US Magnesium Canal Continuation SPK-2008-01773 Comments 9SEPT2022

Office of the Governor
Public Lands Policy Coordinating Office
REDGE B. JOHNSON
State of Utah Executive Director
SPENCER J. COX
Governor
DEIDRE M. HENDERSON
Lieutenant Governor
September 9, 2022
Submitted via electronically: [email protected]
Michael Pectol
Project Manager
US Army Corps of Engineers, Sacramento District
Bountiful Regulatory Office
533 West 2600 South, Suite 150
Bountiful, Utah 84010
Subject: US Magnesium Canal Continuation

SPK-2008-01773
Dear Mr. Pectol:
The State of Utah (State) appreciates the opportunity to submit comments concerning
the US Army Corps of Engineers Public Notice of US Magnesium’s proposal to discharge
dredged material into approximately 126.8 acres of lakebed associated with the removal of
accumulated sediments from the existing P-0 and P-North Canals, and the extension of these
canals to the lakebed contour of 4,185 feet via hydrologic suction dredge. The State has
evaluated the proposal and encourages innovations in processing that would reduce overall
depletions. In collaboration with the Utah Division of Forestry, Fire and State Lands (FFSL),
the Utah Division of Water Resources (DWRe), the Utah Division of Wildlife Resources
(DWR), and the Department of Environmental Quality (DEQ), the State submits the
following comments for your consideration.
Division of Forestry, Fire and State Lands
FFSL holds jurisdiction over the sovereign lands of Great Salt Lake. FFSL has not
taken any action to prevent the extension of the canal and has determined the improvements
are within the existing footprint of Mineral Lease number 200-00140 and allowable per the
terms of the lease. While this is within the existing footprint of the lease, low lake levels and
DNR, Public Lands Policy Coordinating Office, 1594 W North Temple, PO Box 145610, Salt Lake City, Utah 84114 · 385-228-8443
US Magnesium Canal Continuation
SPK-2008-01773
September 9, 2022
Page 2
persistent drought are highly concerning and have serious environmental, economic, and
ecological consequences. While it is not required, FFSL encourages all mineral industries on
Great Salt Lake to make a consistent and concerted effort to employ innovative measures to
quantitatively reduce the amount of water depleted during their processing.
Division of Water Resources
DWRe has concerns about the declining elevation of Great Salt Lake. Utah is
experiencing persistent and intense drought and the lake elevation isn’t expected to return to
an average level in the near future.
At the first indication of drought, Utah experiences agriculture crops struggling and
reduction in water for livestock. At the extreme/exceptional levels of drought, we experience
elevated fire risks and restrictions and cuts in water allotments to water users. Drought
conditions at varying levels have existed in Utah for the past two decades. The outlook for
precipitation in Utah continues to be drier than normal in northern Utah, Wyoming, and
Idaho, the states where sources of water flowing to Great Salt Lake originate. The graph
below (retrieved from the U.S. Drought Monitor website on 8/29/2022) visually represents
water conditions in Utah since 2000. The graphs of drought conditions from 2000 through
2022 set a good foundation for understanding what conditions have led to the current Great
Salt Lake level.
SPK-2008-01773
September 9, 2022
Page 3
The Army Corps of Engineers should carefully consider the historically low lake
levels (4,189 feet above mean sea level) and how the application to modify the existing canal
will impact the lake and surrounding communities.
DWRe is actively working with members of the Utah Legislature, state agencies, non-
governmental organizations, water conservancy districts, agricultural water users, and local
water providers to better understand and protect Great Salt Lake. With appropriations from
the Utah Legislature and federal funds we are working on an integrated Great Salt Lake
assessment and comprehensive study which will provide a better understanding of the
complexities of the Great Salt Lake ecosystem.
Division of Wildlife Resources
DWR provides wildlife information regarding the 3.0-mile and 0.7-mile canal
extensions. Extension of the canals and subsequent spraying of dredged slurry along each
side of the canals has the potential to impact the microbialite community. Microbialites
support the base of the food chain in Great Salt Lake (GSL). Microbialites are sedimentary
deposits made of carbonate mud formed by microbes immersed in the GSL, and provide
foundational ecosystem services where they are found, in shallow water along the shoreline.
These structures, a primary food producer, create biomass for the brine fly and brine shrimp
populations, which are crucial food sources for a diverse array of migratory waterfowl
species. Recently published scientific literature, along with direct observations, indicate that
microbialites are present along the shoreline near both canals. 1 The extension of both canals
into microbialite structures may lead to microbialite loss and the ecosystem services they
provide. Also, aerial broadcasting of the dredged material may cover the microbialite fields
near the canal, potentially contributing to further loss of microbialite structures, or inhibiting
the colonization of new microbialite communities.
The spraying of dredged materials along the sides of each canal has the potential to
impact snowy plover populations. The GSL hosts over 5,500 nesting snowy plovers, the
world’s 2 largest breeding population, and 21 percent of the continental population. The two
125-foot-wide areas where the dredged slurry is to be spread on either side of both canals
have the potential to change or disturb nearby snowy plover nesting habitat.
1
Baskin et.al 2021. “Characteristics and controls on the distribution of sublittoral microbial biotherms in Great
Salt Lake Utah: Implication for understanding microbialite development.” The Depositional Record: The
Journal of the International Association of Sedimentologists. 9 July 2021.
2
https://rockies.audubon.org/gillmor/articles/snowy-plover-beauty-existence
SPK-2008-01773
September 9, 2022
Page 4
The GSL is at record-low lake levels, and there is a significant continuing concern
with the water in the lake and its management. The GSL’s unique ecosystem provides
migratory waterfowl habitat, as well as brine shrimp - a migratory waterfowl food source.
Importantly, the GSL is a crucial part of the Pacific Flyway between North and South
America for over 10 million birds annually. This loss of water and microbialite habitat could
have impacts on wildlife that depend on the lake and on the GSL overall.
If you have questions, contact the DWR’s Impact Analysis Biologist in our Ogden
office, Melissa Early, at [email protected] or 801-386-4885.
Department of Environmental Quality
The Department of Environmental Quality (DEQ) has regulatory authority over air
pollution sources that include fugitive dust from earthmoving activities. The Great Salt Lake
is located within federally designated non-attainment areas for fine particulate matter PM2.5.
Any earth moving activity that impacts greater than ¼ acre requires the development and
submission of a Fugitive Dust Control Plan to the Utah Division of Air Quality. Utah
Administrative Code R307-309 contains the requirements to limit the visible dust generated
and to stabilize the disturbed areas and access roads to restore any protective crust in order to
prevent future wind erosion and the generation of dust. In addition to the lakebed areas
directly impacted by the earthmoving activities, DEQ is concerned that additional water
removal will exacerbate the shrinking of the water surface area of the Great Salt Lake leading
to the exposure of more lake sediment to wind erosion with the potential to violate federal air
quality standards and impact the public health of the residents of Box Elder, Weber, Davis,
Tooele and Salt Lake Counties.
Conclusion
As the water levels in the Great Salt Lake continue to decline, a diverse array of
stakeholders, including state agencies, municipalities, water conservancy district, northern
Utah’s agriculture industry, private industry, nonprofit organizations, and others are
collaborating on numerous efforts to increase water levels in the lake and protect its critical
ecosystem. The State encourages the U.S .Army Corps of Engineers to collaborate with
these stakeholders as we work to find practical solutions for the future of the lake while also
supporting the economic viability of private industries that provide critical minerals for our
nation.
SPK-2008-01773
September 9, 2022
Page 5
Please direct any written correspondence to the Public Lands Policy Coordinating
Office at the address below or call to discuss any questions or concerns.
Sincerely,
Redge B. Johnson
Executive Director

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Office of the Governor

Public Lands Policy Coordinating Office

Submitted via electronically: [email protected]

Subject: US Magnesium Canal Continuation

Dear Mr. Pectol:

Division of Forestry, Fire and State Lands

Division of Water Resources

Division of Wildlife Resources

Department of Environmental Quality

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