FRIENDS of Great Salt Lake - Winter 2010: Mounting Pressures on the System Require a New Approach to Lake Management

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Executive Director's Message

Winter 2010: Mounting Pressures on the System Require a New Approach to Lake Management

Winter Newsletter

Executive Director’s Message

Mounting Pressures on the System Require A New Approach to Lake Management
– Shift the Focus from Resource Use to Sustainability of the System.

“The issue is as much about the process as the heritage.”
-   Dr. Genevieve Atwood, geologist and educator

In late September, the Division of Forestry, Fire & State Lands posted a Request for Proposals for environmental planning consultants to review and update both the 2000 Great Salt Lake Comprehensive Management Plan (CMP) and the 1996 Great Salt Lake Mineral Leasing Plan (MPL). The purpose of the review and update is “to identify issues and concerns relative to the sovereign lands and resources at Great Salt Lake and apply comprehensive studies and new information that has accumulated over the last 10 years.”

These two planning documents essentially steer the Division’s management direction on the use of the lake’s resources and where development of these resources can occur. But the Division’s management obligation does not stop there. By law, the Division is required to execute its authority as a trustee of the Public Trust of the sovereign lands of Great Salt Lake. In that capacity, it is charged with managing these trust resources in perpetuity for the people of Utah. As such, it must ensure that any use of Great Salt Lake does not interfere with navigation, fish and wildlife habitat, aquatic beauty, public recreation, and water quality on or in the lake. The protection of these “public trust values” trumps any other use on sovereign lands –including development.

Given that both planning documents are well beyond their sell by date, the announcement came as welcome news to FRIENDS and other Great Salt Lake stakeholders. We continue to express concerns about the planning documents being out of sync with more recent scientific findings. We acknowledge that past and current management practices have resulted in the radically altered natural lake system that we have today. And we continue to see the Division support proposals that increase the industrialization of the lake. Most recently is the proposed expansion of Great Salt Lake Minerals. The Division appears to be doing this without the knowledge of what the cumulative impacts on the ecological health of the system will be.

Despite this initial measure of good news, after reviewing the detailed scope of work in the RFP, it was discouraging to read that although some attention will be given to issues and concerns relative to Great Salt Lake, the document will still be mired in predictable management tendencies. It appears that the Division will continue to abide by its piecemeal approach by restricting the scope of its decisions for this hemispherically important ecosystem to competing uses - commercially weighted scenarios vs environmentally weighted ones vs something in between.

That’s why FRIENDS and members of the conservation community believe that it’s time to shift the focus from resource use to protection and sustainability of the system. The current approach continues to move lake management further away from lake protection. Instead of pitting Great Salt Lake against development and discharge proposals, the ecological health of the system should be the foundation from which all other uses are allowed to occur. In light of the mounting pressures on the system from population growth, water quality concerns, limited water resources, climate change and an emphasis on industrialization, we believe this is the most prudent way to proceed.

After 10 months of deliberation on existing lake management and ways to improve it, this is the same conclusion that the Great Salt Lake Advisory Council came to with its recommendation that a permanent Great Salt Lake Commission be established. The objective of the Commission is to design and help implement strategies for the sustainable use and protection of Great Salt Lake and its ecosystem. Working with a Science Advisory Panel, among the many tasks the Commission would assume is the establishment of indicators of ecological health for the lake and measureable goals for each indicator. The Commission would act in an advisory capacity to inform regulatory agencies such as the Division of Forestry, Fire & State Lands about these goals. Had the Commission been in place by now, it would be involved in the revision of these planning documents and the public process ahead. Unfortunately, plans to move forward with the formation of the Commission have been stalled.

Nevertheless, sometime in 2010 a series of public open houses will be scheduled in the 5 counties surrounding the lake. This will be an opportunity for all of us to express our concerns and provide input for the next iteration of the two plans. To prepare for these meetings, now would be a good time to review the existing planning documents and identify critical factors that must be addressed to protect and sustain the lake’s ecosystem. Links to these documents are available on our website's weblinks: www.fogsl.org

For starters, during the revision of the CMP in 1999, a Scientific Review Committee was established to verify and validate the scientific underpinnings presented in the “Statement of Current Conditions and Trends” section. The goal of the review process was to “offer an unbiased assessment of the technical information base utilized by the Department of Natural Resources to make decisions and tradeoffs concerning Great Salt Lake. “ The committee’s work culminated in a report titled Evaluation of the Scientific Underpinnings of the May 1, 1999 Great Salt Lake Planning Document. Among the many insightful points that were raised in that report are the following:

•   Knowledge of the relationship between lake hydrology and global climatic    processes should be important to DNR managers, yet there is virtually no mention of climate in the CMP.
•      The CMP does not discuss drought as a serious concern.
•   Natural lake level fluctuations are an important component of the GSL Ecosystem and should be recognized as such by the State of Utah.
•      The CMP implies that a change in upstream depletions of 100,000 acre-feet per year will affect lake elevation by about one foot. It is not clear whether the one-foot differential would be the cumulative result over time or that for a given year. Further the document offers no detailed analysis of the net change in lake inflows that will result from anticipated or planned upstream diversions and water imports. More information regarding future water development in the watershed of GSL is available within DNR and should be used to address concerns about changes in magnitude and direction of lake levels due to human intervention.
•      The natural variability of GSL is not adequately addressed in the CMP. Pre-causeway salinity conditions have not been adequately discussed.

Another insight to consider is located on p. 41 of the Mineral Leasing Plan/Issues & Opportunities Related to Monitoring and Revision of Mineral Leasing Plans. It reads:

“Volumes of research are available on various aspects of the lake’s ecosystem and human impacts on the system. However, the long term trends on many aspects of the lake are not adequately understood or easy to predict. Significant changes take place on the lake on an annual basis with regard to water inflows and level; salinity in various areas of the lake; location, numbers and concentrations of biological resources to name the most prominent resources. Mineral operations can have significant impacts (some adverse, some neutral, some possibly enhancing the lake’s ecosystem) on these variables through diking projects, pollution, depletion of salts in the lake, disturbances of bird populations, and other activities. The impact of mineral operations is not systematically documented nor are parameters or indicators set up which would signal if and when and to what degree a change in leasing and regulator policies or direction might be necessary.”

Recently, the Department of Natural Resources approved an administrative rule change that says if a comprehensive management plan is in effect, no site-specific planning is required. The old rule says that both could be appropriate in a given situation. In the current MLP, areas of the lake are designated as OPEN for oil/gas and mineral extraction. This designation precludes the need to conduct site specific analysis with each proposal that comes forward for consideration. We’re not so sure that streamlining the process works in the best interest of protecting the resource especially if, as indicated in the excerpt above, there are no parameters or indicators set up to act as red flags in changing course.

The bottom line here is that this is our lake and it’s our responsibility to advocate for its sustainability. The issues are big and the threats imminent. As we engage in the public scoping meetings ahead, let’s do everything we can to shape the two planning documents to accurately reflect not only the complexity of the lake, but identify sustainable limits for all lake uses so that we can keep our lake Great.

In saline,

Lynn

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