, 2021. 

Comments can be submitted using this form or emailed directly to

Access the Water Resources Plan here.


Although we have chosen these specific areas for the focus of our comments, we hope that our members and the public will find other important points to make that will serve to strengthen the plan so it can better serve as a reliable reference for how we regard our water resources in the second driest state in the nation.

Selected Comment Message Points:

  • This plan should function as the roadmap for how the state will face an uncertain future, and as such it needs to be based in reality – and not myths or wishful thinking. The Division should be upfront with the public by acknowledging that we can’t have it all and that hard choices will have to be made. A plan based on myths and wishful thinking is merely a fantasy, and while fantasies can be comforting, real life plans based on fantasies lead to disasters. 

  • The biggest fantasy of all is acting as if it’s perfectly feasible for the Division to pursue the goal of getting more water to Great Salt Lake at the same time it is pursuing the goal of developing the Bear River. The Division does the public a great disservice by holding those two goals up side-by-side and implying that both are possible. They are not, and the Division needs to be upfront and acknowledge that they are not. The citizens of Utah have a choice: they can either help save Great Salt Lake, or they can move forward with development of the Bear River. They cannot do both. There is no scenario where both are possible short of a complete reversal of the impacts of climate change on the state. It is nothing short of audacity for the Division to advocate “Keeping the ‘Great’ in Great Salt Lake” in the same document where it outlines how it is going to destroy the Lake through the Bear River development. It is equally audacious for the Division to estimate that the impact on the Lake of the Bear River development will be a mere 8.5 inches drop in elevation, without acknowledging the cumulative impact over time on the Lake of this diversion. The Division must also acknowledge that the size of the proposed diversion has to be significantly greater than the 220,000 acre-feet it intends to provide users due to system losses and evaporation.

  • Great Salt Lake is a Public Trust resource, held in trust by the State, and the state agencies whose actions impact the Lake have a moral, ethical and legal obligation to ensure that those actions do not infringe on that resource.

  • It is time for the Division to stop pretending that we will have all of the water we want going forward, and be upfront with the people of Utah that there are stark choices staring us in the face unless we significantly change our approach to water use. That starts by drafting a plan that tells the citizens of Utah the uncomfortable truth: we live in a desert, and it’s time we start acting like it.

Please submit your comment by Monday, November 15 to strengthen the Water Resources Plan as a tool to make informed water management decisions.

Comments can be submitted using this form or emailed directly to