From the Division of Water Resources:

Development of the Great Salt Lake Basin Integrated Plan (GSLBIP) is underway, and we need your input!

As part of the GSLBIP, the Division of Water Resources and its partners are simulating how the water supply system and water demands in the basin, as well as how Great Salt Lake and the surrounding wetlands, could be impacted by climate in the future. This will allow us as a community to test the effectiveness of different strategies under stressed or extreme conditions that have not been seen in recent history.

Researchers at the University of Utah are working with the United States Bureau of Reclamation to summarize results from Global Climate Models (GCMs – which simulate future climates) to apply to our Great Salt Lake Basin. We need input from you on the type and timing of climate changes that most affect your organization to best tailor the model results.

Click the button below to complete our brief survey. The survey will close on September 13, 2024.

Take the survey 

A vital ecological and economic resource in Utah, Great Salt Lake faces unprecedented challenges due to declining water levels. For three decades, FRIENDS of Great Salt Lake has been a staunch advocate for its protection, tirelessly working to preserve this unique ecosystem. As the Lake's health becomes increasingly precarious, we continue to adapt our strategies to address emerging threats. Our recent focus on challenging groundwater appropriations and protesting wastewater reuse applications demonstrates our commitment to achieving comprehensive watershed-based restoration and protection for the Great Salt Lake ecosystem. These efforts are crucial steps towards ensuring the Lake's future and increasing public awareness of its importance.

Challenging Groundwater Rights Applications

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.

Unfortunately, the State Engineer has interpreted the protections afforded by the Proclamation as excluding groundwater inflows to Gunnison Bay, also known as the North Arm of Great Salt Lake. This interpretation 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 dramatically 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 have begun challenging applications for new groundwater appropriations that we believe violate the provisions of the Proclamation. These challenges are grounded in Utah water law, citing specific statutes such as Utah Code Ann. § 73-3-8, which outlines the criteria for approving water right applications. [Click here] to see an example protest of a Water Right Application.

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.

Wastewater Reuse Permits

Because Great Salt Lake is a terminal lake, all water going through sewer treatment plants in the Great Salt Lake watershed eventually makes its way to the Lake. As water standards become more stringent for the treatment of discharges from these plants, and as water discharges from the plants become cleaner, municipalities in the Great Salt Lake Basin have begun to look at reusing their discharge water as a source of secondary water, primarily for irrigation. However, because taking all of that water out of the system will have a significant negative impact on the water balance for the Lake, the Wastewater Reuse Act requires these municipalities to file a water replacement plan along with their reuse application.

Unfortunately, most of the municipalities have taken the position that they have a right to reuse the water they discharge from the plants without replacing that water. This stance directly conflicts with recent legislative efforts to protect and preserve Great Salt Lake. The significance of maintaining adequate water in the Lake cannot be overstated, given its essential role in supporting over 10 million migratory birds and its importance to the local ecology and economy.

In response to this situation, we have begun challenging these applications because they lack a replacement plan. To date, we have filed protests on reuse applications totaling more than 150,000 acre-feet. As part of this ongoing work, we have submitted numerous protests to the State Engineer, [Click here] to see an example.

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.

Ongoing Work

By challenging groundwater appropriations and insisting on responsible wastewater reuse practices, we are working to ensure that the intent of protective legislation is upheld and that the long-term health of Great Salt Lake remains a priority. As water scarcity becomes an increasingly pressing issue in the American West, the actions taken to protect and preserve Great Salt Lake in perpetuity serve as a model for balancing ecological preservation with human needs. Our ongoing efforts highlight the critical importance of informed, proactive stewardship in safeguarding this hemispheric treasure for future generations.

The Utah Geological Survey recently released the Utah Groundwater Data Hub, an important resource to help us understand groundwater storage and inflows in the state. 

To learn more about the Utah Groundwater Data Hub, you can read this article by Carter Williams of the Great Salt Lake Collaborative:
https://www.ksl.com/article/51093522/new-utah-hub-shines-light-on-states-more-mysterious-water-source

More on Groundwater:
If you've been paying attention to Great Salt Lake news over the last few years, you've likely heard that our understanding of groundwater inflows to the Lake has changed significantly. The most recent estimate, by Hector Zamora and Paul Inkenbrandt estimates that groundwater contributes 313,500 acre feet to Great Salt Lake annually. Because groundwater storage and inflows are notoriously difficult to measure, the growth of this field is important to understanding implications of groundwater storage to the Lake's health. This year, Sam Carter received a Doyle W. Stephens Scholarship for his research on groundwater inflows to Farmington Bay. Click here to watch Sam's presentation on his research at the 2024 Great Salt Lake Issues Forum. 

BYU's Abbott Lab of Ecosystem Ecology worked with a team of 32 researchers and managers to put together an emergency briefing on Great Salt Lake. The briefing provides an overview of the lake's ongoing collapse and call for the establishment of a minimum flow requirement to restore the lake.

View or download the full report as a PDF.

Great Salt Lake is facing unprecedented danger. Without a dramatic increase in water flow to the lake in 2023 and 2024, its disappearance could cause immense damage to Utah’s public health, environment, and economy. This briefing provides background and recommends emergency measures. The choices we make over the next few months will affect our state and ecosystems throughout the West for decades to come. We thank all those already working on solutions, and we thank you for considering this information.

Authors: Benjamin W. Abbott1, Bonnie K. Baxter2, Karoline Busche1, Lynn de Freitas3, Rebecca Frei4, Teresa Gomez1, Mary Anne Karren3, Rachel L. Buck1, Joseph Price1, Sara Frutos1, Robert B. Sowby1, Janice Brahney5, Bryan G. Hopkins1, Matthew F. Bekker1, Jeremy S. Bekker1, Russell Rader1, Brian Brown1, Mary Proteau1, Gregory T. Carling1, Lafe Conner6, Paul Alan Cox7, Ethan McQuhae1, Christopher Oscarson1, Daren T. Nelson8, R. Jeffrey Davis9, Daniel Horns8, Heather Dove10, Tara Bishop11, Adam Johnson12, Kaye Nelson12, John Bennion12, Patrick Belmont5

1Brigham Young University, 2Westminster College, 3Friends of Great Salt Lake, 4University of Alberta, 5Utah State University, 6Wasatch High School, 7Brain Chemistry Labs, Jackson Hole, 8Utah Valley University, 9Integral Consulting, 10Great Salt Lake Audubon, 11Ph.D. Research Ecologist, 12Conserve Utah Valley

Executive summary

1. Great Salt Lake is a keystone ecosystem in the Western Hemisphere. The lake and its wetlands provide minerals for Utah’s industries, thousands of local jobs, and habitat for 10 million migratory birds1–4. Fertilizer and brine shrimp from the lake feed millions of people worldwide5,6. The lake provides $2.5 billion in direct economic activity yearly7–10, as well as increasing precipitation, suppressing toxic dust, and supporting 80% of Utah’s wetlands11–17.
2. Excessive water use is destroying Great Salt Lake. At 19 feet below its average natural level since 1850, the lake is in uncharted territory18–22. It has lost 73% of its water and 60% of its surface area23–26. Our unsustainable water use is desiccating habitat, exposing toxic dust, and driving salinity to levels incompatible with the lake’s food webs1,24,27–29. The lake’s drop has accelerated since 2020, with an average deficit of 1.2 million acre-feet per year. If this loss rate continues, the lake as we know it is on track to disappear in five years.
3. We are underestimating the consequences of losing the lake. Despite encouraging growth in legislative action and public awareness, most Utahns do not realize the urgency of this crisis. Examples from around the world show that saline lake loss triggers a long-term cycle of environmental, health, and economic suffering30–35. Without a coordinated rescue, we can expect widespread air and water pollution, numerous Endangered Species Act listings, and declines in agriculture, industry, and overall quality of life1–4,36.
4. The lake needs an additional million acre-feet per year to reverse its decline. This would increase average streamflow to ~2.5 million acre-feet per year, beginning a gradual refilling. Depending on future weather conditions, achieving this level of flow will require cutting consumptive water use in the Great Salt Lake watershed by a third to a half. Recent efforts have returned less than 0.1 million acre-feet per year to the lake37, with most conserved water held in reservoirs or delivered to other users rather than released to the lake.  
5. Water conservation is the way. While water augmentation is often discussed (pipelines, cloud seeding, new reservoirs, and groundwater extraction, etc.), conservation is the only way to provide adequate water in time to save Great Salt Lake33,38–41. Conservation is also the most cost effective and resilient response42,43, and there are successful examples throughout the region44–48. Ensuring financial, legislative, and technical support for conservation will pay huge dividends during this crisis and for decades to come1,38,46,49.
6. We need to increase trust and coordination. New legislation allows users to return water to the lake while retaining rights50. However, lack of trust and cooperation between farmers, cities, managers, and policymakers is hobbling our response33,38. Users often have financial disincentives to conserve, and farmers often lack legal counsel to navigate policy changes.
7. We call on the governor’s office to implement a watershed-wide emergency rescue. We recommend setting an emergency streamflow requirement of at least 2.5 million acre-feet per year until the lake reaches its minimum healthy elevation of 4,198 feet51. Executive leadership is needed for water leasing, farmer compensation, water donations, and conveyance52. Every major water user needs to be educated, empowered, and assured that their conserved water will be shepherded to Great Salt Lake. We need clear thresholds that trigger binding emergency conservation measures to stop the lake’s collapse.
8. We call on the legislature to fund and facilitate the rescue. Recent bills have laid the groundwork, and a surge of funding is now needed to lease or purchase water and support farmers and cities to dramatically reduce consumption. Likewise, legislation is needed to put in place the policies, accounting, and monitoring for water shepherding to the lake and long-term sustainable water use52.
9. We call on every water user and manager to conserve water and support state efforts. We are in an all-hands-on-deck emergency, and we need farmers, counties, cities, businesses, churches, universities, and other organizations to do everything in their power to reduce outdoor water use. We believe that our community is uniquely suited to face this challenge, but only if we implement a unified and pioneering rescue. By taking a “lake first” approach to water use, we can leave a legacy of wise stewardship for generations to come.

 Click here to read the full report.

By: Ben Winslow

Posted at 12:00 AM, Jan 05, 2023 and last updated 11:30 AM, Jan 05, 2023

Click here to read the full article on the Fox 13 News website.

SALT LAKE CITY — A group of researchers and environmentalists are calling for an "emergency rescue" by policymakers to save the Great Salt Lake.

In a new report issued Thursday, 31 different conservationists and researchers from 11 academic institutions declared that Utahns are "underestimating the severity of consequences if the lake's decline isn't reversed." It warned that the Great Salt Lake could vanish within five years if no action is taken and called for emergency measures by the Utah State Legislature and Governor Spencer Cox.

Among the action items, a minimum of 2.5 million acre-feet of water going into the Great Salt Lake to reverse its collapse. That would require at least 30-50% reductions in water consumption in the Great Salt Lake watershed, from agriculture to residential.

But the report cautions that you cannot blame any single group (agriculture is a favorite target as it is the state's largest water user). Instead, the authors urge solidarity among all water users to save the Great Salt Lake. The lake has declined as a result of water diversion and a changing climate to its lowest levels in recorded history. A declining lake presents an existential threat to Utah. There's toxic dust storms, decreased snowpack, billions in economic losses and the loss of habitat for millions of migratory birds and other wildlife.

"It is really encouraging to see the level of community involvement and leadership around Great Salt Lake. State leaders, farmers, and so many others are working on exactly the kind of long-term solutions we need," said Dr. Ben Abbott, a professor of aquatic ecology at Brigham Young University and one of the authors of the report. "However, the lake is really close to the edge, and the decisions we make in the coming few months will affect our community and ecosystems across the hemisphere. This winter’s above-average snowfall gives us a chance to give the lake a much- needed infusion of freshwater, but that’s only going to happen if we come together and put an emergency rescue into place. We need bold leadership and support from every water user and organization in the watershed."

Click here to continue reading this article on the Fox 13 News website.

The Nature Conservancy • In this three-part series, we'll explore the complex story of a natural wonder whose fate will be decided on our watch.

Dogged Conservation and Optimism

Human health. Jobs. Global industries. International wildlife significance. For the Great Salt Lake, the key boxes all seem to be checked. Yet those working for the Lake's protection over the years have had to wage an uphill PR battle. 

The Nature Conservancy (TNC) made its first purchase at the Great Salt Lake in 1984, protecting wetland bird habitat threatened by development. Since then, TNC has worked with a suite of partners to protect more than 12,000 acres of wetlands and uplands around the Lake, including the Great Salt Lake Shorelands Preserve which stretches 11 miles and 4,531 acres along the Lake’s eastern shore, and serves as a crucial buffer against fast-growing development in Davis County.  TNC also works with the Utah State University Botanical Center to run Lake-based outreach and education programs, which have reached more than 20,000 Utah students to date. Over the years, TNC has supported new science on Lake health and championed policy changes to enhance Lake protection and management. Ann Neville, TNC Utah’s Northern Mountains Regional Director, oversees current protection work at the Lake. “I think we’ve reached a time to truly celebrate the Lake,” says Neville. “For me, getting the right partners in the room, and seeing the traction we’re gaining is energizing.” In terms of conserving habitat around the Lake, TNC and many other entities have made real progress—sanctuaries around the Lake have also been established by Audubon, the State of Utah, and the U.S. Fish and Wildlife Service.

“The Great Salt Lake has always been one of our top priorities,” says Dave Livermore, TNC’s Utah State Director. “For more than 35 years, many of us have been beating this drum, and trying to safeguard the most vulnerable elements of the system—and honestly, just trying to give the Lake a seat at the table.”

Another veteran Lake advocate, Lynn de Freitas, the Executive Director of FRIENDS of Great Salt Lake (FOGSL), is also cautiously optimistic today. FOGSL is dedicated to growing an appreciation of the Lake through education and advocacy programs, and De Freitas has spoken out about threats to the Lake for years—from pollution to diversion to development. “It’s a never-ending battle, but I feel we’re moving in a positive direction. If we act in a timely way with a collective will, we can avert horrific results for people, for wildlife and for the world.  Utah can still offer a success story.”

Building Consensus

Why is effectively protecting the Great Salt Lake such a tall order? It’s not just about the Lake’s public image. Part of the challenge, explains Laura Vernon, is the complexity of the Lake ecosystem itself and the way it’s managed by the State of Utah. Vernon is the Great Salt Lake Coordinator with Utah Department of Natural Resources Division of Forestry, Fire and State Lands. Her position is relatively new, and an indicator that state officials are realizing the need for better management across the Lake’s many moving parts. “You have the bed of the Lake, the water flowing to the Lake and the water in the Lake, as well as some of the lands around the Lake all being overseen by different divisions and departments,” Vernon says. “There has not been one entity responsible for looking at the Lake watershed as a whole.”

Vernon, who’s been working on Lake issues for 10 years, is feeling a new optimism. “It’s shocking to me how little attention the Lake has gotten historically, but things have grown leaps and bounds, even over the last year.” 

She points to new, ongoing funding for the GSLAC, the Great Salt Lake Advisory Council led by Don Leonard, which this past fall released a report highlighting 12 key strategies to keep water in the Lake.  The report’s recommendations range from changing Utah water law and creating new incentives for agricultural and municipal water conservation to new tools for the acquisition of water rights that could protect the Lake’s inflows.

“The report concluded that while each of the strategies will improve water management, a combination of key strategies is necessary to improve water delivery to Great Salt Lake,” says Leonard. “I’m pleased with the focus on the report and the attention it’s getting.  We are working to build consensus behind the strategies.”

Consensus, Vernon hopes, is what may finally lead to a turning point. “It’s been impressive to see such a range of different stakeholders uniting behind a cause. I remember going on a tour out to Stansbury Island in the middle of the Lake with TNC and other conservation groups as well as folks from the mineral extraction industry. And they were all saying the same thing. It was remarkable.”

Flows, Laws and Progress

Still, even with strange new bedfellows holding hands, reversing water level declines at the Great Salt Lake will be no small endeavor. The strategies outlined by GSLAC are up against a special kind of inertia. “Implementing the strategies would require changes in some policies, practices, laws and regulations,” notes Leonard, “many of which have been in place for a long time and are institutionalized.  Such changes require deliberation and mutual understanding.  An important next step is securing understanding by and support from agriculture interests.”

Historically, Utah ranks high on state water consumption lists. Residents themselves could choose to make easy choices that would help, from repairing leaky faucets and taking shorter showers, to not overwatering their lawns. A large percentage of Utah’s water use, however, goes to agriculture. Legal issues governing western water users and historic laws are complicated and sensitive with far-reaching impacts. And pressures are mounting from all sides. Just this summer, more than 99 percent of Utah fell into “extreme” or “exceptional” drought conditions, per the U.S. Drought Monitor. According to the Utah Geological Survey web site “Increasing per capita water use coupled with rapid population growth and projected reductions in both snowpack and streamflow due to changing climate is not sustainable.”  Water management is top of mind for Utah leaders.  But for many years, the Great Salt Lake has been an afterthought.  In fact, the State has never had a formally implemented policy to maintain Great Salt Lake water levels at any particular elevation range.

Despite the challenges, Representative Tim Hawkes, the Republican state legislator from northern Utah, is confident. In 2019, he led the passage of House Concurrent Resolution 10, which called on the State to support additional studies to understand the causes and impacts of the declining Lake levels. “I've never been more optimistic about the future of the Lake. HCR-10 has had remarkable staying power,” he says. “Now it feels like we’ve moved into more of a ‘research and testing’ phase. How do we better direct resources to answer critical scientific questions? How do we engage stakeholders in new and meaningful ways? How do we test drive solutions under existing legal authority on a small scale?”

In the most recent 2021 Legislative session, Hawkes successfully prompted Utah policy-makers to approve funding for two new Great Salt Lake projects: one is a study that will better quantify the contribution of groundwater to Great Salt Lake and its wetlands, while the other is an effort to support local governments that are interested in incorporating smart water planning into their land use planning processes. According to Hawkes: “I think it’s important for people to understand one critical fact: people can make a difference. Losing the Lake is not a foregone conclusion. Best available modeling suggests that, with some sensible and sustained effort, we can keep Lake elevations in a range where the Lake continues to support all its primary beneficial uses.”

Seeing Beyond Today

While Hawkes is convinced that the Lake’s impact on public health and the economy will motivate his fellow legislators, he’s also moved by the plight of the birds. “I remember one moment it hit home for me, the amount of life the Lake supports,” he says. “I took a trip to Promontory Point along the Union Pacific causeway in early autumn. From the moment we could see water south of the causeway to the moment we arrived on Promontory, the edge of the water was black with a thick band of countless birds. It went on for mile after mile. I've never seen so many at one time and in one place.”

It’s the type of epiphany that’s welcomed by Ella Sorensen, manager of the Edward L. and Charles L. Gillmor Audubon Sanctuary, a 3,597-acre preserve on the Lake’s South Shore. A chemist by training, Sorensen has spent decades studying the Great Salt Lake’s birds and writing about the Lake for the Salt Lake Tribune. When I ask her how to explain the Lake’s importance to someone on the street, she sighs. “It’s not effective to say things about Great Salt Lake. What works is to bring people out here.”

As Sorensen flicks mud from her boot tip, her soft, white hair lifts in the afternoon breeze. She’s just spent hours walking her daily route through the sanctuary’s sludgy marsh, which provides vital habitat for migratory shorebirds such as American avocets and snowy plovers. “I bring people out here who’ve lived in Utah their whole lives, but never understood the Lake until they came and saw the birds and the wetlands for themselves. It’s tremendously powerful.”

Perhaps that sheer Lake life force is part of what Terry Tempest Williams wanted us to contemplate when she wrote Refuge, 30 years ago. Her life story was inextricably linked to the Lake and the birds—and so is ours.  We share in nature’s bounty, and in its decline.

Thirty years ago, Williams described living in a “virtually uninhabited” area near the Great Salt Lake. Today over 60 percent of Utah's population (more than 2.5 million people) live within 20 miles of the Lake.  What will the next 30 years bring?  For people?  For the Great Salt Lake? For the birds?  That answer, according to Williams, hinges on our choices. “The eyes of the future are looking back at us,” she wrote, “and they are praying for us to see beyond our own time.”

Click here to read this series on The Nature Conservancy website.

KUER 90.1 | By Jon Reed

Published July 7, 2021 at 5:00 AM MDT

The Great Salt Lake is reaching its lowest level ever. That brings huge environmental costs, from worse air quality to habitat destruction for migratory birds.

It also affects some important industries in Utah’s economy. Businesses that rely on the Great Salt Lake — recreation, mineral extraction and harvesting brine shrimp eggs — bring roughly $1.3 billion to the state’s economy, according to a 2012 report.

Don Leonard, chairman of the Great Salt Lake Brine Shrimp Cooperative, said eggs from the lake’s brine shrimp are a crucial food source for the fish and shrimp eaten around the world. About 40% of the world’s brine shrimp eggs come from the lake but with lower water levels, the water gets saltier, which makes it harder for the shrimp to reproduce.

Leonard said less water also means egg harvesters are spending close to $1 million dredging the bottom of the lake in order to get their boats out.

“We need to be able to have our boats go out on the lake, harvest eggs and then bring our eggs back to shore,” he said. “You need so much water to float your boats, right? So as the water level goes down, we have to lower the bottom of the harbor down an equivalent amount.”

Those kinds of costs drive up the price of the eggs and make Utah business less competitive in an increasingly global market.

Laura Vernon, Great Salt Lake Coordinator with the Utah Division of Forestry, Fire and State Lands, said the impacts to mining magnesium and other minerals also has ripple effects throughout the economy.

“If you pick up a pop can, if you sit on a stadium bench, all of these materials have elements of the Great Lake in them,” Vernon said.

Minerals from the lake are also used to make car parts, cell phones and fertilizer for crops around the country. Some of the companies that rely on the lake are the country’s largest or only suppliers of certain materials.

The total cost of further water loss is estimated to be around $2 billion a year and more than 6,500 jobs. That doesn't include additional expenses for better water management, protecting migratory bird species and mitigating invasive plant species.

“We've all been watching the lake level as it's gone down and this unanticipated drought has definitely expedited concern,” Vernon said. “It's giving us an opportunity to kind of adapt and maybe look a little more quickly to put some of the strategies in place that we have been talking about over the last couple of years.”

Vernon said the state is looking at 12 primary strategies for protecting the lake, including changes to state law that would promote water conservation, which it doesn’t currently do. Likely all of them will be needed to ensure the Great Salt Lake isn’t depleted altogether, she said.

Click here to read this article on the KUER 90.1 website.

“That’s not what they told us at the time,” he said. “Nope, I was never told that.” Rep. Lee Perry, Chief Sponsor of HJR 20—Joint Resolution Approving Class V Landfill for Promontory Point Resources, LLC during the 2016 Utah Legislative Session.

- 2/6/18 Standard Examiner, Box Elder lawmaker has mixed feelings about pushing Promontory landfill approval by Leia Larsen

On October 20, 2020, for the second time, Promontory Point Resources, LLC (PPR), a subsidiary of Allos Environmental of California, submitted a Class V permit application to the Utah Division of Waste Management and Radiation Control (Division). If approved by the Division and the Governor, a Class V permit would allow PPR to bring out-of-state industrial waste to its landfill facility on the SW tip of the Promontory Peninsula in Box Elder County. This location is completely unsuitable for a landfill because of the hydrogeologic connectivity between the landscape and Great Salt Lake that surrounds the peninsula on its three sides. Compelling evidence supports the fact that this particular area of the Lake is seismically active. And the landfill location would threaten a hemispherically significant ecosystem that supports millions of migratory birds, and contributes $1.32B, including 7,700 jobs, annually to Utah’s economy.

During 2017, the first time PPR applied and tried twice to show that another Class V permit was needed in the state, an independent review of PPR’s application and Needs Assessment concluded that the company failed to show that another Class V landfill was needed, especially given that we already have over 1,600 years’ worth of Class V storage. Well aware of PPR’s Class V pursuit, a wide range of Great Salt Lake stakeholders and FRIENDS hosted public outreach programs with the Division, raising questions and concerns about the practices of PPR and the prospect of a Class V landfill on the shores of Great Salt Lake. A white paper presented to the Division by the Great Salt Lake Institute, Great Salt Lake as an Ecologically Significant Natural Area, summarized research from scientific literature, the brine shrimp industry, mineral extraction industry, and ongoing research of all the major institutions of higher education in Utah to help guide decision-making regarding permitting of a Class V landfill operation in close proximity to the Lake. Even the Great Salt Lake Advisory Council, which advises the Governor, the Dept. of Natural Resources, and the Dept. of Environmental Quality on the “sustainable use, protection, and development of Great Salt Lake” submitted a letter requesting “further studies to determine the full extent of risks and the adequacy of the measures designed to address them.” Having failed to show that another Class V landfill was needed, PPR withdrew its application in February 2018.

However, PPR’s failure to show that need prompted the company to try another approach: make an end run and lobby the Utah Legislature to change the law by removing the Needs Assessment for Class V permits. Fortunately, those attempts during the 2019 and 2020 legislative sessions failed, but the takeaway here is that PPR tried to skirt the existing laws it couldn’t satisfy by simply getting rid of them. So why is PPR reapplying?

Because out-of-state waste is where the money is.

In the 2020 Class V application, the Needs Assessment takes a completely different approach to the question of “need” than it did in 2017. This new—and theoretically improved—application focuses much more on out-ofstate markets. Using these new criteria, the assessment concludes that there is, in fact, such a need. In conversations that FRIENDS had with the Division about this critical difference, we encouraged the Division to not simply take the company’s word for it, but instead to conduct an independent review of the company’s conclusions. In letters that FRIENDS and other conservation organizations sent to the Division, we emphasized that without an independent assessment of underling premises contained in the latest Needs Assessment, the Division has no basis for concluding that the underlying facts and conclusions contained in that assessment are accurate. Given that, we would expect the Division to pursue the review in order to make an informed decision on this important matter.

A March 3, 2021 article California Dreamin’? written and researched by Eric Peterson and Jennifer Greenlee of The Utah Investigative Journalism Project in partnership with The Box Elder News Journal, calls into question both the assumptions used in the assessment regarding the extent of the available California market, as well as some possible conflicts of interest among the relationships of the various parties involved in the PPR landfill. Given the ambitiousness of PPR’s proposed Class V operations plan, and the possible adverse consequences of getting it wrong, it is absolutely critical that the assumptions and conclusions contained in this latest Needs Assessment be verified. And although nowhere in the application does PPR indicate that it would consider out-of-state coal ash—a waste product from coal fired power plants that contains toxic substances like mercury, arsenic, and lead from throughout the United States—once a Class V permit is issued, a subsequent provisional request could be made to the Division to bring these wastes into the state. So due diligence NOW is imperative.

A little bit of historical perspective always helps:

Way back when in 2001, two thousand acres of land on the SW tip of the Promontory Peninsula were purchased by Promontory Point Land Resources, LLC to create a landfill. After a bewildering number of name and legal status changes, in 2004 the Division granted a Class I permit to Promontory Landfill, LLC allowing that new owner to take in-state municipal waste once certain conditions were approved by the Division. Those conditions included construction of the facility and installation of groundwater monitoring wells, a financial assurance bond to cover closure and postclosure costs, and contracts with local governments. Around 2016, having recently purchased the relatively unchanged property that came with the Class I permit (due to expire in August 2021), PPR secured $16.25M in bonding from the Utah Private Activity Bond Authority. Around this same time, PPR managed to persuade Representative Perry to sponsor legislative approval of PPR’s Class V plans (HJR 20), a necessary step for a Class V permit. With bond money burning a hole in their pockets, in 2017 PPR used those funds to construct the first phase of its landfill, but without letting the Division know it was doing that. The Division only learned that construction had begun through a news report, even though coordinating construction of a landfill with the Division is standard procedure. Details, details.

This pattern of begging forgiveness rather than asking permission was repeated when the company installed its three new monitoring wells without Division approval. In fact, the Division went on to suggest that the company conduct a “flow and transport model” to ensure PPR had adequately placed its wells to detect leaks. The company “disagreed,” refused to do the modeling, and insisted that the Division approve the wells it had already installed. Given that the purpose of the monitoring wells is for early detection of waste stream contaminants that leave the landfill and percolate into the surrounding landscape and the groundwater that flows to the Lake, this is where FRIENDS stepped in to challenge the Division’s approval of those wells without that modeling.

The issue is that the substrate of the landscape where PPR’s facility is located is fractured bedrock, and experts agree that strategic placement and depth of the monitoring wells under this circumstance must be informed by flow and transport modeling to maximize early detection of leaks. Compelling data exists to support evidence that regardless of how durable landfill liners are, they eventually will leak. And the placement of monitoring wells to detect leakage is critical to addressing the problem early on. Adding insult to injury, when a landfill is located next to a waterbody, the contamination to the environment is compounded exponentially. In this case, the Great Salt Lake ecosystem would be the recipient of these contaminants which would impact the unique ecological values of the system that affect the food web for birds and brine shrimp, as well as adjacent industrial mineral operations like Compass Minerals that produces organic potassium sulfate, a fertilizer for fruits and nuts. Bruce Anderson, president of Mineral Resources International, a family-owned company that harvests minerals from the Lake that are sold as human supplements to more than 50 countries stated, “We’re concerned about the unknown that is not adequately planned for, and that’s why I believe that site should have been considered a fatal flaw to begin with because of the inability to plan for and mitigate the huge risk in the event of a significant natural disaster.”

Which brings us to PPR with a newly constructed landfill that’s been empty for almost four years, and with over $16 million in bonds that have to be paid off. Why is it empty? Because there’s a tight municipal waste market; the landfill is located where it would take lots of truck trips and lots of miles to haul waste to its facility, and with all of that the company has failed to secure any municipal contracts. That math, along with mounting financial pressures, has put PPR in a position where it either obtains a Class V permit for the Promontory Point landfill, or the state is left with a very expensive hole in the ground.

As an aside, during the 2021 session, a commendable step toward justice was taken by Rep. Tim Hawkes who sponsored HB 399—Approval of Nonhazardous Solid or Hazardous Waste Facilities. The law requires that legislative approval of a nonhazardous solid or hazardous waste facility be automatically revoked if an application is withdrawn. Although the sweep of the law could not be retroactive to include PPR, it’s a step in the right direction for the future to prevent the legislature from providing a “blank check” for applications that lack merit. So much for hindsight, right?

Meanwhile, given that the Division has shown a pattern of simply endorsing whatever PPR wants to do, and has failed to require the company to take the steps necessary to show that this landfill will not substantially harm the Lake, there’s no reason to believe that the Division will act differently if it approves PPR for its Class V permit. As for PPR, we have very little faith that the company will police itself, be accountable and transparent in its practices, and regard the significance of the Great Salt Lake ecosystem. With all of that, and because FRIENDS’ mission is to preserve and protect the Lake, we strongly oppose the company’s efforts to obtain this Class V permit. This landfill sits on the very shores of the Lake—which would be a scary prospect even if the landfill contained nothing but local waste. It’s unfathomable that PPR might actually make Promontory Peninsula the dumping ground of the West. I trust that you feel the same. And if you do, I hope you’ll join us in expressing your opposition to the Division about this permit.

In saline and spring,

Lynn

“Unless people start caring and start acting, the Great Salt Lake will only be in increasing danger of, quite literally, drying up and blowing away.”

-Salt Lake Tribune Editorial, No Lake City (8/28/20).

We live along the shores of something GREAT – Great Salt Lake. This is still the case and should always be the case. Since statehood, the state of Utah has had a legal stewardship responsibility to manage the sovereign lands of Great Salt Lake in perpetuity as a Public Trust resource. It says so in Article XX, Section 1 of the Utah Constitution. This mandate requires the state to oversee effective management of this ecologically unique and economically significant saline system. However, it’s also a system that, in the peculiar language of Utah’s Prior Appropriation Water Law, is not considered a “beneficial use”. That means that any drop of water that sits in Great Salt Lake is considered wasted.

So what’s so special about a terminal lake that has no outflows? A lake that’s a remnant of ancient Lake Bonneville, a once deep fresh water system about the size of Lake Michigan. That’s about 20,000 sq. mi. of landscape covering most of western Utah and parts of eastern Nevada and southern Idaho. A unique but somewhat peculiar system that lies at the bottom of a 21,000 sq.mi. hydrologic drainage basin with a growing population of over 2 million people. A system that has a salinity range from 6% - 27% which is between 2 to 7 times saltier than the ocean. Now a relatively shallow lakescape - 33 ft. at its deepest - that in recent history has fluctuated in size by hundreds of square miles and in elevation by 20 ft. depending upon precipitation and inflows. A lake that is often characterized as buggy, stinky, salty, and a dead sea.

“Great Salt Lake is unique among the great American lakes, arresting in its name, yet least known. Its name itself has an aura of the strange and the mysterious, but it resists those who would know it. Lake of paradoxes, in a country where water is life itself and land has little value without it, Great Salt Lake is an ironical joke of nature – water that is itself more desert than a desert.” The Great Salt Lake by Dale L. Morgan. 1947.

And why does this Public Trust resource require a commitment from the state of Utah to manage it in perpetuity?

Let’s take a closer look at the one and only Great Salt Lake. The namesake of Utah’s state capital, a rich and integral part of our cultural heritage, an underpinning that has shaped traditions, and an endless source of research, literature, visual art, and the natural beauty of this place we call home. The largest salt water lake in the Western Hemisphere and the 8th largest terminal lake in the world. Located in the second most arid state in the nation where only 1% of its total area is wetlands. 75% of those wetlands are located on and around Great Salt Lake. In addition to providing important habitat, wetlands control flooding, reduce erosion, and act as filters that improve water quality. Wetlands in Utah have declined from 1.2 million acres in the 1950’s to approximately 400,000 acres today. So we need to keep what we still have. Thanks to the report by Bioeconomics, Inc. January 2012. Economic Significance of the Great Salt Lake to the State of Utah. Prepared for the Great Salt Lake Advisory Council we have a broader understanding about the economic values this Public Trust resource provides.

The economic output of the Great Salt Lake Ecosystem is $1.32 billion annually. That contribution to Utah’s G.D.P. comes from mineral extraction, brine shrimp harvesting (aquaculture), and recreation (waterfowl hunting, bird watching, boating, swimming/general recreation). Income from total labor is $375.1 million and total employment (full and part-time jobs) from those three sectors is 7,706. In addition, the Lake has a significant “net economic value” between $46.4 million to $98.8 million. These are dollars that would be spent if resource users such as waterfowl hunting, non-hunting recreational use, Publicly Owned Treatment Works (POTWs), and industrial dischargers were charged the full market value or price of services received from the ecosystem.

There are also important passive use values that are derived from simply knowing that the Lake’s natural environment and populations exist in a viable condition. And that the resource will be available for future generations of wildlife and people. We also know that water in the Lake suppresses dust from an otherwise exposed lakebed, as well as enhancing our snowpack in the Wasatch with its “Lake Effect”.

" The Great Salt Lake is ornithologically the most impressive salt lake on the continent.” Dr. Joseph R. Jehl Jr.

The ecological values of this remarkable system are equally awesome. In addition to resident populations of mammals, reptiles, amphibians, snakes, fish and birds, we have an extraordinarily wide embrace of migratory birds that elevate the Lake to a global scale of importance. This is evidenced by 10 million migratory birds – about 3 times the current population of Utah- that rely on Great Salt Lake for food and habitat critical to the lifeblood and promise of their future. 338 species of birds representing noteworthy avian populations that includes 30% of the Pacific Flyway come here for resting, staging and nesting as they make their migratory journey through the Western Hemisphere. Here’s a sample of this impressive flock: Wilson’s Phalarope -340,000 - largest staging concentration in the world, American Avocet-250,000 – many times higher than any other wetland in the Pacific Flyway, Snowy Plover- nearly a quarter of the continental population, millions of the Eared Grebe population depend on GSL, American White Pelican-one of the top five breeding populations in North America, and more than 500 wintering Bald Eagles; one of the top ten winter populations in the lower 48 states come here too.

It should come as no surprise that feeding and housing these astonishing numbers also requires water. Without water, islands are no longer islands, submerged aquatic vegetation is no longer submerged, and microbialites aka “Great Salt Lake coral” are unable to fulfill an important role in the food web of the system. Microbialites are calcium carbonate structures formed by the hydrogeological connectivity between the landscape and the lakebed. They carpet most of the lakebed and serve as a food browse source for brine shrimp and are an integral part of the life cycle of brine flies. Both of these critters are vital food sources for birds because they are very high in protein. Brine flies also break down organic matter that would otherwise accumulate in and around the ecosystem.

Because of this impressive bird use all five bays of the Lake have been designated Important Bird Areas by the National Audubon Society. And in 1991, Great Salt Lake was designated a site of “Hemispheric Importance” within the Western Hemisphere Shorebird Reserve Network. But even though the Lake provides this endowment of exceptional beneficial uses, water; its lifeblood - is not considered a beneficial use under Utah water law. This confounding disposition severely complicates the mandate that “We the People” have been given to sustain this truly remarkable place. Compounded by climate change, an average daily per person water consumption of 232 gallons (2015), and a growing population projected to reach 6 million people by 2060, these alarming conditions do not bode well for our Lake’s future. Oy!

A timely and insightful white paper Impacts of Water Development on Great Salt Lake and the Wasatch Front. Wayne Wurtsbaugh et al. February 2016 not only gives us a troubling glimpse of the past but serves as a warning about the future. The report found that since the pioneers arrived in 1847, water development and river diversions for consumptive water uses for municipal and industrial purposes, agricultural activities, reservoirs, and evapotranspiration have produced a persistent reduction of flows into Great Salt Lake by nearly 40%. This reduction has effectively dropped the Lake’s average elevation by 11’, shrinking it in size by almost 50%.

We’ve learned from other saline systems that significant water diversions not only impact ecosystem services but public health as well. Exposed lakebeds generate dust that contributes to air pollution. Billions of dollars are required to mitigate these impacts but many of them can never be fully realized. According to Craig Miller, Utah Division of Water Resources and contributor to the aforementioned white paper, “There are always big ups and downs but the long term trend is down. Based on historical observations, the “average” level of the Lake is said to be 4,200’ above sea level. But with all the modern-era water development upstream, the Lake currently hovers between 4,195’ and 4,196’ above sea level with normal weather.”

On November 16th at the Saltair Boat Harbor, the surface elevation of Great Salt Lake was 4,192.2’. This is 1.2’ above the 1963 record low of 4,191’.

In 2008, when FRIENDS co-hosted the Joint Conference of the 10th International Conference on Salt Lake Research and 2008 FRIENDS of Great Salt Lake Issues Forum 315 participants from 19 countries attended. The program title was Saline Systems Around the World: Unique Systems with Unique Values. Dr. Robert Jellison, limnologist who has done extensive research on Mono Lake, another hypersaline system, and a research associate with the Marine Science Institute, U of California, Santa Barbara, CA. was one of the plenary speakers. The title of his presentation was “The Conservation and Management of Salt Lakes: Past, Present, and Future.” Jellison noted that in the context of conserving these water bodies, agricultural diversions of fresh water in the last several decades has permanently changed these lakes for the worse, while at the same time their ecological importance to migrating and breeding birds has become widely recognized. As for their outlook going forward, he stated that “[t]he future of many saline lakes will be decided over the next several decades as the direct economic value of fresh water inflows are weighted against the less easily measured ecosystem goods and services provided by these unique ecosystems.” So too with Great Salt Lake.

It's imperative that we recognize water for Great Salt Lake as a beneficial use and incorporate measures to support its sustainability. Someone characterized this recognition as “Moving foundation blocks rather than having an earthquake.” Let’s work together to ensure that we have a return on our investment in this phenomenal Public Trust resource. Let’s keep the Lake GREAT. Afterall, Great Salt Lake is the gift that keeps on giving; just add water.

In saline and optimism,

Lynn

USGS Great Salt Lake Hydro Mapper

The USGS Great Salt Lake Hydro Mapper provides easy access to three information resources for Great Salt Lake:

• Salinity and Lake Levels
  • Graphs that show the relationship between salinity and lake level as well as satellite imagery of the changing lake surface area.
• Water Data
  • Lake levels for the southern and northern arms of the lake and discharge for locations on major surface water inflows are included.
• Great Salt Lake Basin Water Dashboard
  • Interactive map that provides real-time stream, lake and reservoir, and groundwater data for USGS observation stations. Weather and other hydrologic information can be added as layers to the map.

Great Salt Lake Resolution (HCR-10) Steering Group

Recommendations to Ensure Adequate Water Flows to Great Salt Lake and Its Wetlands

In response to the decrease in Great Salt Lake levels, the Utah Legislature passed “Concurrent Resolution to Address Declining Water Level of Great Salt Lake” (HCR-10) in 2019. The resolution recognizes “the critical importance of ensuring adequate water flows to Great Salt Lake and its wetlands to maintain a healthy and sustainable ecosystem.” To avoid adverse impacts to Utah’s economy, environment, and the public health of its citizens, long-term watershed planning is required. HCR-10 recommended that a diverse group of stakeholders convene to make recommendations on how to ensure adequate water flows to Great Salt Lake. Their report was completed in December 2020.

• Executive Summary
• Full Report

Great Salt Lake Advisory Council Resources

The Great Salt Lake Advisory Council (GSLAC) was established by the Utah State Legislature in 2010 to address the complex management challenges facing the Great Salt Lake ecosystem. Stakeholders from various industries, state agencies, and environmental organizations are represented on the council, who meet every-other month to discuss solutions to complex issues. Meetings are open to the public and prior meetings can be viewed on the GSLAdvisory Youtube Channel. 

Conservation Impacts Study

To inform future water resource planning decisions that may affect Great Salt Lake, the Conservation Impact Study examines the potential impacts of water conservation on water resource planning and develops an action plan of additional studies needed to assist policy makers in more completely understanding the role of conservation in future water resource planning. This evaluation focuses on four primary water providers in northern Utah: Bear River Water Conservancy District (WCD), Cache Water District, Jordan Valley WCD, and Weber Basin WCD. The Study finds that if additional water conservation efforts can significantly decrease water use, there is the potential to further delay, reduce the magnitude, or perhaps even eliminate the need for future large water development projects, such as the currently defined Bear River Development project.

• Conservation Impacts Study (6.4 MB)
• Executive Summary (2 MB)
• Press Release (128 KB)
• Presentation from Bowen and Collins (GSLAC 9/9/2020)

Water Strategies for Great Salt Lake

Building upon the work completed in 2017 to compile potential strategies to address declining lake levels, GSLAC commission Clyde Snow & Sessions and Jacobs Engineering, Inc. to evaluate priority strategies thought to have a high potential to improve water management and increase water deliveries to Great Salt Lake. GSLAC identified 12 priority strategies are organized as Foundational, Operational, and Tactical in nature. Foundational Strategies are intended to remove legal constraints to delivering water to Great Salt Lake. The Operational Strategies serve to inform decision and policy makers, water users, and managers. Tactical Strategies serve to incentivize water users to protect, conserve, and make available water that could be used for deliveries to Great Salt Lake. The Report is intended to provide specific useful information on each strategy so the water user community can choose where to spend their resources in achieving the overarching goal of maintaining or increasing Great Salt Lake levels.

• Final Report (8 MB)
• Executive Summary (2 MB)
• Strategy Fact Sheets (5 MB)
• Presentation from Emily Lewis to the July 8th, 2020 GSLAC

Consequences of Declining Water Levels

To better understand the implications that could result from continued declining water levels at Great Salt Lake, the Great Salt Lake Advisory Council commissioned two reports:

The first report, “Consequences of Drying Lakes Around the World,” examines eight lakes with similar characteristics to Great Salt Lake. It found that drying lakes result in billions of dollars of economic losses, require extensive mitigation efforts and pose severe threats to human health and the environment.

• Consequences of Drying Lakes Around the World,” February 15, 2019, prepared by AECOM Final Report (2 MB)
• Summary Report (3 MB)

The second report “Assessment of Potential Costs of Declining Water Levels in Great Salt Lake,” synthesizes information from scientific literature, agency reports, informational interviews, and other sources to detail how and to what extent costs could occur at sustained lower lake levels.

• Assessment of Potential Costs of Declining Water Levels in Great Salt Lake
• Executive Summary

Water for Great Salt Lake

In response to an observed long-term decline in Great Salt Lake water levels, in 2017, GSLAC, in cooperation with SWCA Environmental Consultants, compiled a list of potential strategies to increase or maintain water delivery to Great Salt Lake. Strategies were solicited and submitted anonymously or without attribution. This document is intended to facilitate a discussion of potential strategies to maintain or increase the surface elevation of Great Salt Lake. The list is not exhaustive, but reflects an attempt to compile a wide range of strategic options. No ranking or prioritization was completed as part of the compilation process. Inclusion in this document does not constitute an endorsement of any individual strategy by GSLAC or its members. These strategies are ongoing topics of discussion for GSLAC.

• Water for GSL Report

Great Salt Lake Health and Economic Significance

During 2011, the Great Salt Lake Advisory Council commissioned two reports to provide information that will aide the council in advising the Utah administrative and legislative bodies on the sustainable use, protection, and development of the Great Salt Lake.

The two major reports and the name of the contractor that led the effort were:

1. Definition and Assessment of Great Salt Lake Health led by SWCA Environmental Consultants and Applied Conservation
2. Economic Significance of the Great Salt Lake to the State of Utah led by Bioeconomics Inc.

Final Reports were submitted to the Council at the January, 2012 Work Meetings. Please click on the links below to view the fact sheets and final reports:

• Definition and Assessment of Great Salt Lake Health: Fact Sheet, Final Report
• Economic Significance of the Great Salt Lake to the State of Utah: Fact Sheet, Final Report

Past Activity