Comments from Lynn de Freitas below, followed by additional commentary submitted by Wayne Wurtsbaugh.
December 4, 2017
Re: 20-Year Compact Review Members of the Bear River Commission
On behalf of FRIENDS of Great Salt Lake (FRIENDS), thank you for this opportunity to comment on the need to amend the Bear River Compact. FRIENDS is a 501(c)(3) non-profit membership organization. Our mission is to increase public awareness and appreciation of the Lake and to preserve and protect the Great Salt Lake Ecosystem for future generations through education, research, advocacy, and the arts. Because Great Salt Lake is a terminal lake that is located at the bottom of a 22,000- square mile hydrologic drainage basin, the Lake depends on precipitation and water inflows from the watershed to sustain its important ecosystem services. These ecosystem services include critical habitats and food resources for millions of migratory birds that stage, rest and nest at the Lake, as well as important economic resources that include the brine shrimp industry, mineral extraction, recreation and tourism, and extraordinary archeological resources that are symbolic of this unique place in the Great Basin. On behalf of its members, FRIENDS participates in processes to protect and improve Great Salt Lake health and sustainability. We do this by helping to forge sustainable policy development and encourage management and regulatory measures that represent responsible stewardship practices.
For the purposes of these comments, I would like to encourage the Commission to reexamine the Compact in light of the devastating impact to the Great Salt Lake ecosystem that will result should development of the Bear River go forward as outlined in the Compact. Specifically, Article V of the Compact refers to further development of the remaining water in the Lower Division and specifies that: (1) Idaho shall have the first right to deplete 125,000 acre-feet of Bear River water; (2) Utah shall have the second right to deplete 275,000 acre-feet; and, (3) that both Idaho and Utah shall each have an additional right to deplete 75,000 acre-feet.
Should this additional 550,000 acre-feet of water be developed, the Utah Division of Water Resources estimates that the Lake could be lowered by as much as 12.3 feet. While such a drop in water level will essentially dry up both Bear River Bay and Farmington Bay, long before this occurs the increase in salinity in the dropping Lake will exceed a level that will destroy both the brine shrimp and brine fly populations that sustain over 7.5 million birds each year. Additionally, the likely impact on the $1.3 billion that the Lake contributes to Utah’s economy each year is incalculable.
Recognizing that the provisions of the Compact were agreed to in light of precipitation and water trends that have changed substantially in the last forty years, without regard to the “what if’s” of climate change and mega drought cycles, and at a time when we knew much less than we know now about the Lake, and its importance both ecologically and economically, I urge you to amend the Compact to account for these changed circumstances and to the known impacts these depletions will have to Great Salt Lake.
Thank you for your consideration of these comments and for the opportunity to submit them as a part of the 20-Year Compact Review.
In saline and sustainability,
Lynn de Freitas, Executive Director
FRIENDS of Great Salt Lake
Bear River Compact and the Great Salt Lake Wayne Wurtsbaugh, Dec. 3, 2017
The Bear River Compact needs to be modified to incorporate the current understanding of the value and of the hydrology of Great Salt Lake. When the Compact was formed, the public assumed that any water that reached the lake was wasted. However, we now understand the critically important role of this water for industry, aquaculture, recreation, health, climate control and bird populations of the Great Salt Lake ecosystem. The dollar value of the lake is currently assessed at $1.3 billion (Bioeconomics 2012), but that value does not include intrinsic cultural or ecological values, nor the value of the lake for protecting human health and providing an abundant snowpack in the Wasatch Mountains.
To date, water use for agriculture, urban and other uses has lowered the lake 11 ft. from its natural level (Wurtsbaugh et al. 2017; Wurtsbaugh et al. 2016), and exposed 590,000 acres (54%) of the lakebed. The shallow and critically important Bear River Bay and Farmington Bay estuaries have 75%-85% of their areas dried during the summer, limiting habitat for water birds. The exposed lakebed allows dust storms to impact the Wasatch Front cities, creating respiratory problems (Griffin and Kellogg 2004) for the population. Water development of the Bear River has already compromised the Great Salt Lake ecosystem.
The current plan of the Bear River Compact allows for an additional 550,000 acre-feet of water to be depleted from the system, which will greatly decrease flows into Great Salt Lake. The median estimate of the impact of this flow reduction would be to lower the lake an additional 4.5 ft. from current conditions, expose a total of 680,000 acres of lakebed, decrease the volume to 30% of natural, and increase salinities in the south arm of the lake (Gilbert Bay) to ~220 g/L. Bear River and Farmington Bays would be dry during most of the year. Note, however, that the potential impact of the 550,000 acre-feet of water depletion is even more severe, and maximum estimates of this by the Utah Division of Water Resources suggest that the lake could be lowered an additional 10 ft., exposing approximately 785,000 acres of lakebed, decreasing the volume to 20% of the natural value and increasing salinity to near saturation. Given the range of predictions from the median to the maximum impacts, it is obvious that more work on the hydrology of the watershed is needed, but both scenarios indicate that flow reductions would have profound impacts on the environment and human health.
To put these impacts in perspective, managers need to consider the desiccation of Owens Lake in southern California. When water was diverted from the lake it dried completely, exposing 70,000 acres of lakebed. Dust storms have impacted the health of the small community of Bishop and even more distant cities. To mitigate these impacts, the Los Angeles will spend $3.6 billion over 25 years to protect the health of residents (Ramboll Environ US Corporation 2016). Consider what the impacts could be on the 2.5 million residents of the Wasatch Front if 685,000-785,000 acres of the lakebed of Great Salt Lake are exposed! Additionally, the ecology of the lake would be severely damaged. The dried estuary areas would greatly reduce bird use. Brine shrimp populations, which are important source of food for birds and the $60 million dollar aquaculture industry, would be decimated. If salinities increased to 220 g/L, brine shrimp production would be reduced to less than 10% of that at natural lake levels (Barnes and Wurtsbaugh 2015), and if salinities increased to near saturation, brine shrimp and all invertebrate food production in the lake would disappear--we would have another "Dead Sea". It is fortunate that the Bear River Compact is under review, given that we now realize the major impacts that additional water development would have on the lake.
Major water depletions of fresh water from the Bear River and other tributaries of the lake are not warranted until we maximize conservation of this precious resource. The future growth of the Wasatch Front is sometimes cited as a need for water development in Utah. However, given that Utah currently has among the highest per capita water use in the country, and that people in cities such as Tucson use only 50% of what Salt Lake City residents use, it is clear that we have tremendous potential to conserve water. Water conservation programs in the agricultural sector also need to be implemented and enforced. Modification of existing, and outdated water laws in the tristate region could also allow significant transfers of water from the agricultural sector to provide for the expanding urban population and to protect Great Salt Lake and other natural systems (Clyde 2016).
Thank you for considering my input, and please do not hesitate to contact me if you have questions. Wayne Wurtsbaugh, Emeritus Professor, Utah State University (firstname.lastname@example.org).
Barnes, B.D., and Wurtsbaugh, W.A. 2015. The effects of salinity on plankton and benthic communities in the Great Salt Lake, Utah, USA: a microcosm experiment. Can. J. Fish. Aquat. Sci. 72(6): 807-817.
Bioeconomics, I. 2012. Economic significance of the Great Salt Lake to the State of Utah. Great Salt Lake Advisory Council (Activities), Salt Lake City, Utah. https://deq.utah.gov/great-salt-lake-advisory-council/docs/2012/Jan/GSL_FINAL_REPORT-1-26-12.PDF
Clyde, S.E. 2016. Water rights for Great Salt Lake: is it the impossible dream? p. 1-29, Utah Water Law, CLE International, Salt Lake City, Utah. http://www.clydesnow.com/images/Articles--Great-Salt-Lake-Paper-2016-01090010xB165B.pdf.
Griffin, D.W., and Kellogg, C.A. 2004. Dust storms and their impact on ocean and human health. EcoHealth 1: 284-295.
Ramboll Environ US Corporation. 2016. Great Basin Unified Air Pollution Control District: 2016 Owens Valley Planning Area PM10 State implementation plan. Great Basin Unified Air Pollution Control District, Bishop, California. 1494 p. http://www.gbuapcd.org/Air%20Quality%20Plans/OVPA_SIP_2016/2016_SIP_FINAL_20160413.pdf.
Wurtsbaugh, W.A., Miller, C., Null, S.E., DeRose, R.J., Wilcock, P., Hahnenberger, M., Howe, F., and Moore, J. 2017. Decline of the world's saline lakes. Nature Geoscience 10(11): 816-821 (DOI: 810.1038/ngeo3052).
Wurtsbaugh, W.A., Miller, C., Null, S.E., Wilcock, P., Hahnenberger, M., and Howe, F. 2016. Impacts of Water Development on Great Salt Lake and the Wasatch Front. White paper issued from the Quinney College of Natural Resources (Utah). http://digitalcommons.usu.edu/cgi/viewcontent.cgi?article=1891&context=wats_facpub.