Great Salt Lake Dedicated Water Reconciliation

Distinguishing between legal dedication and durable lake water accretion

Purpose

This page reconciles the Utah Division of Water Rights’ Great Salt Lake Distribution Accounting Tool (DAT) with GSL Accounting’s estimates of recurring physical lake benefit. It explains why the legal quantities dedicated through individual water-right actions, the DAT’s cumulative modeled balance, and representative annual bankable lake accretion are related but not interchangeable. It also documents the assumptions used to translate each active DAT application into representative wet- and dry-regime estimates.

That reconciliation begins by distinguishing the two complementary forms of dedicated-water accounting now used for Great Salt Lake:

• The Utah Division of Water Rights’ Great Salt Lake Distribution Accounting Tool (DAT) administers water that has been legally dedicated to Great Salt Lake. 
• GSL Accounting estimates of how much additional water those actions can reasonably be expected to add to—or retain in—the lake during a representative year.

The distinction matters because the two systems use the same unit, acre-feet, to measure different accounting objects:

The DAT asks:

How much cumulative dedicated-water accretion should remain credited within Great Salt Lake after annual additions, modeled evaporation, and movement between the North and South Arms?

GSL Accounting asks:

How much incremental water reaches or remains in Great Salt Lake in a given year because a diversion or depletion changed?

The first is a cumulative administrative and operational account. The second is an annual hydrologic estimate.

Neither approach replaces the other. The DAT administers dedicated water within Utah’s water-right system, while GSL Accounting translates those legal and operational actions into annual quantities relevant to lake elevation and the basin water balance. Reconciling their outputs therefore begins with understanding what the DAT’s cumulative balance represents—and what it does not.

What the DAT Balance Represents

The DAT does not simply add the face value of every approved water right. Its downloaded calculation files show a daily ledger that separately tracks dedicated water in the North and South Arms. The model begins with the prior balance, adds credited water, transfers the accounting attribution between the arms as water moves through the causeway, and deducts evaporation attributed to the calculated additional lake surface area after adding the credited water. The credited water itself is tied to measured streamflow at the point of accretion, not simply asserted from an order's authorized quantity: for example, if 100 cubic feet per second is measured arriving at the D Line dike at the Bear River Migratory Bird Refuge, and 10 cfs of that total is attributable to an upstream donation, the accounting records 90 cfs as base flow and 10 cfs as the dedicated credit—both components reconciled against the same gaged total.

The basic identity is:

Beginning Dedicated-Water Balance
+ New Dedicated-Water Credits
± North / South Arm Reallocation
− Marginal Evaporation
=
Ending Dedicated-Water Balance

The resulting balance is neither a reservoir account nor a pool of water that can later be called, released, sold, or redirected. Great Salt Lake water is physically mixed, and there are no separately identifiable dedicated-water molecules. The legal status still has real effect, however: once water is credited to the DAT, it is treated as committed to the lake and is not available for appropriation to other uses, even though it cannot be physically isolated within the lake's total volume.

The balance is better understood as:

The State’s modeled cumulative attribution of lake storage to water that has been legally credited for Great Salt Lake, after applying the DAT’s rules.

The underlying actions can be physical: an irrigation depletion may be eliminated or reduced, an industrial withdrawal may be curtailed, or imported water may be delivered. The DAT then carries the modeled retained effect of those actions forward through time. It is a registry of dedicated water rights as on record, adjusted for estimated evaporation, but it is not a callable physical asset.

With the accounting object established, the next step is to trace how annual credits, carried-forward balances, and modeled evaporation produced the cumulative balance displayed by the DAT on January 1, 2026.

How the DAT Reached 476,115 Acre-Feet

The DAT began with no dedicated-water balance as of January 1, 2021. Its calculated-value files show annual credits added to the account after that date and the prior balance being carried forward after deducting modeled evaporation.

The five-year reconciliation is:

Cumulative DAT credits, 2021–2025              520,538 af
Less cumulative modeled evaporation             44,412 af
                                               ----------
Dedicated-water balance, December 31, 2025     476,126 af

Less January 1, 2026 modeled evaporation            11 af
                                               ----------
DAT balance displayed January 1, 2026          476,115 af

This explains why the 476,115-acre-foot balance does not reconcile to a simple sum of the current change applications. The DAT is carrying forward five years of annual credits, less the evaporation attributed to the cumulative balance. It is not displaying the annual capacity of the current order portfolio.

476,115 af is NOT:

• 476,115 af of new water delivered during 2025
• 476,115 af of annual depletion reduction
• 476,115 af that can be released or called
• the sum of the current face values of the change applications
• a forecast that the same quantity will be added each future year

It is the DAT’s modeled cumulative remaining balance as of a specific date. That distinction is essential when comparing the dashboard balance with public summaries prepared at different reporting dates and for different purposes.

How the Strike Team Reports Dedicated Water

The January 2026 Great Salt Lake Strike Team report states that Utah’s recent actions resulted in “nearly 400,000 acre-feet of water being dedicated and delivered to Great Salt Lake between 2021 and 2025.” It also reports that the portfolio of voluntary donations and leases increased nearly nine-fold after 2021.

The Strike Team report does not print the January 1, 2026 DAT balance of 476,115 acre-feet. The difference is largely a matter of timing: the DAT charges modeled evaporation daily, but the streamflow accretions that generate new credits depend on river commissioner reports that are only finalized after each water year closes, so the running balance is continually trued up as those reports arrive. The Strike Team's "nearly 400,000 acre-feet" statement reflects a best point-in-time estimate provided ahead of that final reconciliation, not the fully trued-up year-end balance the DAT dashboard now shows—including large credits entered during 2025 that were finalized only after the report's cutoff.

The two figures should therefore be described carefully:

2026 Strike Team report             Nearly 400,000 af dedicated and delivered
                                    between 2021 and 2025

DAT dashboard                       476,115 af cumulative dedicated-water
                                    balance as of January 1, 2026

They are related measures of the same emerging dedicated-water program, but they are not interchangeable. The Strike Team uses dedicated and delivered water as a measure of implementation progress. The DAT maintains the more detailed cumulative accounting balance.

The Strike Team also recognizes the larger scale required for recovery. Its updated projections conclude that sustained additional inflows on the order of hundreds of thousands of acre-feet per year are required to move Great Salt Lake into healthier elevation ranges under contemporary climate conditions.

That distinction is central to this reconciliation:

A cumulative dedicated-water balance is evidence of real institutional and conservation progress. But it is a stock, not a flow—and restoring lake elevation depends on recurring annual inflow, not an accumulated total.

The GSL Accounting Bankability Approach

Translating that cumulative stock into a recurring physical benefit requires a different starting point. GSL Accounting begins one step earlier than the DAT by asking whether—and by how much—the underlying action changes the physical water balance before carrying any quantity into a lake account.

For an irrigation conversion, the relevant quantity is generally historical consumptive use—not the full diversion. For a direct industrial withdrawal, it is the credible withdrawal actually avoided—not unused legal capacity. For imported water, it is measured delivery after conveyance losses. For a temporary change application, the benefit exists only while the authorization and associated operations remain in effect.

The governing identity is:

Bankable Annual Benefit
=
Credible Counterfactual Depletion
− Depletion Remaining After the Action

Depending on the project, additional adjustments may be required for:

• return flows;
• intervening diversions;
• conveyance and wetland routing;
• priority administration;
• actual industrial demand;
• elevation-dependent operating limits;
• temporary versus permanent authorization.

“Bankable” does not mean that water survives forever or becomes a callable lake asset. It means:

The recurring annual increase in lake inflow or retained storage that can reasonably be attributed to the action under representative operating and hydrologic conditions.

Wet- and dry-regime estimates are used because the same legal order may perform differently as water availability, priority administration, industrial operations, lake elevation, and conveyance conditions change. These representative annual estimates can then be compared with the portfolio’s legal face value and the DAT’s cumulative balance without treating the three quantities as interchangeable.

Reconciling the Headline Numbers

Version 1.1 change in reported bankable quantities. Version 1.0 reported estimated total annual bankable accretion of 198.450 kaf under the dry regime and 185.520 kaf under the wet regime. Version 1.1 reports lower quantified subtotals of 158.515 kaf/year dry and 119.707 kaf/year wet.

This change does not represent a reduction in the legal dedicated-water portfolio or a determination that previously identified projects provide no benefit. Version 1.1 applies a stricter evidentiary distinction between:

• representative quantities supported by an order’s depletion determination, elevation schedule, or other documented operating basis; and
• benefits that may be real and measurable but cannot yet be assigned a predetermined annual dry- or wet-regime quantity from the order alone.

Accordingly, assumed annual values were removed for a50507, f53574, f53788, and the Ontario Drain Tunnel. The FFSL Sovereign Lands order, a53322, was reclassified from zero to not quantified because its incremental benefit depends on the industrial withdrawal that would otherwise have occurred. Morton Salt and Earth’s Elements were revised to follow their exact elevation schedules, and the Huntsville Abbey Farm wet-regime value was aligned with its State Engineer depletion ceiling.

The affected projects remain part of the legal portfolio. Their annual bankable benefit will be recognized from measured delivery, reported participation, documented depletion, or a supported counterfactual baseline when those records become available.

The current DAT order inventory contains 549.456 kaf of fixed legal dedication, excluding the withdrawn f46437 application, the Ontario Drain Tunnel (f53110), whose credit is based on measured flow rather than a fixed quantity, and the Bear River Bay / Willard Spur project (a48872), whose authorization is expressed as a flow right (cfs) rather than an annual acre-foot quantity. This total reflects the legal face value of the active DAT orders. It includes orders whose physical lake accretion may be substantially smaller—or, in the case of aquifer recharge, effectively zero—illustrating the distinction between legal dedication and bankable annual lake accretion.

These numbers are not supposed to match.

549.456 kaf = active fixed-order maximum

158.515 kaf/year dry and 119.707 kaf/year wet
            = subtotal of cases with quantified representative estimates

193.718 kaf = fixed-order maximum associated with cases whose recurring
              bankable benefit is not yet quantified

476.115 kaf = cumulative DAT balance after five years of credits and
              modeled marginal evaporation

The legal portfolio is larger than the quantified annual-benefit subtotal because some orders protect unused diversion capacity, some are elevation dependent, some represent diversion rather than depletion, and some are temporary, operationally constrained, or not yet supported by the records needed to assign a representative annual quantity.

The cumulative DAT balance is larger than one year of bankable lake accretion because it includes credits accumulated over several years. Keeping these accounting objects separate is not merely a matter of terminology; it determines how the program’s progress should be interpreted in relation to the lake’s physical water balance.

Why the Distinction Matters

The DAT operates in acre-feet because water rights must be measured, administered, and distributed one order at a time. Great Salt Lake responds at a different scale. Whole-lake evaporation averages millions of acre-feet per year, human depletions total more than two million acre-feet per year, and meaningful elevation recovery requires sustained changes measured in hundreds of thousands of acre-feet per year. The Strike Team reports average lake evaporation of approximately 2,733 kaf/year for 1989–2024—greater than average annual human depletion over that period.

This does not make small projects unimportant. Many provide highly valuable wetland flows, protect water from future diversion, improve drought resilience, and establish the legal and administrative infrastructure required for long-term recovery. Elevation-dependent mineral agreements may also provide meaningful resilience as the lake decline approaches or falls below 4,190 feet.

But the scale comparison prevents a category error:

Dedicated-water accounting measures the implementation of individual legal actions. Bankability accounting measures the total of how much those actions change the lake’s annual physical water balance.

Both forms of accounting are necessary, but neither answers the other’s question by itself. The practical reconciliation therefore requires applying this distinction consistently to each legal dedication in the active portfolio.

Reconciling the Dedicated-Water Portfolio

The Great Salt Lake Distribution Accounting Tool (DAT) tracks each approved dedication as an individual legal accounting record. GSL Accounting asks a different question: how much recurring physical benefit is likely to reach Great Salt Lake after operational constraints, hydrology, and project-specific assumptions are considered?

The table below reconciles every active DAT application using the same framework applied throughout this page. It preserves the State Engineer’s legal accounting and, where the available record supports a representative quantity, translates each order into annual “bankable” lake accretion under recent dry and typical wet conditions. Where the record does not support such a quantity, the bankable benefit is reported as not quantified.

Accounting principle: Financial analysis often distinguishes between contractual entitlement and expected realization. Likewise, GSL Accounting estimates the recurring environmental accretion expected to be realized under representative operating conditions rather than the maximum dedication authorized by each order.

Methodology. The State Engineer’s orders establish the maximum legal environmental dedication authorized under each application. Where supported by the available record, GSL Accounting estimates representative annual physical lake accretion under recent dry and typical wet operating conditions by considering the legal and operational assumptions contained in each order, expected hydrologic availability, diversion constraints, project durability, and whether the order creates new water, reduces consumptive use, or reallocates an existing water right. Where the record does not support a defensible representative quantity, the benefit is reported as not quantified rather than assigned an assumed value.

Estimation limitation. The wet- and dry-regime figures in this table are representative accounting estimates, not measured deliveries or State Engineer determinations. They are derived from the legal operating limits in each order and adjusted for identifiable realization constraints, including historical consumptive use, hydrologic availability, priority administration, actual industrial demand, elevation triggers, and project duration. Where operating data are unavailable, a representative estimate is presented only when the order or another documented basis supports a reasonable scenario; otherwise, the annual bankable benefit is reported as not quantified.

Concentration. Because the Compass Minerals (a52152, a52277) and Morton Salt (a53468) agreements together account for more than half of the dry-regime quantified subtotal and more than one-third of the wet-regime quantified subtotal, uncertainty in their actual operating realization has a disproportionate effect on the portfolio-level estimate.

CU-ceiling convention. For orders where the accounting identity is expressed relative to a State Engineer historical consumptive-use determination, the wet-regime estimate is generally treated as approaching but not exceeding that determination.

Implications. Because different agreements peak in different hydrologic regimes, the portfolio dampens both upside and downside rather than behaving as a single fixed quantity. But the concentration of benefit in a few large agreements matters for more than volume. Compass Minerals and Morton Salt hold rights to withdraw directly from Great Salt Lake itself, so their benefit is realized at the lake margin without passing through the Zone 1 or Zone 2 accounting boundaries at all; it registers almost entirely as elevation and salinity effects, with only secondary influence on playa dust, and its wet/dry range reflects uncertainty in industrial operating behavior rather than routing loss. The smaller, upstream initiatives instead reduce depletion above the Zone 1 terminal gages, and the water they conserve must still pass through Zone 2 wetland routing—Bear River Bay, Farmington Bay, Willard Spur—before it reaches the open lake; their wet/dry range reflects that routing and delivery uncertainty, and the water itself carries the broader habitat and connectivity benefits associated with passing through the wetland system along the way. The portfolio total therefore combines two different kinds of value reached through two different physical pathways. A single acre-foot total—however well it foots—cannot capture that difference in kind, so the portfolio-level reconciliation must be supported by examining the legal terms, physical mechanism, and realization constraints of each order.

Order-by-Order Reconciliation

The analyses that follow use the State Engineer’s orders as the starting point. Each analysis preserves the State’s legal dedication, identifies the physical mechanism by which the action may benefit Great Salt Lake, and then estimates the portion that is reasonably bankable under representative wet and dry conditions.

The purpose is not to recalculate the DAT or substitute a new administrative judgment for the State Engineer’s. It is to answer the next accounting question:

Once water has been legally dedicated, what recurring annual change in Great Salt Lake’s physical water balance can reasonably be attributed to that action?

That distinction allows both systems to be read correctly. The DAT documents a rapidly expanding legal and administrative portfolio. GSL Accounting evaluates how much of that portfolio is likely to translate into durable annual lake accretion. The existing order analyses provide the project-level bridge between the two.

f46437 Kennecott Jordan River Exchange (Withdrawn)

Fixed-time industrial-to-environmental dedication

This fixed-time change application proposed converting a portion of Kennecott Utah Copper’s Jordan River water right from industrial use to environmental use for the benefit of Great Salt Lake. Water historically used for mining and industrial processing would instead be redirected through the Lower Jordan River system for propagation and maintenance of wildlife, fisheries, recreation, and enhancement of the natural aquatic environment on Great Salt Lake sovereign lands.

Unlike traditional conservation projects, this application did not create new water. Instead, it redirected an existing fully consumptive industrial water right toward environmental purposes. Because the historical industrial use was assumed to be fully consumptive, nearly the entire authorized diversion had the potential to become environmental water if physically delivered.

This application was later withdrawn and replaced by Fixed-Time Change Application f53574, which refined the diversion locations and operating conditions while preserving the underlying environmental dedication concept.

Sources

Utah Division of Water Rights — Fixed-Time Change Application f46437 (withdrawn)

Utah Division of Water Rights — Fixed-Time Change Application f53574 (replacement)

Application quantities and status

Component                           Volume (af)
-----------------------------------------------
Authorized Diversion                18,387
Historical Depletion               ~18,387*
Return Flow                        Minimal

*Industrial use assumed fully consumptive

Interpretation

• Industrial water right converted to environmental use
• Historical industrial depletion assumed essentially fully consumptive
• Environmental accretion depends primarily on successful downstream delivery rather than irrigation efficiency

Variability drivers:

• Lower Jordan River hydrology
• River commissioner operations
• Exchange availability and priority administration

Ledger translation

Because the system:

• converts historical industrial depletion
• relies upon an exchange and commissioner administration
• delivers water through the Lower Jordan River

The accounting identity is:

Dedicated Water ≠ Guaranteed Lake Accretion

Benefit = Delivered Industrial Depletion

What is bankable

No recurring lake benefit is credited to f46437 because the application was withdrawn and superseded by f53574. The proposed physical benefit—historical industrial depletion successfully delivered through the Lower Jordan River system—must be evaluated under the replacement order instead.

What is NOT fully bankable

• No delivery may be attributed independently to the withdrawn application.
• The proposed exchange remained subject to prior rights, river administration, and hydrologic availability.
• Any current environmental delivery, measurement, or reporting occurs under f53574 rather than f46437.

Bankability assessment

Factor          Rating
---------------------------------------------
Proximity       Medium
Timing          Medium
Control         Medium
Measurement     Not applicable
Durability      Withdrawn

• Proximity — Medium: The proposed water would have traveled through the Lower Jordan River system before reaching Great Salt Lake.
• Timing — Medium: Delivery depended on exchange availability, hydrologic conditions, prior rights, and commissioner administration.
• Control — Medium: The proposed exchange provided an administrable delivery mechanism, but operation was not controlled solely by the applicants.
• Measurement — Not applicable: f46437 is no longer an active authorization. Current measurement and reporting requirements belong to replacement order f53574.
• Durability — Withdrawn: f46437 was expressly withdrawn and superseded by f53574; it produces no separately bankable continuing benefit.

Durability under wet and dry regimes

Wet / high-flow years

• f46437 remains withdrawn regardless of water availability.
• No environmental delivery can be credited under this application.
• Any current delivery, measurement, or reporting occurs under f53574.

Implication:

Bankable benefit under f46437 is 0.000 kaf/year.

Dry / low-flow years

• f46437 remains withdrawn regardless of water availability.
• No minimum or realized delivery exists under this application.
• Any current benefit must be evaluated under f53574.

Implication:

Bankable benefit under f46437 is 0.000 kaf/year.

Critical distinction

The application converted:

• historical industrial consumptive use

It did not create:

• new basin yield
• new water supply

Its environmental accretion depended entirely upon successful annual delivery through the Lower Jordan River exchange system.

Bottom line

Fixed-Time Change Application f46437 demonstrated that fully consumptive industrial water rights could be converted to environmental use for Great Salt Lake. The application was subsequently withdrawn and replaced by Fixed-Time Change Application f53574, which now provides the operative authorization for the underlying water. Accordingly, f46437 should not be counted as a separate source of recurring annual bankable water.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f46437 (Withdrawn)     |     18.387    |     0.000      |     0.000

Because this application has been withdrawn and superseded, it contributes no current recurring annual bankable water under this framework. Evaluation of the continuing benefit transfers to the replacement application (f53574), avoiding double counting.

• Historical application illustrating the evolution of environmental dedication
• Replaced by permanent authorization (f53574)
• Not included in long-term durable accounting

Important historically, but superseded for purposes of permanent Great Salt Lake water accounting.

a47913 Hooper Slough

Near-lake agricultural conversion

The Hooper Slough project permanently converts a small agricultural water right from irrigation and stockwatering to year-round wildlife propagation within Hooper Slough, east of Fremont Island. The change eliminates historical agricultural consumptive use and dedicates the water to Great Salt Lake habitat management immediately adjacent to the lake.

Because the diversion occurs within the terminal wetlands surrounding Great Salt Lake, this project represents one of the shortest and most direct conveyance pathways in Utah’s dedicated water portfolio. Nearly all uncertainty relates to annual wetland operations rather than upstream river routing.

Sources

Utah Division of Water Rights — Permanent Change Application 35-476 (a47913)

Order-authorized quantities and calculated depletion

Component                         Volume (af)
--------------------------------------------
Historical Diversion               248
Historical Irrigated Acres          61.6
Historical Stockwatering            60 ELUs

Interpretation

• Small agricultural irrigation right
• Irrigation and stockwatering permanently retired
• Water dedicated immediately adjacent to Great Salt Lake wetlands

Variability drivers:

• wetland operations
• local water management
• annual hydrologic conditions

Ledger translation

Because the system:

• is immediately adjacent to Great Salt Lake
• permanently removes agricultural depletion
• has a very short delivery pathway

The accounting identity is:

Diversion ≠ Benefit to Lake

Benefit = Reduction in Agricultural Depletion

What is bankable

The bankable component is:

Permanent elimination of historical agricultural depletion immediately adjacent to Great Salt Lake.

For representative accounting :

• Realistic durable range: approximately 0.15–0.23 kaf/year
• Nearly the entire benefit results from reduced consumptive use rather than new water creation.

What is NOT fully bankable

• Wetland management may temporarily retain a portion of flows.
• Seasonal operations influence exactly when water reaches open lake.
• The project does not increase basin yield or create new water.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    High
Durability                     High

• Proximity — Very high: The authorized place of use is within Great Salt Lake’s terminal wetland system east of Fremont Island, leaving essentially no upstream river-routing exposure.
• Timing — High: The order authorizes year-round wildlife propagation, although the timing of delivery to the open lake remains affected by wetland operations and local hydrologic conditions.
• Control — High: The applicant must construct or install and maintain controlling works, while operation remains subject to prior rights and local water management.
• Measurement — High: The order expressly requires a measuring device, and proof of beneficial use must identify each water source and the amount used from that source.
• Durability — High: The permanent change requires the former irrigation and stockwatering diversions to cease. Its continuing benefit remains subject to development, proof, and ongoing compliance with the order.

Durability under wet and dry regimes

Wet / high flow years

• Wetlands operate with abundant inflow.
• Nearly complete realization of historical depletion savings.
• Excellent connectivity to Great Salt Lake habitat.

Implication:

Strong and consistent environmental accretion.

Dry / low flow years

• Wetland operations become more constrained.
• Some water may be retained within managed habitat.
• Reduced agricultural depletion still occurs regardless of annual conditions.

Implication:

Bankability remains high, although realized lake accretion is modestly reduced.

Critical distinction

The project removes:

• historical agricultural depletion immediately adjacent to Great Salt Lake

It does NOT create:

• additional basin yield
• new upstream water
• increased watershed runoff

Bottom line

Hooper Slough represents a small but highly durable category of dedicated water. Although the annual volume is modest, the project permanently removes historical agricultural depletion immediately adjacent to Great Salt Lake, minimizing uncertainty associated with upstream routing and river administration. Because the conserved water enters the terminal wetland system almost immediately, it provides one of the more reliable examples of long-term bankable environmental water in the State’s portfolio.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a47913                 |      0.250    |     0.150      |     0.230

Hooper Slough is a high-bankability, near-lake agricultural conversion.

• Permanent reduction in agricultural depletion
• Extremely short delivery pathway
• Minimal dependence on upstream hydrology

Although modest in volume, Hooper Slough demonstrates how small, strategically located agricultural conversions can produce durable, high-confidence environmental water for Great Salt Lake.

a48872 Bear River Bay / Willard Spur

Near-lake wetland routing

The Bear River Bay / Willard Spur project permanently modifies an existing Great Salt Lake water right to improve delivery of water through the Bear River Migratory Bird Refuge and into the Willard Spur Wildlife Management Area. Rather than creating new water or reducing historical consumptive use, the project changes diversion points and places of use to improve management of approximately 13,940 acres of terminal wetlands. The order removes the previously proposed reservoir storage and redirects water through the existing wetland system.

Unlike a traditional conservation project, this action primarily improves how dedicated Great Salt Lake water is routed and managed within the terminal wetland complex. Because the water already exists within the Great Salt Lake system, its value comes from preserving and directing environmental flows rather than generating additional basin yield.

Sources

Utah Division of Water Rights — Permanent Change Application 13-3404 (a48872)

Order-authorized parameters

Component
----------------------------------------------------
Underlying Area 13 GSL right              8,000 cfs
Reservoir storage eliminated             80,000 af
Terminal wetland place of use           ~13,940 acres
Annual acre-foot quantity             Not specified

Interpretation

• Existing Great Salt Lake Area 13 water right
• Reservoir concept eliminated
• Water redirected through existing refuge and wetland system
• Improves management rather than creating new water

Variability drivers:

• Bear River inflows
• Wetland operations
• Refuge management
• Annual hydrologic conditions

Ledger translation

Because the system:

• remains entirely within the Great Salt Lake basin
• redirects existing environmental water
• does not reduce upstream consumptive use

The accounting identity is:

Routing Change ≠ New Lake Accretion

Accounting Effect
=
Improved Management of Existing Environmental Water

What is bankable

The order provides a durable legal and operational framework for routing existing Great Salt Lake environmental water through the Bear River Migratory Bird Refuge and Willard Spur.

No annual bankable accretion quantity is assigned. The underlying right is expressed as an 8,000 cfs flow rate, and the order does not establish a fixed annual acre-foot volume from which representative wet- and dry-regime accretion can be calculated.

What is NOT fully bankable

• No new basin yield is created.
• No upstream consumptive use is eliminated.
• Annual routing and wetland use depend on Bear River hydrology and refuge operations.
• The project reallocates and manages existing environmental water rather than producing an independently measurable increment of new lake water.
• The order does not provide a fixed annual acre-foot quantity suitable for wet- and dry-regime bankability estimates.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         Medium
Control                        Medium
Measurement                    Medium
Durability                     High

• Proximity — Very high: The authorized water passes from the Bear River Migratory Bird Refuge directly into the Willard Spur Wildlife Management Area within Great Salt Lake’s terminal wetland system.
• Timing — Medium: Available flow depends on Bear River hydrology, refuge discharges, return flows, and high-water conditions. The right cannot call for water from or through the refuge or from upstream Areas 29, 31, or 35.
• Control — Medium: The order requires controlling works, but the applicants do not control the upstream supply or refuge releases on which physical routing depends.
• Measurement — Medium: Measuring devices are required, but the 8,000 cfs authorization is a maximum flow rate rather than a fixed annual volume, and the order does not isolate an incremental quantity of newly created lake water.
• Durability — High: The permanent change establishes a lasting terminal-wetland routing function and requires ownership to be transferred to the Utah Division of Wildlife Resources before proof. Continued durability depends on development, proof, and compliance with the order.

Durability under wet and dry regimes

Wet / high flow years

• Full Bear River connectivity.
• Wetlands receive complete environmental deliveries.
• A larger share of available environmental flow can be routed through the refuge and Willard Spur.

Implication:

The routing and habitat-management function is strongest, but no annual acre-foot accretion estimate is assigned.

Dry / low flow years

• Lower Bear River inflows reduce available deliveries.
• Refuge operations prioritize limited supplies.
• Less water is available for routing through the terminal wetland system.

Implication:

The routing function remains legally durable, but its physical realization is constrained by available flow and cannot be quantified from the order alone.

Critical distinction

The system improves:

• routing of existing Great Salt Lake environmental water
• wetland delivery
• habitat management

It does NOT create:

• new basin yield
• additional watershed runoff
• measurable reductions in upstream depletion

Bottom line

Bear River Bay / Willard Spur is a high-confidence environmental routing project rather than a traditional depletion-reduction initiative. The permanent change order reroutes an existing Area 13 Great Salt Lake water right through the Bear River Migratory Bird Refuge and into the Willard Spur Wildlife Management Area while eliminating the previously proposed 80,000 acre-foot reservoir. The project does not create new basin yield or eliminate an upstream depletion. Its importance lies in improving the legal and operational management of existing environmental water within the terminal wetland system. Because the underlying right is expressed as an 8,000 cfs flow rate and the order provides no fixed annual acre-foot quantity, GSL Accounting does not assign dedicated or bankable wet- and dry-regime volumes to this order.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a48872                 |       -       |       -        |       -

Bear River Bay / Willard Spur is a high-confidence, near-lake environmental routing project that is not quantified for annual bankability.

• Permanent change to an existing Great Salt Lake environmental right.
• Excellent proximity to Great Salt Lake and important wetland-routing function.
• Improves management of existing water rather than creating new basin yield.
• No fixed annual acre-foot quantity is established by the order.

High confidence in the permanence and environmental-routing function of the order, but no annual bankable accretion estimate is assigned because the underlying right is expressed as a flow rate rather than a fixed annual volume.

a49954 Utah Lake / Jordan River

Upstream agricultural exchange

The Utah Lake / Jordan River project permanently converts a portion of East Jordan Irrigation Company’s agricultural water right from irrigation to environmental use for the benefit of Great Salt Lake. Water formerly diverted from Utah Lake for irrigation is instead released through the Jordan River system, Surplus Canal, and Farmington Bay to support hydrophytic vegetation, wildlife habitat, and Great Salt Lake wetlands.

Unlike near-lake projects such as North Point, this dedication begins upstream at Utah Lake and must travel through the entire Jordan River system before reaching Great Salt Lake. The State Engineer specifically recognizes that only the historical consumptive use represents new environmental water. Water released in excess of historical depletion remains available for diversion under existing downstream water rights and therefore does not automatically become additional inflow to Great Salt Lake.

Sources

Utah Division of Water Rights — Permanent Change Application 57-10981 (a49954)

Order-authorized quantities and calculated depletion (acre-feet)

Component                           Volume (af)
-----------------------------------------------
Dedicated Water Right                3,500
Historical Consumptive Use           1,485
Historical Irrigated Acres             700
Potential Return Flows              ~2,015

Interpretation

• Agricultural irrigation permanently retired
• Water released from Utah Lake through the Jordan River system
• Historical depletion—not total diversion—defines new environmental accretion

Variability drivers:

• Utah Lake releases
• Jordan River operations
• downstream diversions
• Farmington Bay routing

Ledger translation

Because the system:

• originates upstream at Utah Lake
• passes through multiple diversion systems
• has documented historical consumptive use

The accounting identity is:

Dedicated Water ≠ Benefit to Lake

Benefit = Historical Depletion − Downstream Re-diversion

What is bankable

The bankable component is:

Historical agricultural depletion successfully delivered through the Jordan River to Great Salt Lake.

Using the order’s historical-depletion determination:

• Historical depletion: 1.49 kaf/year
• Realistic durable range: ~1.0–1.5 kaf/year
• The remaining dedicated water already existed within the downstream river system and may continue to satisfy existing rights.

What is NOT fully bankable

• Approximately 2.0 kaf represents historical return flows rather than new depletion reduction.
• Water released above historical depletion may be diverted downstream under existing rights.
• Annual benefit depends upon Utah Lake operations, Jordan River routing, and downstream administration.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Medium
Timing                         Medium
Control                        Medium
Measurement                    Medium
Durability                     High

• Proximity — Medium: The dedication begins at Utah Lake and must pass through the Jordan River, Surplus Canal, and Farmington Bay before reaching Great Salt Lake.
• Timing — Medium: Releases are administered by the Utah Lake, Jordan River, and Lower Jordan River commissioners and remain exposed to seasonal hydrology and downstream diversion.
• Control — Medium: The order permanently ends irrigation of the associated 700 acres and places releases under commissioner direction, but the applicants do not control downstream river conditions or intervening water-right administration.
• Measurement — Medium: The order fixes the annual diversion at 3,500 acre-feet and calculates historical depletion at 1,485.17 acre-feet. However, the portion ultimately reaching Great Salt Lake is not measured independently after downstream diversions and routing.
• Durability — High: The permanent change requires the historical irrigation diversion to cease and the associated East Jordan Irrigation Company shares to remain dedicated and in good standing. Durability remains contingent on development, proof, and continued compliance.

Durability under wet and dry regimes

Wet / high flow years

• Higher Jordan River flows improve downstream delivery.
• More historical depletion ultimately reaches Farmington Bay.
• Existing downstream rights are less likely to intercept released water.

Implication:

Approximately 1.5 kaf of durable environmental accretion.

Dry / low flow years

• River administration becomes more restrictive.
• Greater opportunity for downstream diversion.
• Historical depletion remains conserved, but less ultimately reaches Great Salt Lake.

Implication:

Approximately 1.0 kaf of durable environmental accretion.

Critical distinction

The project removes:

• historical agricultural depletion

It does NOT create:

• 3.5 kaf of new Great Salt Lake inflow
• additional basin yield
• new watershed runoff

The State Engineer explicitly notes that water released above historical depletion remains subject to existing downstream water rights.

Bottom line

The Utah Lake / Jordan River project demonstrates one of the most important accounting principles in the Great Salt Lake system: legal dedication is not the same as durable lake accretion. Although 3.5 kaf is permanently dedicated to environmental use, the State Engineer concludes that only the historical consumptive use represents new water to the system. Because releases occur through the entire Jordan River corridor, downstream diversions and river operations introduce additional uncertainty before water reaches Great Salt Lake. The project therefore provides a durable but modest increase in long-term lake inflow, illustrating why historical depletion—not the face value of a water right—is the appropriate basis for bankable water accounting.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a49954                 |      3.500    |     1.000      |     1.500

Utah Lake / Jordan River is a moderate-bankability, upstream depletion reduction.

• Historical depletion defines the durable benefit.
• Downstream river administration limits full realization.
• Excellent illustration that legal dedication and lake accretion are not synonymous.

This project provides perhaps the clearest legal demonstration that permanent dedication alone does not determine Great Salt Lake accretion; durable accretion is ultimately governed by historical depletion and downstream hydrology.

f50223 / RC023 Jordan River Aquifer Recharge

Municipal aquifer recharge

The Jordan River Aquifer Recharge project authorizes the Metropolitan Water District of Salt Lake and Sandy to divert up to 2,252 acre-feet per year from Little Cottonwood Creek for managed aquifer recharge within the Salt Lake Valley. Water is diverted during periods of available supply and placed into surface infiltration basins and injection wells to replenish the underlying aquifer.

Unlike traditional Great Salt Lake restoration projects, this application does not dedicate water directly to Great Salt Lake, nor does it authorize recovery of the recharged groundwater. The State Engineer expressly limits the application to recharge only. Any future recovery would require a separate approval.

Sources

Utah Division of Water Rights — Amended Recharge Application RC023; related Fixed-Time Change Application 57-6754 (f50223)

Order-authorized quantities

Component                          Volume (af)
---------------------------------------------
Underlying Water Rights            10,509
Maximum Annual Recharge             2,252
Maximum Diversion Rate             25.625 cfs
Project Type              Managed Aquifer Recharge

Interpretation

• Municipal aquifer recharge project
• Water stored underground rather than delivered to Great Salt Lake
• No groundwater recovery authorized
• No direct environmental dedication

Variability drivers:

• available Little Cottonwood Creek flows
• recharge opportunities
• aquifer performance
• future recovery applications

Ledger translation

Because the system:

• stores water underground
• authorizes recharge only
• does not authorize environmental delivery

the accounting identity is:

Recharge Authorization
        ≠
Great Salt Lake Accretion

What is bankable

The bankable component is:

None can presently be assigned.

The order authorizes recharge only. It does not authorize recovery of the stored groundwater or dedicate any measurable quantity of water to Great Salt Lake. Any future lake accretion would depend upon a separate recovery application and future municipal operating decisions that are outside the scope of this order.

What is NOT fully bankable

• Recharge is not environmental dedication.
• Recharge does not itself reduce Jordan River depletion.
• No recovery authorization exists.
• Future Great Salt Lake accretion cannot be inferred from this order.

Bankability Assessment

Factor                         Rating
-------------------------------------------
Proximity                      Low
Timing                         None
Control                        None
Measurement                    Low
Durability                     None

• Proximity — Low: Water is recharged into the southeast Salt Lake Valley aquifer rather than delivered to Great Salt Lake or its terminal wetlands.
• Timing — None: The order establishes no schedule or mechanism for lake delivery. Recharge may occur for approximately 90–180 days when water is available, but any recovery would require a separate permit.
• Control — None: The applicant controls recharge operations but has no authorization under this order to recover the stored groundwater or direct it to Great Salt Lake.
• Measurement — Low: Recharge quantities, groundwater levels, water quality, and aquifer mass balance must be measured and reported extensively. Those measurements document groundwater storage, however, not incremental Great Salt Lake accretion.
• Durability — None: The project may create durable groundwater storage, but it establishes no continuing or legally protected lake benefit. Any future benefit would depend on a separate recovery authorization and subsequent operating decisions.

Durability under wet and dry regimes

Wet / high flow years

• Greater opportunity to recharge groundwater.
• More water may be placed into storage.
• Recharge remains groundwater storage rather than lake delivery.

Implication:

Groundwater storage increases, but no measurable Great Salt Lake accretion is established.

Dry / low flow years

• Recharge opportunities decrease.
• Stored groundwater may become operationally valuable.
• The order authorizes neither groundwater recovery nor delivery to Great Salt Lake.

Implication:

Potential future substitution value increases, but no annual lake accretion can be assigned from this order alone.

Critical distinction

The project creates:

• groundwater storage

It does NOT create:

• dedicated Great Salt Lake water
• measurable annual lake inflow
• reduced basin depletion

Those outcomes would require a future recovery authorization and separate accounting.

Bottom line

Recharge Application RC023 is fundamentally different from the other projects evaluated in this analysis. It authorizes managed aquifer recharge—not environmental water delivery. Although the project may ultimately support more flexible municipal water management, the State Engineer expressly limits this approval to recharge and does not authorize recovery of the stored groundwater. As a result, no durable Great Salt Lake accretion can presently be assigned under the Water Ledger framework.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f50223                 |      9.660    |      0.000     |      0.000

State accounting reflects the underlying municipal water rights associated with the recharge project. Under the Water Ledger framework, however, this order alone does not establish measurable annual Great Salt Lake accretion.

Recharge Application RC023 is a high-confidence groundwater recharge initiative, but not a bankable Great Salt Lake restoration initiative.

• Improves groundwater storage.
• May support future municipal substitution.
• No direct, durable Great Salt Lake inflow demonstrated by this order.

This application demonstrates that authorization to recharge groundwater is not equivalent to authorization to restore Great Salt Lake. Any future lake accretion depends on subsequent recovery approvals and operating decisions, not on the recharge permit itself.

a50505 Kennecott Jordan River Rediversion

Industrial reuse with environmental redirection

Permanent Change Application a50505 modifies Water Right 59-23, historically used by Kennecott Utah Copper for mining, milling, refining, and smelting along the Jordan River. The order authorizes continued industrial use while adding wildlife management, fishing, recreation, and other public purposes within Great Salt Lake. Water that is not required for industrial operations may be conveyed through the C7 Ditch to Lee Creek and ultimately into Great Salt Lake.

Unlike agricultural conservation projects, this application does not permanently reduce historical consumptive use. Instead, it redirects excess industrial water that would otherwise remain within Kennecott’s operating system. The lake accretion therefore depends upon annual industrial demand rather than a permanent reduction in depletion.

Sources

Utah Division of Water Rights — Permanent Change Application 59-23 (a50505)

Order-authorized parameters

Component                         Volume (af)
--------------------------------------------
Historical Diversion Right        28,733
Historical Use               Mining / Industrial
Maximum Diversion                  83.65 cfs
Environmental Use Added    Wildlife / GSL

Interpretation

• Existing industrial water right
• Historical diversion and depletion unchanged
• Excess unused water may be routed to Great Salt Lake
• Environmental accretion depends upon annual industrial operations

Variability drivers:

• industrial production
• milling and smelting demand
• annual operating schedules
• availability of excess water

Ledger translation

Because the system:

• preserves historical industrial use
• redirects only water that is not consumed
• does not reduce the historical depletion limit

the accounting identity is:

Dedicated Right
        ≠
Permanent lake accretion

Benefit = Industrial Water Not Consumed

What is bankable

The bankable component is:

Industrial water that would historically have remained within Kennecott’s operating system but is instead delivered through Lee Creek to Great Salt Lake.

Because industrial demand varies from year to year, the realized benefit is substantially less than the full 28.7 kaf dedicated under the order.

Using the Water Ledger framework:

• Durable dry-year benefit: approximately 20 kaf/year
• Durable wet-year benefit: approximately 26 kaf/year

Unlike the agricultural conversion orders on this page, no published historical average diversion or withdrawal record was available to anchor this estimate; the dry/wet range instead reflects an assumed typical share of unused authorized capacity redirected annually. If metered historical diversion data become available for this water right, they should replace this estimate.

What is NOT fully bankable

• Historical industrial consumptive use continues.
• The full 28.7 kaf water right is not environmental water.
• Actual deliveries depend upon annual mining operations.
• No additional basin yield is created.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        High
Measurement                    Medium
Durability                     Medium

• Proximity — High: Excess water is rediverted from the Jordan River through the C7 Ditch and Lee Creek into Great Salt Lake, creating a relatively short and direct delivery pathway.
• Timing — Medium: Environmental delivery occurs only when water is available beyond Kennecott’s continuing industrial requirements and remains subject to annual operations and river administration.
• Control — High: Kennecott controls its industrial operations and the redirection of unused water, is identified as the last water user on the relevant canals, and operates under the direction of the Utah Lake/Jordan River Commissioner.
• Measurement — Medium: The order requires measuring and totalizing recording devices for all diverted water, annual reporting, and records demonstrating compliance with the diversion limit. It does not expressly require separate measurement of the portion delivered to Great Salt Lake after industrial use.
• Durability — Medium: The permanent order preserves environmental redirection as an authorized use, but it does not permanently retire industrial depletion. The recurring lake benefit therefore depends on unused industrial capacity remaining available.

Durability under wet and dry regimes

Wet / high flow years

• Industrial demand generally represents a smaller fraction of available supply.
• More excess water can be redirected to Lee Creek.
• Environmental accretion approaches the upper end of the historical range.

Implication:

Higher realized lake accretion.

Dry / low flow years

• Industrial operations continue to receive priority within the authorized right.
• Less unused water remains available for environmental delivery.
• The order guarantees no minimum environmental delivery.

Implication:

Meaningful benefit continues, but annual deliveries decline.

Critical distinction

The project redirects:

• unused industrial water

It does NOT eliminate:

• historical industrial depletion
• industrial consumptive use
• basin water demand

Unlike agricultural conservation projects, the environmental accretion is created through operational management rather than permanent depletion reduction.

Bottom line

Permanent Change Application a50505 is a high-value, near-lake environmental redirection project, but its benefit is fundamentally operational rather than structural. The State Engineer allows Kennecott to continue its historical industrial use while directing surplus water to Great Salt Lake whenever it is not required for mining operations. As a result, the legal dedication of 28.7 kaf overstates the quantity of durable annual lake accretion. Under the Water Ledger framework, the more meaningful accounting measure is the long-term volume of water that consistently bypasses industrial use and reaches Great Salt Lake under varying hydrologic conditions.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a50505                 |      28.730   |     20.000     |     26.000

Kennecott Rediversion is a high-bankability, near-lake operational redirection project.

• Permanent legal dedication
• Direct conveyance to Great Salt Lake
• Benefit varies with industrial demand rather than hydrology alone

The State Engineer dedicated the full industrial water right for potential environmental use. The Water Ledger instead estimates the portion that is likely to become durable annual Great Salt Lake inflow after accounting for continuing industrial operations.

a50506 Kennecott Jordan River Rediversion II

Industrial reuse with environmental redirection

Permanent Change Application a50506 modifies Water Right 59-30, historically used by Kennecott Utah Copper for mining, milling, refining, and smelting along the Jordan River. The order authorizes continued industrial use while adding wildlife management, fishing, recreation, and other public purposes within Great Salt Lake. Water that is not required for industrial operations may be conveyed through the C7 Ditch to Lee Creek and ultimately into Great Salt Lake.

Unlike agricultural conservation projects, this application does not permanently reduce historical consumptive use. Instead, it redirects excess industrial water that would otherwise remain within Kennecott’s operating system. The lake accretion therefore depends upon annual industrial demand rather than a permanent reduction in depletion.

Sources

Utah Division of Water Rights — Permanent Change Application 59-30 (a50506)

Order-authorized parameters

Component                         Volume (af)
--------------------------------------------
Historical Diversion Right        17,174
Historical Use               Mining / Industrial
Maximum Diversion                  23.72 cfs
Environmental Use Added        Wildlife / GSL

Interpretation

• Existing industrial water right
• Historical diversion and depletion unchanged
• Excess unused water may be routed to Great Salt Lake
• Environmental accretion depends upon annual industrial operations

Variability drivers:

• industrial production
• milling and smelting demand
• annual operating schedules
• availability of excess water

Ledger translation

Because the system:

• preserves historical industrial use
• redirects only water that is not consumed
• does not reduce the historical depletion limit

The accounting identity is:

Dedicated Right
        ≠
Permanent lake accretion

Benefit = Industrial Water Not Consumed

What is bankable

The bankable component is:

Industrial water that would historically have remained within Kennecott’s operating system but is instead delivered through Lee Creek to Great Salt Lake.

Because industrial demand varies from year to year, the realized benefit is substantially less than the full 17.2 kaf dedicated under the order.

Using the Water Ledger framework:

• Durable dry-year benefit: approximately 12 kaf/year
• Durable wet-year benefit: approximately 16 kaf/year

Unlike the agricultural conversion orders on this page, no published historical average diversion or withdrawal record was available to anchor this estimate; the dry/wet range instead reflects an assumed typical share of unused authorized capacity redirected annually. If metered historical diversion data become available for this water right, they should replace this estimate.

What is NOT fully bankable

• Historical industrial consumptive use continues.
• The full 17.2 kaf water right is not environmental water.
• Actual deliveries depend upon annual mining operations.
• No additional basin yield is created.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        High
Measurement                    Medium
Durability                     Medium

• Proximity — High: Excess water is rediverted from the Jordan River through the C7 Ditch and Lee Creek into Great Salt Lake, providing a relatively short and direct delivery pathway.
• Timing — Medium: Environmental delivery occurs only when water is available beyond Kennecott’s continuing industrial requirements and remains subject to annual operations and river administration.
• Control — High: Kennecott controls its industrial operations and the redirection of unused water, is identified as the last water user on the relevant canals, and operates under the direction of the Utah Lake/Jordan River Commissioner.
• Measurement — Medium: The order requires measuring and totalizing recording devices for all diverted water, annual reporting, and records demonstrating compliance with the 17,174.5 acre-foot diversion limit. It does not expressly require separate measurement of the portion delivered to Great Salt Lake after industrial use.
• Durability — Medium: The permanent order preserves environmental redirection as an authorized use, but it does not permanently retire industrial depletion. The recurring lake benefit therefore depends on unused industrial capacity remaining available.

Durability under wet and dry regimes

Wet / high flow years

• Industrial demand generally represents a smaller fraction of available supply.
• More excess water can be redirected to Lee Creek.
• Environmental accretion approaches the upper end of the historical range.

Implication:

Higher realized lake accretion.

Dry / low flow years

• Industrial operations continue to receive priority within the authorized right.
• Less unused water remains available for environmental delivery.
• The order guarantees no minimum environmental delivery.

Implication:

Meaningful benefit continues, but annual deliveries decline.

Critical distinction

The project redirects:

• unused industrial water

It does NOT eliminate:

• historical industrial depletion
• industrial consumptive use
• basin water demand

Unlike agricultural conservation projects, the environmental accretion is created through operational management rather than permanent depletion reduction.

Bottom line

Permanent Change Application a50506 applies the same environmental redirection strategy as the companion Kennecott change applications, but to a smaller industrial water right. The State Engineer allows continued historical industrial use while requiring that water not needed for mining operations be conveyed toward Great Salt Lake. As a result, the legal dedication of 17.2 kaf exceeds the quantity of durable annual lake accretion likely to occur over time. Under the Water Ledger framework, the more meaningful accounting measure is the volume of water that consistently bypasses industrial use and reaches Great Salt Lake under varying operating conditions.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet) 
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a50506                 |     17.170    |     12.000     |     16.000

Kennecott Rediversion is a high-bankability, near-lake operational redirection project.

• Permanent legal dedication
• Direct conveyance to Great Salt Lake
• Benefit varies with industrial demand rather than hydrology alone

The legal dedication represents the maximum quantity that may be redirected for environmental purposes. The Water Ledger estimates the smaller, durable annual volume that is likely to reach Great Salt Lake after accounting for continued industrial operations.

a50507 Jordan River Rediversion III

Industrial water right with an authorized environmental-delivery pathway

Permanent Change Application a50507 modifies Kennecott’s existing Jordan River industrial water right by adding public use, wildlife management, fishing, and recreation within the boundaries of Great Salt Lake. It preserves the historical mining and industrial uses. Water diverted from the Jordan River but not used for industrial purposes may be conveyed through the C7 Ditch to Lee Creek and into Great Salt Lake.

The order therefore creates a permanent legal pathway for environmental delivery, but it does not reserve or dedicate a fixed quantity exclusively to Great Salt Lake. Industrial use and approved temporary changes may continue within the same combined annual diversion limit.

Sources

Utah Division of Water Rights — Permanent Change Application 59-3517 (a50507), State Engineer Order dated August 28, 2023

Utah Division of Water Rights — 2026 Temporary Change Applications 59-3517 (t54363, t54365, t54366, and t54367)

Order-authorized parameters

Component                         Authorized amount
---------------------------------------------------
Combined annual diversion         8,750 af
Maximum diversion rate            26.64 cfs
Historical uses                   Mining / industrial
Environmental uses added          Public use / wildlife / GSL
Environmental volume reserved     None

Interpretation

• The underlying water right remains authorized for mining and industrial use.
• Surplus water may be conveyed through the C7 Ditch and Lee Creek to Great Salt Lake.
• The environmental use is permissive rather than exclusive.
• All permanent and temporary uses share the same 8,750 acre-foot annual ceiling.
• The order requires metering and annual reporting of water diverted under the right.
• It does not establish a minimum annual environmental delivery.

The continuing availability of the water for other approved uses is consequential. For 2026, four one-year temporary-change orders authorized a combined 8,515.82 acre-feet for irrigation and related uses:

Application                      Authorized diversion
------------------------------------------------------
t54363                            4,000.00 af
t54365                               50.00 af
t54366                            3,533.00 af
t54367                              932.82 af
------------------------------------------------------
Combined                          8,515.82 af

If those temporary authorizations were fully exercised, no more than 234.18 acre-feet of the 8,750 acre-foot annual ceiling would remain available for other uses during their effective period. Actual diversions and environmental deliveries must be determined from metered operating records.

Ledger translation

Because a50507:

• preserves historical industrial use
• allows subsequent temporary changes
• redirects only water that is not otherwise used
• establishes no minimum environmental-delivery volume

The accounting identity is:

Environmental use authorization
                ≠
Guaranteed lake accretion

Realized lake benefit
        =
Metered water actually conveyed
through Lee Creek to Great Salt Lake

What is bankable

A lake benefit may be credited only when records demonstrate that water was actually conveyed through the authorized route toward Great Salt Lake and was not simultaneously counted under an industrial or temporary use.

The permanent order establishes the legal mechanism and requires measurement and annual reporting. However, the currently available record does not establish a representative annual environmental-delivery history from which a durable dry-year or wet-year volume can be calculated.

For conservative portfolio accounting:

• Bankable dry-year benefit: 0 kaf/year pending measured delivery records
• Bankable wet-year benefit: 0 kaf/year pending measured delivery records

This does not mean that no water reaches Great Salt Lake under a50507. It means that no recurring annual quantity should be credited before the relevant diversion and environmental-delivery records are obtained and reconciled.

What is NOT fully bankable

• The full 8.75 kaf authorization
• Water used for mining or industrial purposes
• Water diverted under temporary-change orders
• Unused legal capacity without evidence of lake delivery
• An assumed 6–8 kaf annual surplus unsupported by operating records

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Low
Control                        Medium
Measurement                    Medium
Durability                     Low

• Proximity: The authorized route conveys water through the C7 Ditch and Lee Creek directly toward Great Salt Lake.
• Timing: No fixed environmental-delivery schedule or minimum annual quantity is established; timing depends on industrial operations, temporary changes, and water administration.
• Control: Kennecott can direct available water through the environmental pathway, but industrial uses, temporary changes, and distribution by the Utah Lake/Jordan River Commissioner limit exclusive environmental control.
• Measurement: The order requires measuring and totalizing devices and annual reporting, but a separately verified historical series of environmental deliveries to Great Salt Lake has not been established in the published record.
• Durability: The environmental use remains permanently authorized, but the volume realized for the lake is not protected from competing uses and may be negligible in years when most of the right is temporarily reassigned.

Durability under wet and dry regimes

Wet / high-flow years

• More water may be available after authorized industrial and temporary-change uses are satisfied.
• Higher Jordan River flows may improve delivery toward Great Salt Lake.
• The order nevertheless guarantees no minimum environmental delivery.

Implication:

Wet-regime bankable benefit is not quantified pending measured delivery records.

Dry / low-flow years

• Industrial demand may consume a larger share of the available supply.
• Prior-right administration may further limit environmental delivery.
• The order still provides no guaranteed minimum environmental delivery.

Implication:

Dry-regime bankable benefit is not quantified pending measured delivery records.

Critical distinction

The order permanently authorizes an environmental-delivery pathway. It does not permanently dedicate the underlying 8,750 acre-feet exclusively to Great Salt Lake.

Permanent pathway
        ≠
Permanent protected volume

Bottom line

Permanent Change Application a50507 provides a valuable legal and operational pathway by which unused Kennecott industrial water may be conveyed to Great Salt Lake. Its proximity is favorable, and the order requires metering and annual reporting. Nevertheless, industrial uses and temporary changes remain authorized within the same annual ceiling, and the order guarantees no minimum environmental delivery. Until measured delivery records establish a recurring lake benefit, the legal authorization should be reported separately from bankable annual lake accretion.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a50507                 |      8.750    |       -       |        - 

a50507 is a high-proximity but presently low-durability environmental-delivery mechanism.

• Permanent environmental use authorization
• Direct conveyance route toward Great Salt Lake
• No volume reserved exclusively for environmental delivery
• Annual credit dependent on verified measured deliveries

The 8.75 kaf amount is the shared legal diversion ceiling, not a guaranteed environmental delivery. Bankable lake accretion should be recognized only from measured water actually conveyed through the authorized route to Great Salt Lake.

f50738 Welby Jacob Exchange

Utah Lake exchange for Great Salt Lake environmental water

The order of the State Engineer approving Fixed-Time Change Application f50738 authorizes Jordan Valley Water Conservancy District (JVWCD), together with the Utah Division of Forestry, Fire and State Lands, the Utah Division of Wildlife Resources, and the Welby Jacob Water Users Company, to dedicate up to 10,000 acre-feet per year of Utah Lake storage water for Great Salt Lake environmental purposes. The application is part of the long-standing Welby Jacob Exchange, under which Utah Lake water is delivered to the Welby Jacob Water Users Company, allowing Jordan Valley Water Conservancy District to divert an equivalent amount of Provo River water for municipal supply. The Order also allows for a nuance in the exchange agreement which allows Jordan Valley to apply Provo River water to make up any deficit in the water due to Welby Jacobs in dry years. Since the order comprehends this nuance, the freed water volume made available by this arrangement may be redirected toward Great Salt Lake in wet or dry years.

Unlike projects that permanently reduce irrigation depletion, this application creates environmental water through an operational exchange. The quantity of water ultimately reaching Great Salt Lake depends upon annual exchange operations, river administration, downstream diversions, and the historical consumptive use associated with the underlying irrigation right.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-5272 (f50738)

Order-authorized quantities and historical-depletion calculation

Component                                 Volume (af)
-----------------------------------------------------
Maximum Utah Lake Exchange                 10,000
Historical Irrigated Acres                  2,000
Historical Consumptive Use                  4,243
Historical Return Flow                      5,757

The order specifically calculates the historical depletion associated with the underlying irrigation right as 4,243.33 acre-feet per year, with the balance historically returning to the river system. Water released in excess of that historical depletion remains subject to downstream diversion under existing water rights.

Interpretation

• Exchange project rather than direct conservation
• Municipal substitution creates environmental opportunity
• Historical consumptive use limits durable lake accretion
• Downstream administration determines realized delivery

Variability drivers:

• Utah Lake releases
• Provo River substitution
• Lower Jordan administration
• downstream diversions

Ledger translation

Because the system:

• exchanges Utah Lake water for municipal supply
• preserves historical consumptive use limits
• remains subject to downstream administration

The accounting identity is:

Dedicated Water
        ≠
Great Salt Lake accretion

Benefit = Historical Depletion
          × Successful Delivery

What is bankable

The bankable component is:

The historical irrigation depletion that can consistently be converted into environmental delivery through the Welby Jacob Exchange.

Using the Water Ledger framework as a conditional planning estimate:

• Estimated dry-year benefit: ~3 kaf/year
• Estimated wet-year benefit: ~4 kaf/year

These estimates are bounded by the order’s 4,243.33 acre-foot historical-depletion calculation. They are not guaranteed annual deliveries. The amount actually credited in any year should be reconciled to the diversion records reported by the river commissioners.

What is NOT fully bankable

• The full 10,000 af exchange is not environmental water.
• Historical return flows were already part of the river system.
• Water released beyond historical depletion may be diverted downstream.
• Annual delivery depends upon exchange operations and river commissioner administration.
• Continued delivery after December 31, 2028 is not assured unless the fixed-time authorization is extended.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Medium
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: Water must travel from Utah Lake through the Jordan and Lower Jordan River system before reaching Great Salt Lake, leaving it exposed to routing losses and downstream administration.
• Timing: The amount delivered directly to Great Salt Lake is determined annually and must be coordinated with Utah Lake releases, exchange operations, and river commissioners.
• Control: The applicants can designate water for environmental delivery, but implementation depends on the Welby Jacob Exchange and administration by both the Utah Lake/Jordan River and Lower Jordan River commissioners.
• Measurement: The order requires a record of all water diverted under f50738 and requires that record to be included in the river commissioner’s annual report.
• Durability: The authorization is repeatable during its approved term but expires December 31, 2028, unless an extension is timely requested and approved.

Durability under wet and dry regimes

Wet / high flow years

• Exchange operations are easier to implement.
• Higher river flows improve downstream delivery.
• Realized benefit approaches the upper end of the historical depletion range.

Implication:

Strong environmental delivery.

Dry / low flow years

• River administration becomes more restrictive.
• Downstream diversion pressure increases.
• Some exchanged water may be intercepted before reaching Great Salt Lake.

Implication:

Durable benefit remains positive but is somewhat reduced.

Critical distinction

The project creates:

• environmental water through exchange and substitution

It does NOT create:

• new basin yield
• additional water supply
• benefit equal to the full exchange volume

The durable benefit is governed by historical depletion, not by the total exchanged water.

Bottom line

The Welby Jacob Exchange demonstrates how existing municipal exchange agreements can create dedicated environmental water without reducing municipal water supply. During the fixed-time authorization, the State Engineer allows up to 10,000 acre-feet per year to be delivered directly for Great Salt Lake environmental purposes. Under the Water Ledger framework, the durable annual Great Salt Lake accretion is therefore substantially smaller than the legal dedication but remains one of the more repeatable exchange-based restoration projects in the basin.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f50738                 |     10.000    |      3.000     |      4.000

Welby Jacob is a moderate-bankability, exchange-based environmental dedication.

• Creates environmental water through substitution rather than new supply
• Historical depletion governs durable benefit
• Delivery depends on annual exchange operations and river administration

The Welby Jacob Exchange illustrates that dedicated environmental water created through exchange must still be evaluated against historical consumptive use and downstream delivery. Under the Water Ledger framework, durable lake accretion is measured by the water that consistently reaches Great Salt Lake—not by the total volume exchanged.

a51083 North Point

Near-lake agricultural depletion reduction

Permanent Change Application a51083 converts irrigation water historically used within the North Point Consolidated Irrigation Company into dedicated environmental water for Great Salt Lake. The application permanently retires irrigation on approximately 4,130 historically irrigated acres and redirects water through the Lower Jordan River, Surplus Canal, Farmington Bay, and Gilbert Bay for wildlife habitat and preservation of Great Salt Lake.

Unlike exchange projects or industrial operational changes, North Point permanently eliminates historical agricultural consumptive use. Because the project occurs immediately upstream of Great Salt Lake within existing conveyance infrastructure, it represents one of the most direct examples of durable depletion reduction currently implemented in Utah.

Sources

Utah Division of Water Rights — Permanent Change Application 59-6048 (a51083)

Order-authorized quantities and historical-depletion calculation

Component                         Volume (af)
--------------------------------------------
Total Diversion Right             20,650
Historical Consumptive Use         8,763
Historical Return Flow            11,887

Interpretation

• Permanent retirement of irrigation.
• Historical depletion becomes environmental water.
• Return flows remain part of the existing river system.
• Direct delivery through the Lower Jordan River and Surplus Canal.

Variability drivers:

• annual routing through Farmington Bay
• wetland operations
• hydrologic conditions

Ledger translation

Because the system:

• permanently eliminates irrigation depletion,
• occurs immediately upstream of Great Salt Lake,
• has measured historical consumptive use,

the accounting identity is:

Diversion Right
      ≠
lake accretion

Benefit = Historical Depletion

The State Engineer independently determined that historical depletion equals 8,762.58 acre-feet per year and notes that water in excess of that amount remains subject to downstream diversion.

What is bankable

The bankable component is:

Permanent elimination of historical irrigation depletion.

Using the State Engineer’s historical-depletion calculation as the central estimate:

• Durable dry-year benefit: ~7 kaf/year
• Durable wet-year benefit: ~9 kaf/year

These values closely bracket the State Engineer’s independent historical depletion calculation of 8.76 kaf/year.

What is NOT fully bankable

• The remaining 11.9 kaf historically returned to the river system.
• Water exceeding historical depletion may still be diverted under existing rights.
• The full 20.65 kaf legal dedication is therefore not equivalent to new lake inflow.
• Continued effectiveness requires the dedicated shares to remain in good standing and the applicants to complete proof of beneficial use.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    Medium
Durability                     High

• Proximity: The water enters the Lower Jordan River and Surplus Canal immediately upstream of Farmington Bay and Great Salt Lake.
• Timing: Irrigation diversion must cease, and the changed water is authorized for environmental use throughout the year; realized routing still varies with river and wetland operations.
• Control: The 5,765 North Point shares must remain dedicated to the environmental use, and deliveries are administered by the Lower Jordan River Commissioner.
• Measurement: The diversion entitlement and historical depletion are quantified from shares, irrigated acreage, duty, and benchmark consumptive use, but the order does not require a separate meter measuring final delivery at the lake.
• Durability: The change is permanent and requires the former irrigation diversion to cease, although the shares must remain dedicated and in good standing and proof of beneficial use must be completed by March 31, 2031.

Durability under wet and dry regimes

Wet / high flow years

• Full routing capacity available.
• Historical depletion almost fully realized.
• Excellent environmental delivery.

Implication:

Realized benefit approaches the upper end of the historical depletion range.

Dry / low flow years

• Historical irrigation remains retired.
• Some operational routing losses may occur.
• Wetland management may slightly reduce realized lake inflow.

Implication:

Benefit remains consistently high because the depletion reduction is permanent.

Critical distinction

The project permanently removes:

• agricultural consumptive use.

It does NOT create:

• new basin yield,
• benefit equal to the full diversion right.

Historical return flows already belonged to the Great Salt Lake system.

Bottom line

North Point is one of the strongest examples of durable Great Salt Lake restoration currently implemented. The State Engineer independently calculated the historical irrigation depletion at approximately 8.8 kaf/year, which closely matches the Water Ledger estimate of durable annual lake accretion. Although the legal dedication totals 20.65 kaf, the majority of that volume historically returned to the river system and therefore does not represent new water reaching Great Salt Lake. Under the Water Ledger framework, the project’s lasting value comes from permanently eliminating historical consumptive use immediately upstream of the lake, making it one of the highest-confidence restoration actions in the basin.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |      (kaf)    |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a51083                 |     20.650    |      7.000     |      9.000

North Point is a high-bankability, near-lake depletion reduction.

• Permanent elimination of irrigation depletion.
• Independent State Engineer depletion analysis validates the accounting.
• Strong proximity and highly durable annual benefit.

North Point demonstrates that the most durable Great Salt Lake restoration projects are those that permanently eliminate measured historical depletion immediately upstream of the lake. The legal dedication authorizes 20.65 kaf, but the lasting environmental accretion is defined by the approximately 8.8 kaf of historical consumptive use that has been permanently retired.

f51947 Jordan River Wildlife Habitat Conversion

Fixed-term industrial-to-habitat conversion

Fixed-Time Change Application f51947 authorizes the Central Utah Water Conservancy District and the Utah Division of Wildlife Resources to temporarily convert water historically used for industrial milling and refining into environmental water supporting Great Salt Lake, Farmington Bay, Gilbert Bay, and associated wildlife management areas. The application redirects Jordan River water from its former industrial use to public use, habitat management, fishing, recreation, and preservation of hydrophytic vegetation within Great Salt Lake. Because the project changes an existing consumptive industrial use to environmental use, it creates a measurable reduction in depletion while remaining subject to a fixed ten-year approval period.

Unlike permanent dedication projects such as North Point, this approval expires after ten years unless extended, making it a temporary conservation action rather than a permanent restoration asset.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-5334 (f51947)

Order-authorized parameters

Component                              Volume (af)
--------------------------------------------------
Industrial Water Right                  2,927
Authorized Annual Diversion             2,927
Project Duration                        10 years
Project Type                 Fixed-Time Change

Interpretation

• Temporary conversion from industrial use to environmental use.
• Existing industrial consumptive use is redirected to Great Salt Lake habitat.
• Environmental accretion depends upon annual operation during the approval period.

Variability drivers:

• Jordan River hydrology
• annual project operation
• future renewal of the fixed-time approval

Ledger translation

Because the system:

• redirects an existing consumptive use,
• delivers water through the Lower Jordan River,
• remains a fixed-time authorization,

the accounting identity is:

Industrial Use
        ↓
Environmental Use

Benefit = Reduced Consumptive Use
(during approval period)

What is bankable

The bankable component is:

Temporary reduction in industrial consumptive use.

Using the order-authorized diversion and conservative delivery assumptions:

• Durable benefit during approval period: approximately 2–2.5 kaf/year
• Water Ledger estimate:
• Dry: 2.0 kaf
• Wet: 2.5 kaf

What is NOT fully bankable

• The authorization is temporary rather than permanent.
• Future benefit depends upon renewal or replacement of the order.
• Annual delivery remains subject to Lower Jordan River administration and hydrologic conditions.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: The authorized points and places of use are in the Lower Jordan River, Farmington Bay, Gilbert Bay, and associated Great Salt Lake wetlands.
• Timing: Environmental use is authorized year-round, but diversion is allowed only after all prior Jordan River rights have been satisfied.
• Control: The applicants control the changed use, but actual diversion is administered by the Lower Jordan River Commissioner and remains subordinate to prior rights.
• Measurement: The order requires measuring and totalizing devices for all water diverted under f51947, annual reporting to the Lower Jordan River Commissioner, and reporting to the Division of Water Rights Water Use Program.
• Durability: The authorization remains effective through November 30, 2034, but continuation beyond that date requires a timely requested and approved extension.

Durability under wet and dry regimes

Wet / high flow years

• Full diversion generally available.
• Environmental delivery readily achieved.
• Strong habitat benefit.

Implication:

Benefit approaches the upper end of the estimated range.

Dry / low flow years

• Administration under prior rights may reduce available diversion.
• Habitat delivery may decline modestly.
• Environmental use remains prioritized within approved limits.

Implication:

Benefit remains positive but somewhat reduced during drought.

Critical distinction

The project converts:

• existing industrial consumptive use

It does NOT create:

• new basin yield,
• permanent environmental water.

The principal limitation is the temporary nature of the approval rather than uncertainty in the accounting.

Bottom line

Jordan River Wildlife Habitat Conversion demonstrates how existing consumptive industrial water rights can be temporarily redirected to benefit Great Salt Lake and associated wetlands. Because the underlying industrial use is assumed to be fully consumptive, much of the authorized diversion represents real depletion reduction while the order remains in effect. However, unlike permanent change applications, the authorization expires after ten years unless renewed. Under the Water Ledger framework, this project represents a moderate-to-high bankability restoration action whose principal limitation is administrative permanence rather than hydrologic uncertainty.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f51947                 |      2.930    |      2.000    |       2.500

Jordan River Wildlife Habitat Conversion is a high-quality but temporary depletion reduction.

• Authorized near-lake environmental delivery, subject to prior rights and Lower Jordan River administration.
• Strong proximity to Great Salt Lake.
• Durable only while the fixed-time approval remains in effect.

Unlike permanent change applications, the long-term value of this project depends less on hydrology than on whether the fixed-time authorization is ultimately renewed or converted into a permanent environmental water right.

f51983 Jordan River Irrigation Conversion

Fixed-term agricultural-to-habitat conversion

Fixed-Time Change Application f51983 authorizes Jordan Valley Water Conservancy District and the Utah Division of Wildlife Resources to temporarily convert an existing agricultural irrigation water right into environmental water supporting Great Salt Lake, Farmington Bay, Gilbert Bay, and associated wildlife management areas. The project redirects Jordan River water historically used to irrigate agricultural land toward public use, wildlife habitat, fishing, recreation, and hydrophytic vegetation within the Great Salt Lake ecosystem. Because the project converts an existing irrigation use, the environmental accretion is limited by the historical consumptive use of the underlying right rather than the full diversion authorized.

Unlike permanent restoration projects such as North Point, this approval is a fixed-time change application with a ten-year duration unless extended.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 57-3575 (f51983)

Order-authorized quantities and historical-depletion calculation

Component                              Volume (af)
--------------------------------------------------
Historical Diversion Right             5,565.91
Historical Consumptive Use             2,359.95
Historical Return Flow                 3,205.96
Project Duration                       10 years

Interpretation

• Temporary conversion from irrigation to environmental use.
• Historical depletion becomes the maximum durable environmental accretion.
• Historical return flows remain part of the existing river system.
• Water in excess of historical depletion remains subject to downstream diversion.

Variability drivers:

• Lower Jordan River administration
• annual river hydrology
• future renewal of the fixed-time approval

Ledger translation

Because the system:

• converts agricultural consumptive use,
• preserves historical return flows,
• remains a fixed-term authorization,

the accounting identity is:

Diversion Right
        ≠
lake accretion

Benefit = Historical Depletion

The State Engineer independently determined the historical depletion to be 2,359.95 acre-feet per year, noting that diversions above this amount remain subject to existing downstream water rights.

What is bankable

The bankable component is:

Temporary elimination of historical irrigation depletion during the life of the approval.

Using the State Engineer’s historical-depletion calculation as the central estimate:

• Durable dry-year benefit: ~2.0 kaf/year
• Durable wet-year benefit: ~2.5 kaf/year

These estimates closely bracket the State Engineer’s independent historical depletion analysis.

What is NOT fully bankable

• Approximately 3.2 kaf/year historically returned to the river system.
• Water exceeding historical depletion remains subject to downstream diversion.
• The authorization expires after ten years unless renewed.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: Water is redirected through the Lower Jordan River to Farmington Bay, Gilbert Bay, and associated Great Salt Lake habitat.
• Timing: Environmental use is authorized during the historical irrigation season, April 1 through October 31, and remains subject to prior rights and annual river conditions.
• Control: The former irrigation use must cease during the fixed-time term, but diversion is administered by the Lower Jordan River Commissioner and must be coordinated with the underlying permanent change application.
• Measurement: The order requires controlling works and a meter and requires records of diversions under both f51983 and the underlying permanent application to be included in the river commissioner’s annual report.
• Durability: The conversion remains authorized through November 30, 2034; continuation after that date requires a timely requested and approved extension.

Durability under wet and dry regimes

Wet / high flow years

• Full diversion generally available.
• Historical depletion largely realized.
• Strong habitat benefit.

Implication:

Environmental accretion approaches the upper end of the historical depletion range.

Dry / low flow years

• River administration becomes more restrictive.
• Historical depletion reduction remains.
• Some delivery may be constrained by prior rights.

Implication:

Benefit remains positive but modestly reduced.

Critical distinction

The project removes:

• historical irrigation consumptive use.

It does NOT create:

• new basin yield,
• benefit equal to the full diversion right.

Historical return flows were already part of the Lower Jordan River system.

Bottom line

Fixed-Time Change Application f51983 illustrates the importance of distinguishing between legal diversion and durable environmental accretion. Although the application authorizes up to 5,565.91 acre-feet annually, the State Engineer independently determined that only 2,359.95 acre-feet represented historical consumptive use. Under the Water Ledger framework, this historical depletion—not the full diversion—is the quantity that can reasonably be considered durable Great Salt Lake accretion during the life of the project. Because the approval is temporary, the principal limitation is administrative permanence rather than hydrologic uncertainty.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
-----------------------------------------------------------------------
f51983                 |      5.566    |      2.000     |      2.500

Jordan River Irrigation Conversion is a moderate-to-high bankability, temporary depletion reduction.

• State Engineer depletion analysis closely validates the Water Ledger methodology.
• Strong proximity to Great Salt Lake.
• Long-term benefit depends upon renewal of the fixed-time approval.

This project demonstrates that the durable environmental accretion of an irrigation conversion is defined by historical consumptive use—not by the full legal diversion. The State Engineer’s independent depletion analysis closely mirrors the accounting approach used in the Water Ledger.

f51985 Jordan River Irrigation Conversion II

Fixed-term agricultural-to-habitat conversion

Fixed-Time Change Application f51985 authorizes Jordan Valley Water Conservancy District and the Utah Division of Wildlife Resources to temporarily convert an existing agricultural irrigation water right into environmental water supporting Farmington Bay and Great Salt Lake. The project redirects water historically used for irrigation to wildlife habitat, fisheries, recreation, and hydrophytic vegetation within the Great Salt Lake ecosystem. As with other irrigation conversion projects, the durable environmental accretion is determined by the historical consumptive use of the underlying right rather than the full diversion authorized.

This is a fixed-time approval with a ten-year duration unless extended, making it an effective but temporary reduction in irrigation depletion.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-5771 (f51985)

Order-authorized quantities and historical-depletion calculation

Component                              Volume (af)
--------------------------------------------------
Historical Diversion Right             4,330.64
Historical Consumptive Use             1,837.63
Historical Return Flow                 2,493.01
Project Duration                       10 years

Interpretation

• Temporary conversion from irrigation to environmental use.
• Historical depletion establishes the maximum durable environmental accretion.
• More than one-half of the historical diversion historically returned to the river system.
• Water exceeding historical depletion remains available to satisfy downstream rights.

Variability drivers:

• Lower Jordan River administration
• annual river conditions
• renewal of the fixed-time approval

Ledger translation

Because the system:

• converts irrigation depletion,
• preserves historical return flows,
• remains a temporary authorization,

the accounting identity is:

Diversion Right
        ≠
lake accretion

Benefit = Historical Depletion

The State Engineer determined the historical depletion to be 1,837.63 acre-feet per year and noted that water diverted above this amount may be subject to downstream diversion and beneficial use.

What is bankable

The bankable component is:

Permanent reduction in historical irrigation depletion during the life of the approval.

Using the State Engineer’s historical-depletion calculation as the central estimate:

• Realistic dry-year benefit: ~1.4 kaf/year
• Realistic wet-year benefit: ~1.8 kaf/year

These values closely match the independently calculated historical depletion.

What is NOT fully bankable

• Approximately 2.5 kaf/year historically returned to the Lower Jordan River.
• Water exceeding historical depletion remains available to satisfy existing downstream rights.
• The authorization expires after ten years unless renewed.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: Water bypasses the Brighton and North Point Canal diversion into the Lower Jordan River and Surplus Canal near Farmington Bay and Great Salt Lake.
• Timing: Environmental use is authorized from April 1 through September 30, but diversion is allowed only after all prior Jordan River rights have been satisfied.
• Control: The former irrigation use must cease during the fixed-time term, but delivery is administered by the Lower Jordan River Commissioner and remains subordinate to prior rights.
• Measurement: The order requires measuring and totalizing devices for all water diverted under f51985 and annual reporting to both the Lower Jordan River Commissioner and the Division of Water Rights Water Use Program.
• Durability: The conversion remains authorized through November 30, 2034; continuation after that date requires a timely requested and approved extension.

Durability under wet and dry regimes

Wet / high flow years

• Full diversion generally available.
• Historical depletion largely realized.
• Strong habitat and environmental accretion.

Implication:

Environmental accretion approaches the upper end of the historical depletion range.

Dry / low flow years

• River administration becomes more restrictive.
• Historical depletion reduction remains.
• Delivery may be somewhat constrained by senior rights.

Implication:

Benefit remains durable but somewhat reduced during drought.

Critical distinction

The project removes:

• historical irrigation consumptive use.

It does NOT create:

• new basin yield,
• benefit equal to the full diversion right.

Historical return flows were already part of the Lower Jordan River system and therefore cannot be counted as new Great Salt Lake accretion.

Bottom line

Fixed-Time Change Application f51985 is another strong example of the distinction between legal dedication and durable environmental accretion. Although the application authorizes 4,330.64 acre-feet annually, the State Engineer determined that only 1,837.63 acre-feet represented historical consumptive use. Under the Water Ledger framework, this historical depletion defines the maximum durable Great Salt Lake accretion during the life of the project. Like the companion Jordan River conversions, the principal limitation is administrative permanence rather than hydrologic uncertainty.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f51985                 |     4.331     |      1.400     |      1.800

Jordan River Irrigation II is a moderate-to-high bankability, temporary depletion reduction.

• Independent State Engineer depletion analysis validates the Water Ledger accounting approach.
• High proximity to Great Salt Lake.
• Long-term benefit depends upon renewal of the fixed-time authorization.

Like f51983, this project demonstrates that the durable environmental accretion of an irrigation conversion is determined by historical consumptive use rather than the full legal diversion. The State Engineer’s depletion analysis independently arrives at the same accounting principle used in the Water Ledger.

f51986 Jordan River Irrigation Conversion III

Fixed-term agricultural-to-habitat conversion

Fixed-Time Change Application f51986 authorizes Jordan Valley Water Conservancy District and the Utah Division of Wildlife Resources to temporarily convert the irrigation component of an existing agricultural water right into environmental water supporting Farmington Bay, Gilbert Bay, and Great Salt Lake. The underlying right also includes year-round stockwatering for 390 equivalent livestock units, which remains authorized as before. The environmental accretion is therefore determined by the historical consumptive use of the converted irrigation component—not by the total diversion authorized under the mixed-use water right.

The approval is temporary, remaining in effect for ten years unless extended.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-5772 (f51986)

Order-authorized quantities and historical-depletion calculation

Component                              Volume (af)
--------------------------------------------------
Total mixed-use diversion right         2,163.672
Irrigation diversion converted          1,730.936
Stockwatering diversion retained          432.736
Historical irrigation depletion           918.120
Historical irrigation return flow         812.816
Project duration                         10 years

Interpretation

• Temporary conversion from irrigation to environmental use.
• Historical depletion defines the maximum durable lake accretion.
• More than half of the diverted water historically returned to the river system.
• Water exceeding historical depletion remains available to satisfy downstream water rights.

Variability drivers:

• Lower Jordan River administration
• annual river hydrology
• renewal of the fixed-time approval

Ledger translation

Because the system:

• converts irrigation consumptive use,
• preserves historical return flows,
• remains a temporary authorization,

the accounting identity is:

Diversion Right
        ≠
lake accretion

Benefit = Historical Depletion

The State Engineer determined the historical irrigation depletion to be 918.12 acre-feet per year, noting that water diverted beyond this amount may be subject to diversion and beneficial use by downstream rights.

What is bankable

The bankable component is:

Temporary elimination of historical irrigation depletion during the life of the approval.

Using the State Engineer’s historical-depletion calculation as the central estimate:

• Realistic dry-year benefit: ~0.7 kaf/year
• Realistic wet-year benefit: ~0.9 kaf/year

These values closely bracket the independently calculated historical depletion.

What is NOT fully bankable

• Approximately 0.813 kaf/year of the converted irrigation diversion historically returned to the Lower Jordan River system.
• Approximately 0.433 kaf/year remains authorized for year-round stockwatering and is not converted to environmental use.
• Water exceeding historical depletion remains available to satisfy downstream rights.
• The approval expires after ten years unless renewed.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: The converted irrigation water bypasses the Brighton and North Point Canal diversion into the Lower Jordan River and Surplus Canal near Farmington Bay and Great Salt Lake.
• Timing: Environmental use of the converted irrigation component is authorized from April 1 through October 31, but diversion is allowed only after all prior Jordan River rights have been satisfied.
• Control: Historical irrigation diversion must cease during the fixed-time term, but stockwatering remains authorized and environmental delivery is administered by the Lower Jordan River Commissioner.
• Measurement: The order requires measuring and totalizing devices for all water diverted under f51986, records coordinated with the underlying permanent application, and annual reporting to the Lower Jordan River Commissioner and Division of Water Rights Water Use Program.
• Durability: The conversion remains authorized through November 30, 2034; continuation after that date requires a timely requested and approved extension.

Durability under wet and dry regimes

Wet / high flow years

• Full diversion generally available.
• Historical depletion largely realized.
• Strong habitat benefit.

Implication:

Environmental accretion approaches the full historical depletion amount.

Dry / low flow years

• River administration becomes more restrictive.
• Historical depletion reduction remains.
• Delivery may be modestly constrained by senior rights.

Implication:

Benefit remains durable but slightly reduced during drought.

Critical distinction

The project removes:

• historical irrigation consumptive use.

It does NOT create:

• new basin yield,
• benefit equal to the full diversion right.

Historical return flows were already part of the Lower Jordan River system and therefore cannot be counted as new Great Salt Lake accretion.

Bottom line

Fixed-Time Change Application f51986 authorizes a total mixed-use diversion of 2,163.672 acre-feet, but only 1,730.936 acre-feet represents the irrigation component converted to environmental use. The State Engineer calculated that 918.12 acre-feet of that irrigation diversion represented historical consumptive use; the remaining irrigation water historically returned to the river system, while approximately 432.736 acre-feet remains associated with continuing stockwatering. Under the Water Ledger framework, this historical depletion—not the full diversion right—is the quantity that can reasonably be considered durable Great Salt Lake accretion during the life of the project. The principal limitation is not hydrology but the temporary nature of the authorization.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f51986                 |     1.731     |      0.700     |      0.900

Jordan River Irrigation III is a moderate-to-high bankability, temporary depletion reduction.

• Independent State Engineer depletion analysis validates the Water Ledger accounting approach.
• High proximity to Great Salt Lake.
• Long-term benefit depends upon renewal of the fixed-time authorization.

Like the companion Jordan River irrigation conversions, this project demonstrates that durable Great Salt Lake accretion is defined by historical consumptive use rather than legal diversion volume. The State Engineer’s independent depletion analysis closely mirrors the accounting methodology used in the Water Ledger.

a52152 Compass Minerals

Industrial lake-withdrawal reduction

Permanent Change Application a52152 establishes one of the largest Great Salt Lake dedication agreements approved to date. The order approving a52152 allows Compass Minerals to continue extracting salt and minerals while permanently adding Great Salt Lake enhancement as a beneficial use of the same 156,000 acre-foot water rights. Under the accompanying agreement with the State of Utah, allowable industrial use withdrawals decrease as the elevation of the South Arm declines, with the unused portion of the authorized diversion remaining in Great Salt Lake for environmental purposes.

Unlike upstream conservation projects, this application does not reduce watershed depletion or create new basin inflow. Instead, it limits future industrial withdrawals directly from Great Salt Lake through an elevation-dependent operating schedule established by the State Engineer, thereby leaving water for environmental use in the lake at times when the water is most needed rather than diverting it for mineral extraction use. Compass Minerals may also elect to leave some water in the lake that it would otherwise be entitled to use, so the total benefit in a given year ultimately depends on the actual amount of water Compass decides to leave in the lake.

Sources

Utah Division of Water Rights — Reissued Order for Permanent Change Application 13-246 (a52152), September 26, 2025

Order-authorized parameters

Interpretation

• Permanent industrial water-right modification.
• Great Salt Lake enhancement added as a beneficial use.
• Maximum allowable industrial diversions decrease automatically as lake elevation declines.
• One of the State’s largest dedicated-water agreements.

Variability drivers:

• South Arm elevation
• industrial production requirements
• annual mineral demand

Ledger translation

Because the system:

• withdraws water directly from Great Salt Lake,
• allocates water between industrial and environmental use,
• adjusts allowable diversion according to lake elevation,

the accounting identity becomes:

Potential Environmental Allocation
=
Maximum Authorized Diversion
−
Allowed Industrial Diversion

For GSL Accounting, however, the objective is not to estimate the maximum legal environmental allocation. The objective is to estimate the representative annual increase in lake storage expected from reduced industrial withdrawals under wet and dry hydrologic regimes.

Constraints

Several factors limit the translation from legal dedication to durable annual lake accretion.

• The State Engineer’s order establishes maximum allowable diversions, not actual annual withdrawals.
• Actual industrial demand may be substantially lower than the authorized diversion.
• South Arm elevation is influenced by basin hydrology and Adaptive Management Berm operations, affecting which diversion threshold is triggered.
• The order creates a legal environmental allocation but does not, by itself, establish the annual volume of additional water retained in Great Salt Lake.

What is bankable

The bankable component is the expected reduction in industrial lake withdrawals under representative operating conditions.

Although the State Engineer’s order allows substantially larger environmental allocations at lower lake elevations, those values represent legal operating limits rather than expected annual withdrawals. GSL Accounting therefore estimates the durable annual benefit using representative operating conditions rather than maximum legal allocations.

As a representative accounting judgment within the range permitted by the order:

• Dry regime: approximately 32 kaf/year
• Wet regime: approximately 14 kaf/year

These figures were derived by reviewing the terms of the order alongside this order's own historical diversion records for 2021–2024 (approximately 24–100 kaf/year). We welcome engagement from the Division of Water Rights or other qualified reviewers who may wish to discuss or refine this estimate.

What is NOT fully bankable

• The full 156 kaf water right conditionally remains legally authorized.
• Elevation-based allocations represent maximum environmental availability rather than expected annual savings.
• The project does not create additional watershed inflow or reduce upstream consumptive use.
• Annual benefit depends upon actual industrial operations as well as the applicable elevation threshold.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    High
Durability                     High

• Proximity: The project governs withdrawals directly from Great Salt Lake, so no upstream routing or delivery loss separates the retained water from the lake.
• Timing: The applicable annual diversion limit is determined from the South Arm elevation measured on June 15 and governs industrial diversion during that calendar year.
• Control: The elevation schedule establishes enforceable maximum diversions, although the application remains subject to the future Great Salt Lake Distribution Management Plan.
• Measurement: FFSL must report the June 15 elevation from USGS Gage 10010000, and the applicants must meter and annually report all water diverted under the application.
• Durability: The change is permanent but remains valid only while FFSL continues as an interested party under the agreement and change application; proof of beneficial use is due by September 30, 2032 unless extended.

Durability under wet and dry regimes

Wet / higher-lake years

• Industrial diversion remains largely unrestricted.
• Environmental allocation is relatively small.
• Representative annual benefit is approximately 14 kaf.

Implication:

Useful environmental accretion, but limited influence on lake elevation.

Dry / lower-lake years

• Lower elevation triggers progressively reduce allowable industrial diversion.
• Environmental allocation increases substantially.
• Representative annual benefit is approximately 32 kaf.

Implication:

The project provides greater protection during drought but does not eliminate industrial depletion.

Critical distinction

The project reduces:

• future industrial withdrawals from Great Salt Lake.

It does NOT create:

• new watershed inflow,
• additional basin yield,
• upstream depletion reductions.

Unlike irrigation conservation projects, benefits result from limiting direct lake withdrawals rather than reducing historical consumptive use.

Bottom line

Compass Minerals a52152 represents one of the State’s most significant legal commitments to Great Salt Lake enhancement. The State Engineer’s order creates an adaptive operating framework in which industrial withdrawals are progressively reduced as lake elevation declines. While the legal environmental allocation can become substantially larger under severe low-lake conditions, GSL Accounting estimates a more conservative representative annual benefit by recognizing that actual industrial withdrawals, operating conditions, and lake elevations vary over time. The result is a durable but moderate increase in annual lake retention rather than the full legal allocation authorized by the order.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a52152                 |   156.000     |     32.000     |     14.000

Compass Minerals is a high-confidence industrial conservation initiative.

• Permanent reduction in potential industrial lake withdrawals.
• Benefits increase as lake elevation declines.
• Representative annual benefit is substantially smaller than the maximum legal allocation because it reflects expected operating conditions rather than theoretical capacity.

The State Engineer’s order establishes the legal framework for environmental protection. GSL Accounting estimates the representative annual lake accretion expected under that framework.

a52277 Compass Minerals

Industrial consumptive-use reduction

Permanent Change Application a52277 establishes a permanent reduction in consumptive industrial use by Compass Minerals. The order converts an existing mineral extraction water right to primarily non-consumptive industrial purposes while adding Great Salt Lake enhancement as a beneficial use. Compass may continue to divert water for mineral rinsing and pump operations, but consumptive mineral extraction under this right is eliminated. Any portion of the authorized diversion not used by Compass is dedicated to FFSL for preservation and enhancement of Great Salt Lake.

Unlike a52152, this order is not tied to lake elevation. Instead, the environmental accretion depends primarily on the difference between Compass’s actual annual non-consumptive diversion and the authorized annual diversion limit.

Sources

Utah Division of Water Rights — Permanent Change Application 13-3457 (a52277)

Order-authorized parameters

Component                               Volume (af)
---------------------------------------------------
Maximum Annual Diversion                60,089
Industrial Use              Non-consumptive rinsing
Beneficial Use Added        Great Salt Lake Enhancement
Project Type                Permanent

Interpretation

• Permanent conversion from consumptive mineral extraction to non-consumptive industrial use.
• Great Salt Lake enhancement added as a beneficial use.
• Water not diverted by Compass is automatically available for FFSL environmental use.
• Annual environmental accretion depends on actual industrial operations rather than lake elevation.

Variability drivers:

• annual industrial rinsing demand
• facility operations
• actual annual diversion

Ledger translation

Because the system:

• permanently removes consumptive mineral extraction under this right,
• limits future industrial use to non-consumptive purposes,
• dedicates unused annual diversion to FFSL,

the accounting identity becomes:

FFSL in-situ allocation
=
60,089.25685 af
−
Actual annual Compass diversion

Total water retained in the lake system
=
FFSL in-situ allocation
+
Compass water returned after non-consumptive use
−
Verified operational losses

Unlike upstream conservation projects, this order reduces future consumptive industrial use directly within Great Salt Lake rather than increasing watershed inflow.

Constraints

• The order establishes a maximum annual diversion, not a guaranteed annual environmental accretion.
• Actual annual benefit depends on Compass’s measured diversion each year.
• The order requires annual metering and reporting of diversions, allowing realized environmental accretion to be determined from observed operations rather than assumptions.
• The order does not increase basin yield or create new inflow to Great Salt Lake.

What is bankable

The bankable component is the permanent elimination of consumptive mineral-salt extraction under this water right. Water not diverted by Compass remains in situ under FFSL’s environmental use, while water diverted for the remaining non-consumptive purposes is returned through the order’s identified return points. Quantifying the resulting increase in lake storage requires records of historical consumptive extraction, current diversions, return flows, and any operational losses.

The following values are provisional accounting scenarios rather than quantities established by the order:

• Dry regime: approximately 50 kaf/year
• Wet regime: approximately 40 kaf/year

The order does not itself support a different dry- and wet-regime benefit because it contains no elevation-triggered diversion schedule. These estimates should be replaced or confirmed using verified historical consumptive extraction and operating records for Water Right 13-3457. Until that verification is completed, they should not be described as high-confidence measured benefits.

What is NOT fully bankable

• The full 60 kaf authorization is not automatically conserved every year.
• Actual benefit depends on Compass’s measured annual diversion.
• The order does not generate additional watershed inflow.
• Benefits are measured through reduced industrial consumptive use rather than increased tributary deliveries.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    Medium
Durability                     High

• Proximity: The project governs water withdrawn directly from and returned to Great Salt Lake, eliminating upstream routing uncertainty.
• Timing: The non-consumptive industrial and environmental uses are authorized year-round, subject to water availability, priority, and the future Great Salt Lake Distribution Management Plan.
• Control: The order permanently removes consumptive mineral-salt extraction and limits Compass to non-consumptive purposes, while assigning unused diversion capacity to FFSL in situ.
• Measurement: The order requires meters and annual reporting of all diversions, but it does not expressly require measurement of return flows or operational losses needed to quantify net lake retention.
• Durability: The change is permanent but remains valid only while FFSL continues as an interested party under the agreement and application; proof of beneficial use is due by September 30, 2032 unless extended.

Durability under wet and dry regimes

Wet / higher-lake years

• Authorized non-consumptive industrial use may continue.
• Water not required for authorized operations remains dedicated to Great Salt Lake enhancement.
• The order contains no elevation-triggered schedule establishing a distinct wet-regime quantity.

Implication:

The current 40 kaf/year wet-regime value is a provisional scenario estimate pending verification against historical consumptive extraction, diversions, return flows, and operating losses.

Dry / lower-lake years

• The permanent elimination of consumptive mineral-salt extraction continues to protect lake water.
• Actual lake retention depends on industrial operations, diversions, return flows, and losses.
• The order contains no elevation trigger that independently produces a larger dry-regime allocation.

Implication:

The current 50 kaf/year dry-regime value is a provisional scenario estimate, not an order-determined or measured benefit.

Critical distinction

The project reduces:

• consumptive mineral extraction,
• future industrial depletion from Great Salt Lake.

It does NOT create:

• new tributary inflow,
• additional basin yield,
• upstream depletion reductions.

Bottom line

Compass Minerals a52277 permanently converts a consumptive mineral extraction right to primarily non-consumptive industrial use while dedicating unused annual diversion to Great Salt Lake enhancement. Because the order permanently eliminates consumptive mineral-salt extraction, its legal protection is strong. However, annual net lake retention cannot be characterized as highly predictable until diversion, return-flow, and historical consumptive-use records are reconciled. GSL Accounting therefore treats this as one of the highest-confidence industrial conservation projects in the dedicated-water portfolio.

Compass Minerals is a strong permanent industrial conservation framework with a provisionally estimated annual benefit.

• Permanently converts consumptive mineral extraction to primarily non-consumptive industrial use.
• Environmental accretion is determined by measured annual industrial diversions rather than lake elevation.
• Representative annual benefit remains relatively stable because the order is based on actual operations rather than elevation-triggered diversion limits.

The State Engineer’s order permanently removes consumptive mineral extraction under this water right and requires annual measurement of actual diversions. GSL Accounting estimates the representative annual lake accretion expected from that operational framework rather than assuming the maximum legal allocation is realized each year.

a53108 North Shore Limited

Industrial lake-withdrawal reduction

Permanent Change Application a53108 establishes a permanent Great Salt Lake enhancement agreement between North Shore Limited and the Utah Division of Forestry, Fire and State Lands (FFSL). The order allows North Shore to continue mineral extraction while adding Great Salt Lake enhancement as a beneficial use of the same 125 acre-foot water right. Under the agreement, allowable industrial withdrawals decrease as the South Arm elevation declines, with the unused portion of the authorized diversion remaining in Great Salt Lake for environmental purposes.

Unlike upstream conservation projects, this application does not reduce watershed depletion or create additional basin inflow. Instead, it limits future industrial withdrawals directly from Great Salt Lake through an elevation-dependent operating schedule established by the State Engineer.

Sources

Utah Division of Water Rights — Order for Permanent Change Application 13-3723 (a53108), September 26, 2025

Order-authorized parameters

Interpretation

• Permanent industrial water-right modification.
• Great Salt Lake enhancement added as a beneficial use.
• Maximum allowable industrial diversions decrease automatically as lake elevation declines.
• Environmental allocation is determined by the State Engineer’s elevation schedule.

Variability drivers:

• South Arm elevation
• annual mineral production
• industrial demand

Ledger translation

Because the system:

• withdraws water directly from Great Salt Lake,
• allocates water between industrial and environmental use,
• adjusts allowable diversion according to lake elevation,

the accounting identity becomes:

Potential Environmental Allocation
=
Maximum Authorized Diversion
−
Allowed Industrial Diversion

For GSL Accounting, however, the objective is not to estimate the maximum legal environmental allocation. The objective is to estimate the representative annual increase in lake storage expected from reduced industrial withdrawals under wet and dry hydrologic regimes.

Constraints

• The State Engineer’s order establishes maximum allowable diversions, not actual annual withdrawals.
• Actual industrial demand may be lower than the authorized diversion.
• South Arm elevation—and therefore the applicable diversion limit—depends on basin hydrology and future lake-management decisions.
• The order creates a legal environmental allocation but does not establish the annual volume of additional water retained in Great Salt Lake.

What is bankable

The bankable component is the expected reduction in industrial lake withdrawals under representative operating conditions.

As a representative accounting judgment within the range permitted by the order:

• Dry regime: approximately 90 af/year
• Wet regime: approximately 20 af/year

These representative values are rounded from the order’s elevation schedule. The dry-regime estimate of approximately 90 af/year corresponds closely to the 87.5 af FFSL allocation when the South Arm is between 4,190.01 and 4,192.99 feet. The wet-regime estimate of approximately 20 af/year corresponds closely to the 21.25 af allocation between 4,195.00 and 4,197.99 feet. At or above 4,198 feet, the required in-situ allocation is zero; at or below 4,190 feet, it is the full 125 acre-feet.

What is NOT fully bankable

• The full 125 af water right remains legally authorized.
• Elevation-based allocations represent maximum environmental availability rather than expected annual savings.
• The project does not create additional watershed inflow or reduce upstream consumptive use.
• Annual benefit depends upon actual industrial operations and the applicable elevation threshold.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    High
Durability                     High

• Proximity: The project governs withdrawals directly from Great Salt Lake, eliminating upstream routing and delivery uncertainty.
• Timing: The applicable diversion limit is determined from the South Arm elevation measured on June 15 and governs the ensuing annual industrial allocation.
• Control: The elevation schedule establishes enforceable maximum industrial diversions, although the application remains subject to the future Great Salt Lake Distribution Management Plan.
• Measurement: FFSL must report the June 15 elevation from USGS Gage 10010000, and the applicants must meter and annually report all water diverted under the application.
• Durability: The change is permanent but remains valid only while FFSL continues as an interested party under the agreement and application; proof of beneficial use is due by September 30, 2032 unless extended.

Durability under wet and dry regimes

Wet / higher-lake years

• Industrial diversion remains largely unrestricted.
• Environmental allocation is relatively small.
• At or above 4,198 feet, the order assigns no mandatory in-situ environmental allocation.

Implication:

Useful environmental accretion, but limited influence on lake elevation.

Dry / lower-lake years

• Lower lake elevations progressively reduce allowable industrial diversion.
• Environmental allocation increases substantially.
• At or below 4,190 feet, the full 0.125 kaf remains assigned to Great Salt Lake enhancement.

Implication:

The project provides greater protection during drought while maintaining industrial operations at reduced levels.

Critical distinction

The project reduces:

• future industrial withdrawals from Great Salt Lake.

It does NOT create:

• new watershed inflow,
• additional basin yield,
• upstream depletion reductions.

Unlike irrigation conservation projects, benefits result from limiting direct lake withdrawals rather than reducing historical consumptive use.

Bottom line

North Shore Limited a53108 establishes a permanent industrial conservation agreement in which allowable lake withdrawals decrease as Great Salt Lake elevation declines. The State Engineer’s order creates an adaptive operating framework that progressively shifts a larger portion of the 0.125 kaf water right to Great Salt Lake enhancement during lower-lake conditions. While the legal environmental allocation increases as lake elevation falls, GSL Accounting estimates a representative annual benefit by recognizing that actual industrial withdrawals, operating conditions, and lake elevations vary from year to year. The result is a durable but modest increase in annual lake retention rather than the maximum legal allocation authorized under the order.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a53108                 |    0.125      |      0.090     |     0.020

North Shore Limited is a high-confidence industrial conservation initiative.

• Permanent reduction in potential industrial lake withdrawals.
• Benefits increase as lake elevation declines.
• Representative annual benefit is substantially smaller than the maximum legal allocation because it reflects expected operating conditions rather than theoretical capacity.

The State Engineer’s order establishes the legal framework for environmental protection. GSL Accounting estimates the representative annual lake accretion expected under that framework.

f53187 Jordan River Irrigation Dedication

Fixed-time irrigation-to-lake conversion

The Jordan River Irrigation Dedication temporarily changes irrigation water historically served by the Utah and Salt Lake Canal Company to environmental use in Great Salt Lake. The project is sponsored by Jordan Valley Water Conservancy District, Utah and Salt Lake Canal Company, the Utah Division of Forestry, Fire and State Lands, and the Utah Division of Wildlife Resources. The amended fixed-time approval expires September 30, 2030, unless an extension is requested and approved.

Unlike earlier Jordan River projects that relied primarily on historical depletion estimates from Report 145, this amended order incorporates a project-specific depletion analysis prepared by the Division of Water Rights. The State Engineer estimated historical irrigation consumptive use at 884.81 acre-feet per year. The remaining 896.09 acre-feet of the authorized diversion was historically nondepleted water that may remain available to downstream water users.

Sources

Utah Division of Water Rights — Amended Order of the State Engineer for Amended Fixed-Time Change Application 59-5619 (f53187), dated May 4, 2026.

Order-authorized quantities and historical-depletion estimates (acre-feet)

Component                              Volume (af)
---------------------------------------------------
Maximum annual diversion                 1,780.90
Report 145 depletion estimate              804.97
State Engineer depletion estimate          884.81
Historical nondepleted water               896.09

Interpretation

• Irrigation use of the associated 388 canal-company shares must cease during the approved fixed-time period.
• Water may be delivered for environmental use on Great Salt Lake sovereign lands.
• The State Engineer uses a project-specific historical-depletion estimate rather than treating the full diversion as lake benefit.
• Water diverted above 884.81 acre-feet may remain subject to diversion and beneficial use by existing Lower Jordan River water users.
• Diversions are administered by the Utah Lake/Jordan River and Lower Jordan River commissioners, and the applicants must report annual diversions and uses.

Ledger translation

Because the system:

• suspends the historical irrigation use during the approved fixed-time period,
• occurs near the terminal Jordan River,
• distinguishes depletion from return flow,

the accounting identity is:

Diversion ≠ Benefit to Lake

Benefit = Historical Depletion Eliminated

What is bankable

The bankable component is the elimination of historical irrigation depletion.

The State Engineer calculated project-specific historical depletion at 884.8 acre-feet per year, replacing the more generalized Report 145 estimate of approximately 805 acre-feet. Water in excess of that depletion remains available to downstream appropriators because it historically existed as return flow.

Using the Water Ledger framework:

• Realistic durable range: 0.8–0.9 kaf/year.
• Upper bound (1.78 kaf diversion): not bankable

What is NOT fully bankable

• Historical return flows (~896 af)
• were already part of the Jordan River system
• continue to satisfy downstream rights
• Full diversion volume cannot be counted as new Great Salt Lake inflow.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         High
Control                        High
Measurement                    Medium
Durability                     Medium

• Proximity: The changed water is delivered through the Lower Jordan River system immediately upstream of Great Salt Lake.
• Timing: The order authorizes year-round environmental use, although actual routing remains subject to river administration.
• Control: The associated canal-company shares must remain dedicated to the changed use; historical irrigation must cease; and diversions are administered by the river commissioners.
• Measurement: Annual diversion and use reporting is required, and the State Engineer established a project-specific depletion estimate. Actual lake accretion is inferred from eliminated depletion rather than measured directly at the lake.
• Durability: The approval is fixed-time and expires September 30, 2030, unless extended. The benefit is durable during the approved term but is not yet permanent.

Durability under wet and dry regimes

Wet / high flow years

• Historical depletion is almost fully realized.
• Routing flexibility allows efficient delivery.
• Additional diverted water remains available to downstream users.

Implication:

Strong and measurable lake accretion.

Dry / low flow years

• Irrigation depletion remains eliminated.
• River administration may influence timing.
• Benefit remains close to historical depletion.

Implication:

Durable environmental accretion with only modest hydrologic variability.

Critical distinction

This order explicitly recognizes that:

• only historical depletion represents new environmental water;
• historical return flows remain part of the existing water-right system.

In doing so, it reinforces one of the central accounting principles of the Great Salt Lake Water Ledger:

Dedicated Water ≠ Bankable Water

The durable environmental accretion is measured by depletion reduction, not diversion volume.

Bottom line

The Jordan River Irrigation Dedication represents a high-confidence depletion-reduction project immediately upstream of Great Salt Lake. It is especially significant because the State Engineer independently performed a project-specific depletion analysis and reached the same accounting conclusion developed throughout this Water Ledger analysis: lake accretion is determined by eliminated historical consumptive use rather than by the full diversion volume. During the approved fixed-time period, the project can therefore provide a highly reliable annual increase in lake inflow while preserving historical return flows for downstream water users.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f53187                 |     1.781     |      0.800     |      0.900

Jordan River Dedication is a high-bankability, near-lake depletion reduction.

• Bankable inflow: approximately 0.8–0.9 kaf/year during the approved term
• State Engineer validated depletion accounting
• Excellent agreement with the Water Ledger framework

This order is one of the clearest demonstrations that durable Great Salt Lake accretion is governed by historical depletion rather than diversion volume. By independently quantifying consumptive use and preserving historical return flows, the State Engineer reaches the same accounting principle that underpins the Great Salt Lake Water Ledger.

a53323 Earth’s Elements

Adaptive industrial diversion agreement

The Earth’s Elements project establishes a permanent change application under which water not diverted for industrial mineral extraction is used by the Utah Division of Forestry, Fire and State Lands for Great Salt Lake enhancement. The State Engineer’s order makes the allocation dependent on the South Arm elevation measured each June 15. As lake elevation declines, Earth’s Elements’ authorized industrial diversion decreases and FFSL’s corresponding in-situ environmental use increases.

Unlike most dedicated water projects, this is not an irrigation-to-environment conversion. Instead, it is an adaptive operational agreement that directly links industrial water use to lake conditions, making it one of the first examples of elevation-triggered water management in the Great Salt Lake basin.

Sources

Utah Division of Water Rights — Permanent Change Application 13-3846 (a53323) and State Engineer Order.

Order-authorized elevation schedule (acre-feet)

South Arm elevation     Industrial use   FFSL in situ
                             (af)            (af)
------------------------------------------------------
4,198.00 or above           11.70             0.00
4,197.99–4,195.00            9.71             1.99
4,194.99–4,193.00            5.85             5.85
4,192.99–4,190.01            3.51             8.19
4,190.00 or below            0.00            11.70

Interpretation

• Industrial mineral extraction right.
• Diversions automatically decrease as lake elevation declines.
• Water remaining in the lake is dedicated to Great Salt Lake enhancement.
• One of the first elevation-responsive conservation agreements approved by the State Engineer.

Variability drivers:

• Great Salt Lake elevation
• annual industrial demand
• operational compliance
• future Distribution Management Plan

Ledger translation

Because the system:

• adjusts diversions based on lake elevation,
• leaves water in Great Salt Lake rather than creating new upstream inflow,
• directly links environmental accretion to lake conditions,

the accounting identity is:

Reduced Lake Withdrawal = Increased Lake Storage

What is bankable

The bankable component is the portion of the 11.7 acre-foot annual right assigned to FFSL for in-situ Great Salt Lake enhancement under the order’s elevation schedule. It equals 11.7 acre-feet minus Earth’s Elements’ authorized industrial diversion for the applicable elevation range.

Because the water originates within Great Salt Lake and remains in situ, no upstream conveyance or return-flow adjustment is required. The bankable quantity is therefore:

• 0 acre-feet at or above elevation 4,198.00 feet;
• 1.99 acre-feet from 4,197.99 to 4,195.00 feet;
• 5.85 acre-feet from 4,194.99 to 4,193.00 feet;
• 8.19 acre-feet from 4,192.99 to 4,190.01 feet; and
• 11.70 acre-feet at or below elevation 4,190.00 feet.

The applicable amount is determined annually using the June 15 South Arm elevation at USGS gage 10010000.

Elevation-dependent bankable range: 0–0.0117 kaf/year

What is NOT fully bankable

• Benefits depend upon annual lake elevation.
• Industrial diversions continue during higher lake conditions.
• The agreement governs only this specific industrial water right.
• No new basin yield is created.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    High
Durability                     High

• Proximity: The benefit consists of water retained directly within Great Salt Lake.
• Timing: The annual allocation is established from the June 15 South Arm elevation and applies to the following operating period.
• Control: The State Engineer’s order limits industrial diversion according to a binding elevation schedule and assigns the balance to FFSL.
• Measurement: FFSL must report the June 15 gage elevation, while all diversions must be metered with totalizing recording devices and reported annually.
• Durability: The change application is permanent, but it remains valid only while FFSL remains an interested party using the water under the agreement and change application. It will also be subject to the Great Salt Lake Distribution Management Plan when adopted.

Durability under wet and dry regimes

Wet / high lake years

• Earth’s Elements may divert its full 11.7 acre-feet.
• Environmental dedication is minimal.
• At or above 4,198 feet, the order assigns no mandatory in-situ environmental allocation.

Implication:

At or above 4,198 feet, Earth’s Elements may divert the entire 11.7 acre-feet and the incremental in-situ environmental allocation is zero.

Dry / low lake years

• Industrial diversions progressively decline.
• More water remains in Great Salt Lake.
• At elevations below 4,190 feet, all 11.7 acre-feet remain in the lake.

Implication:

Environmental accretion increases precisely when the lake is most stressed.

Critical distinction

This project does not reduce upstream consumptive use.

Instead, it reduces direct withdrawals from Great Salt Lake itself.

Unlike irrigation conversions, no return-flow accounting is required because every acre-foot left in the lake remains part of lake storage.

Bottom line

Although small in volume, the Earth’s Elements agreement represents an important policy innovation. Rather than permanently retiring a water right, it creates a flexible operating framework in which industrial diversions automatically decline as Great Salt Lake elevations fall. The result is an adaptive conservation mechanism that delivers increasing environmental accretion during periods of greatest ecological stress while allowing continued industrial operations during healthier lake conditions. This type of elevation-responsive administration may provide a useful model for future Great Salt Lake water management.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a53323                 |     0.012     |     0.012       |     0.000

Earth’s Elements is a high-bankability, adaptive industrial conservation project.

• Immediate benefit through reduced lake withdrawals.
• Environmental accretion increases as lake levels decline.
• Demonstrates an innovative approach to adaptive Great Salt Lake management.

Earth’s Elements shows that not every Great Salt Lake conservation project must create new inflow. By linking industrial diversions directly to lake elevation, this agreement keeps water in the lake when it is needed most, introducing a new model of adaptive water-right administration for Great Salt Lake.

a53322 FFSL Sovereign Lands Right

Permanent lake-right dedication

The FFSL Sovereign Lands Right permanently converts an industrial Great Salt Lake water right into an environmental water right dedicated entirely to the preservation and enhancement of Great Salt Lake. Unlike the adaptive industrial agreements with Compass Minerals and other mineral operators, this order contains no continuing industrial diversion. The entire right is transferred to the Utah Division of Forestry, Fire and State Lands (FFSL) for in situ use within Great Salt Lake.

This application was filed pursuant to the September 1, 2024 Voluntary Agreement between Compass Minerals and FFSL and replaces the earlier change application (a41026a). The State Engineer approved the dedication as approximately 167 cfs (120,908 acre-feet annually) of Great Salt Lake water for environmental purposes.

Sources

Utah Division of Water Rights — Permanent Change Application 13-4130 (a53322) and State Engineer Order.

Order-authorized quantities

Component                               Volume
-----------------------------------------------
Dedicated Lake Right                    120,908 af
Flow Right                              167.0 cfs
Project Type                 Permanent Lake Dedication

Interpretation

• Complete dedication of an existing Great Salt Lake water right.
• No continuing industrial use.
• Water remains in Great Salt Lake for environmental purposes.
• Replaces the previous FFSL application (a41026a).

Variability drivers:

• natural lake evaporation
• future Great Salt Lake Distribution Management Plan
• lake elevation

Ledger translation

Because the system:

• is an existing Great Salt Lake water right,
• creates no additional upstream inflow,
• leaves water in Great Salt Lake,

the accounting identity becomes:

Maximum Legal Dedication
          ≠
Incremental Lake Benefit

Incremental Benefit =
Historical Withdrawal Avoided

What is bankable

The order permanently dedicates a maximum annual in-situ diversion of 120,908 acre-feet to Great Salt Lake enhancement. That legal quantity is not automatically equivalent to 120,908 acre-feet of incremental lake benefit.

The bankable benefit is the industrial withdrawal that would reasonably have occurred without the donation and permanent change. The order states that the right had historically been used for mineral rinsing, pumping, pond operations, and mineral-salt extraction, but it does not provide historical diversion records or establish a representative annual withdrawal baseline.

Accordingly:

• Maximum legal dedication: 120.908 kaf/year
• Maximum possible avoided withdrawal: 120.908 kaf/year
• Representative annual bankable benefit: not quantified from the order alone

Historical metered withdrawals, operational records, or an independently supported counterfactual industrial-demand baseline would be needed to calculate a defensible annual bankable amount.

What is NOT fully bankable

• The full 120.908 kaf legal right cannot be counted automatically as incremental lake benefit.
• The order does not document historical annual industrial withdrawals.
• The order does not establish how much water Compass Minerals would have withdrawn without the donation.
• The right is subject to prior rights and the future Great Salt Lake Distribution Management Plan.
• The project creates no new watershed inflow, although it may prevent direct withdrawals from existing lake storage.

Bankability assessment

actor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    Low
Durability                     High

• Proximity: The protected water is located directly within Great Salt Lake.
• Timing: Any avoided industrial withdrawal produces an immediate lake-storage benefit.
• Control: FFSL holds the permanent change approval for Great Salt Lake enhancement, and the prior application is withdrawn and superseded.
• Measurement: The order requires measuring devices and annual reporting, but it does not provide the historical-withdrawal baseline needed to quantify the incremental benefit of the donation.
• Durability: The change application is permanent, subject to prior rights, completion requirements, and the future Great Salt Lake Distribution Management Plan.

Durability under wet and dry regimes

Wet / higher-lake years

• The permanent legal dedication remains in effect.
• Former industrial uses are no longer authorized under the right.
• Incremental lake benefit equals the industrial withdrawal that would otherwise have occurred.

Implication:

Wet-regime bankable benefit is not quantified because the order does not establish the required counterfactual industrial-withdrawal baseline.

Dry / lower-lake years

• The permanent legal dedication continues during stressed lake conditions.
• Preventing a potential industrial withdrawal may be particularly valuable when lake levels are low.
• The annual benefit still depends on the withdrawal that would otherwise have occurred.

Implication:

Dry-regime bankable benefit is not quantified pending a defensible historical or operational withdrawal baseline.

Critical distinction

This project protects:

• an existing Great Salt Lake water right.

It does NOT create:

• new watershed inflow,
• reduced upstream depletion,
• additional basin yield.

From a legal perspective, this is one of the largest dedicated water rights in the portfolio.

From a hydrologic accounting perspective, it primarily protects existing lake water rather than creating new water for Great Salt Lake.

Bottom line

The FFSL Sovereign Lands Right represents one of the largest permanent legal dedications in Utah’s Great Salt Lake restoration portfolio. The State Engineer approved 120,908 acre-feet annually for in-situ Great Salt Lake enhancement and eliminated the right’s former industrial uses. The legal dedication is clear, but its incremental hydrologic benefit is not established by the order alone. That benefit equals the industrial withdrawal that would otherwise have occurred—not necessarily the full legal right and not necessarily zero. Historical diversion records or another supported counterfactual baseline are required before assigning a representative annual bankable amount.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
a53322                 |   120.908     |       -        |       -

FFSL Sovereign Lands is a high-confidence legal protection project rather than a long-term accretion project.

• Permanently protects an existing Great Salt Lake water right.
• Creates no new watershed inflow.
• Demonstrates the important distinction between legal dedication and durable hydrologic benefit, a central theme of the Water Ledger analysis.

The FFSL Sovereign Lands Right illustrates that the largest legal dedication in the portfolio is not necessarily the largest hydrologic benefit. Protecting water already within Great Salt Lake strengthens environmental stewardship, but durable lake recovery ultimately depends on reducing upstream consumptive depletion rather than simply changing the ownership or purpose of existing lake water.

f53436 Huntsville Abbey Farm

Upstream agricultural fallowing

The Huntsville Abbey Farm project temporarily converts irrigation, domestic, and stockwatering water rights in the upper Weber River basin into dedicated environmental water for Great Salt Lake. Unlike permanent change applications, this project is approved as a ten-year fixed-time change application, allowing historical agricultural water use to be redirected for environmental purposes while preserving the underlying water rights.

Rather than crediting the full diversion, the State Engineer determined that only the historical depletion associated with the retired agricultural uses may be accounted for as dedicated Great Salt Lake water. The order establishes a maximum annual diversion of 635 acre-feet and a maximum annual depletion of 357.10 acre-feet. Actual delivery credited to Great Salt Lake is limited to the prorated depletion component of water that is diverted, measured, and released by the applicants. Thus, 357.10 acre-feet is an annual ceiling rather than an automatic annual delivery.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 35-455 (f53436) and State Engineer Order.

Order-authorized quantities and depletion estimates (acre-feet)

Component                              Volume (af)
---------------------------------------------------
Maximum annual diversion                  635.00
Report 145 depletion estimate             386.23
State Engineer depletion estimate         357.39
Order-authorized depletion ceiling        357.10
  Irrigation-season component             349.85
  Non-irrigation-season component           7.25

Note: The approximately 340 af/year figure is the rounded 2015–2024 OpenET estimate of actual irrigation depletion, while 357 af/year is the controlling historical-depletion quantity adopted by the State Engineer for project accounting. The difference reflects distinct estimation and administrative accounting bases rather than an additional 17 af of separately identified depletion.

Interpretation

• Temporary agricultural fallowing project.
• State accounting based on historical depletion rather than diversion.
• Water delivered through either:
• Willard Bay exchange releases, or
• direct Weber/Ogden River delivery.
• Annual accounting based upon measured releases.

Variability drivers:

• annual irrigation operations
• measured diversion
• Weber Basin exchange operations
• hydrology

Ledger translation

Because the system:

• retires historical agricultural depletion,
• measures actual diversion,
• credits only depletion,

the accounting identity becomes:

Diversion ≠ Lake Accretion

Credited Delivery =
Prorated Depletion Component of Water
Actually Diverted, Measured, and Released

Annual Maximum = 357.10 acre-feet

What is bankable

The bankable component is the prorated historical-depletion component of water actually diverted from Bennett Creek and Upper Bennett Spring, measured at the farm’s discharge structures, and released through an approved delivery alternative.

The State Engineer authorizes two alternatives:

• a measured, depletion-equivalent release from Willard Bay into the Willard Spur of Bear River Bay; or
• a measured delivery shepherded through the Ogden and Weber Rivers to Great Salt Lake through the Ogden Bay Waterfowl Management Area.

The credited quantity cannot exceed 357.10 acre-feet annually. Actual annual credit depends on the amount diverted, measured, released, and reported—not merely on the existence of the 635-acre-foot diversion authorization.

The current Water Ledger estimates of approximately 0.30 kaf in a constrained year and up to 0.357 kaf in a fully realized year are reasonable planning scenarios, but they are not quantities guaranteed by the order.

What is NOT fully bankable

• Diversion volume (635 af) is not equivalent to lake accretion.
• Annual deliveries depend upon measured operations.
• Project expires after ten years unless renewed.
• Hydrologic conditions influence annual realization.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Medium
Timing                         Medium
Control                        Medium
Measurement                    High
Durability                     Medium

• Proximity: The historical uses are in the upper Weber basin, although the preferred exchange release occurs much closer to Great Salt Lake at Willard Bay.
• Timing: The applicants select one delivery alternative annually, and realization depends on the year’s measured diversion and release operations.
• Control: The order prohibits the historical irrigation, domestic, and stockwatering uses during the approved term and places delivery under the Weber River Commissioner, but implementation depends on coordinated applicants, agreements, and either exchange or downstream delivery operations.
• Measurement: Real-time meters are required at the Bennett Creek discharge structures. Willard Bay releases must be measured and reported, while direct river deliveries are measured and accounted for at designated USGS gages.
• Durability: The fixed-time approval expires March 31, 2036, unless extended, and remains valid only while FFSL or DWR remains an interested party under the agreement and application.

Durability under wet and dry regimes

Wet / high flow years

• A larger measured quantity may be available for diversion and release.
• The preferred Willard Bay exchange may provide a direct, measurable delivery to the Willard Spur.
• Credited delivery may approach, but cannot exceed, 357.10 acre-feet.

Implication:

The project may realize nearly its full authorized depletion-equivalent benefit.

Dry / low flow years

• Credited delivery declines if less water is diverted, measured, and released.
• If the preferred Willard Bay alternative is unavailable, the applicants may use the approved Ogden-Weber River delivery alternative.
• The order does not establish a guaranteed minimum annual delivery.

Implication:

The benefit remains measurable, but its annual quantity must be determined from actual operations.

Critical distinction

This project is grounded in reducing historical agricultural depletion.

It does NOT create:

• new watershed yield,
• permanent water rights,
• perpetual environmental dedication.

Unlike many earlier change applications, the State Engineer explicitly distinguishes diversion from depletion and credits only the latter—a methodology that closely parallels the Water Ledger approach.

Bottom line

The Huntsville Abbey Farm project represents one of the most technically rigorous environmental water transactions approved to date. Rather than assuming that all diverted water benefits Great Salt Lake, the State Engineer independently quantified historical consumptive use and limited accounting to approximately 357 acre-feet of annual depletion. Although the authorization is temporary and subject to annual operational conditions, it provides a highly credible example of depletion-based accounting and demonstrates how future Great Salt Lake conservation projects can be evaluated using measurable hydrologic benefit rather than diversion volume alone.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |     (kaf)     |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f53436                 |     0.635     |     0.300      |     0.357

Huntsville Abbey Farm is a high-confidence, depletion-based agricultural conservation project.

• State accounting already recognizes historical depletion rather than diversion.
• Strong agreement between State Engineer methodology and the Water Ledger framework.
• Temporary authorization limits long-term durability, but the hydrologic accounting represents one of the strongest examples in the current Great Salt Lake portfolio.

The Huntsville Abbey Farm order is significant because it marks a shift from accounting for water diverted to accounting for water depleted. By limiting environmental credit to measured historical consumptive use, the State Engineer adopted a hydrologic accounting approach that closely aligns with the Water Ledger principle that durable Great Salt Lake accretion is created by reducing depletion—not simply by redirecting diversion.

a53468 Morton Salt

Industrial lake-withdrawal reduction

Permanent Change Application a53468 establishes a permanent Great Salt Lake enhancement agreement between Morton Salt, Inc. and the Utah Division of Forestry, Fire and State Lands (FFSL). The order allows Morton Salt to continue producing salt while adding Great Salt Lake enhancement as a beneficial use of the same water rights. Under the agreement, allowable industrial withdrawals decrease as the South Arm elevation declines, with the unused portion of the authorized diversion remaining in Great Salt Lake for environmental purposes. At elevations below 4,190 feet, only operational maintenance diversions are permitted, and any resulting depletion must be fully mitigated using water rights above the Great Salt Lake meander line.

Unlike upstream conservation projects, this application does not reduce watershed depletion or create additional basin inflow. Instead, it limits future industrial withdrawals directly from Great Salt Lake through an elevation-dependent operating schedule established by the State Engineer.

Sources

Utah Division of Water Rights — Permanent Change Application 15-414 (a53468)

Order-authorized elevation schedule (acre-feet)

Interpretation

• Permanent industrial water-right modification.
• Great Salt Lake enhancement added as a beneficial use.
• Industrial withdrawals decrease automatically as lake elevation declines.
• Below 4,190 feet, any remaining operational depletion must be fully mitigated.
• Environmental allocation is determined by the State Engineer’s elevation schedule.

Variability drivers:

• South Arm elevation
• annual salt production
• industrial demand

Ledger translation

Because the system:

• withdraws water directly from Great Salt Lake,
• allocates water between industrial and environmental use,
• adjusts allowable diversion according to lake elevation,

the accounting identity becomes:

Potential Environmental Allocation
=
Maximum Authorized Diversion
−
Allowed Industrial Diversion

For GSL Accounting, however, the objective is not to estimate the maximum legal environmental allocation. The objective is to estimate the representative annual increase in lake storage expected from reduced industrial withdrawals under wet and dry hydrologic regimes.

Constraints

• The State Engineer’s order establishes maximum allowable diversions rather than expected annual withdrawals.
• Actual industrial demand may be lower than the authorized diversion.
• South Arm elevation—and therefore the applicable diversion limit—depends on basin hydrology and future lake-management decisions.
• At elevations below 4,190 feet, the order requires any operational depletion to be fully mitigated using water rights from above the Great Salt Lake meander line.
• The order creates a legal environmental allocation but does not establish the annual volume of additional water retained in Great Salt Lake.

What is bankable

The bankable component is the portion of the 32,578 acre-foot maximum annual diversion assigned to FFSL for in-situ Great Salt Lake enhancement under the applicable elevation range.

The order establishes the following quantities:

• 0 acre-feet at or above elevation 4,198.00 feet;
• 16,289 acre-feet from 4,197.99 to 4,195.00 feet;
• 22,805 acre-feet from 4,194.99 to 4,193.00 feet; and
• 26,063 acre-feet from 4,192.99 to 4,190.01 feet.

At or below elevation 4,190.00 feet, Morton Salt may divert only for operational maintenance, and all resulting depletion must be mitigated using water rights from above the Great Salt Lake meander line.

Because these quantities are established directly by the State Engineer’s order, no separate assumed 25 kaf dry or 10 kaf wet estimate is necessary. The applicable annual legal allocation should instead be determined from the June 15 South Arm elevation, actual metered diversions, and any required mitigation.

What is NOT fully bankable

• The full 32.6 kaf water right remains legally authorized.
• Elevation-based allocations represent maximum environmental availability rather than expected annual savings.
• The project does not create additional watershed inflow or reduce upstream consumptive use.
• Annual benefit depends upon actual industrial operations and the applicable elevation threshold.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Very high
Timing                         High
Control                        High
Measurement                    High
Durability                     High

• Proximity: The benefit consists of reduced withdrawals directly from Great Salt Lake.
• Timing: The applicable annual diversion limit is determined from the June 15 South Arm elevation, producing an immediate operating constraint.
• Control: The State Engineer’s order imposes binding elevation-based limits and requires mitigation of depletion from maintenance use at or below 4,190 feet.
• Measurement: FFSL must report the June 15 USGS gage elevation, while the applicants must meter all diversions with totalizing recording devices and report them annually.
• Durability: The change application is permanent, although it remains valid only while FFSL participates under the agreement and application and will be subject to the Great Salt Lake Distribution Management Plan when adopted.

Durability under wet and dry regimes

Wet / higher-lake years

• At or above 4,198 feet, Morton Salt may divert the full 32.578 kaf.
• The order assigns no mandatory in-situ environmental quantity at or above that elevation.
• Between 4,197.99 and 4,195.00 feet, the order assigns 16.289 kaf to FFSL.

Implication:

For the representative wet regime at or above 4,198 feet, bankable legal protection is 0.000 kaf/year.

Dry / lower-lake years

• Between 4,194.99 and 4,193.00 feet, the FFSL allocation is 22.805 kaf.
• Between 4,192.99 and 4,190.01 feet, the allocation increases to 26.063 kaf.
• At or below 4,190 feet, Morton Salt is limited to operational-maintenance diversions and must mitigate the resulting depletion.

Implication:

The representative dry-regime bankable quantity is 26.063 kaf/year, corresponding to the 4,192.99–4,190.01-foot elevation band.

Critical distinction

The project reduces:

• future industrial withdrawals from Great Salt Lake.

It does NOT create:

• new watershed inflow,
• additional basin yield,
• upstream depletion reductions.

Unlike irrigation conservation projects, benefits result from limiting direct lake withdrawals rather than reducing historical consumptive use.

Bottom line

Morton Salt a53468 establishes a permanent industrial-conservation agreement under which allowable lake withdrawals decline as Great Salt Lake elevation falls. The State Engineer’s order assigns an exact in-situ environmental quantity to FFSL in each elevation band, ranging from zero at or above 4,198 feet to 26,063 acre-feet between 4,192.99 and 4,190.01 feet. At or below 4,190 feet, Morton Salt is limited to operational-maintenance diversions and must mitigate all resulting depletion with water rights from above the meander line. The annual benefit should therefore be reported from the applicable elevation band, metered industrial diversion, and required mitigation—not from a single assumed representative percentage.

Initiative           | Order maximum | Bankable (Dry) | Bankable (Wet)
                     |    (kaf)      |     (kaf)      |     (kaf)
----------------------------------------------------------------------
a53468               |    32.578     |     26.063     |      0.000

Morton Salt is a high-confidence industrial conservation initiative.

• Permanent reduction in potential industrial lake withdrawals.
• Benefits increase as lake elevation declines.
• Representative annual benefit is substantially smaller than the maximum legal allocation because it reflects expected operating conditions rather than theoretical capacity.

The State Engineer’s order establishes the legal framework for environmental protection. GSL Accounting estimates the representative annual lake accretion expected under that framework.

f53574 Kennecott Replacement Application

Industrial water conversion

The Kennecott Replacement Application changes a portion of Water Right 59-3518 from historical mining, milling, smelting, and refining uses to environmental purposes benefiting Great Salt Lake. It authorizes up to 18,386.77 acre-feet annually for wildlife propagation, recreation, fishing, and preservation or enhancement of Great Salt Lake’s natural aquatic environment. The approval replaces and supersedes Fixed-Time Change Application f46437, which was withdrawn. Although the order’s page headings identify a permanent change application, its analysis and operative conditions characterize the approval as fixed-time. The approval expires November 30, 2035, unless an extension is requested and approved.

The State Engineer assumes, in the absence of contrary information, that the historical milling and refining uses were fully consumptive. Nevertheless, the annual lake benefit is not automatically 18,386.77 acre-feet. It equals the water actually available under the right, diverted through the approved system, metered, delivered for the environmental uses, and reported after accounting for any concurrent diversion under Exchange Application 59-5861 (E33).

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-3518 (f53574) and State Engineer Order.

Order-authorized quantities and operating constraints

Component                              Quantity
---------------------------------------------------
Maximum annual diversion             18,386.77 af
Maximum flow rate                         30.0 cfs
NJIC seasonal diversion limit             10.0 cfs
Authorization expires              Nov. 30, 2035
Historical industrial use       Assumed consumptive

Interpretation

• Industrial water converted to environmental use.
• historical industrial depletion assumed fully consumptive.
• Environmental use replaces industrial use rather than creating new water.
• Approval is temporary and expires unless extended.

Variability drivers:

• annual diversion availability
• commissioner distribution
• hydrologic conditions
• future renewal beyond the ten-year approval

Ledger translation

Because the system:

• replaces industrial consumptive use,
• delivers water to Great Salt Lake,
• remains subject to fixed-time authorization,

the accounting identity is:

Maximum Authorization
          ≠
Annual Lake Benefit

Annual Bankable Benefit =
Water Actually Diverted, Metered,
Delivered, and Reported for
Environmental Use

What is bankable

The bankable component is the water actually diverted, metered, and delivered under f53574 for the approved Great Salt Lake environmental uses.

The State Engineer permits a maximum annual diversion of 18,386.77 acre-feet and assumes that the historical milling and refining uses were fully consumptive. The applicants must meter all diversions, report them annually to the Utah Lake and Lower Jordan River Commissioners, and separately track water diverted under Exchange Application 59-5861 (E33).

Delivery remains subject to prior rights on the Lower Jordan River. The applicable priority differs by season:

• November 1 through April 30: January 22, 1936 priority;
• May 1 through October 31: July 26, 1938 priority.

Accordingly, 18.38677 kaf is the annual ceiling, not a guaranteed or representative annual benefit. The order provides no historical delivery record supporting the current 12 kaf dry and 16 kaf wet estimates. Until operating data are available, representative dry- and wet-regime quantities should be shown as not quantified.

What is NOT fully bankable

• Authorization expires after ten years unless extended.
• Annual deliveries remain subject to river commissioner administration.
• Diversions cannot exceed historical depletion limits.
• Long-term durability depends upon renewal or permanent conversion.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        High
Measurement                    High
Durability                     Medium

• Proximity: Approved delivery points and uses are in the Lower Jordan River–Great Salt Lake system, close to the lake.
• Timing: Delivery can occur year-round, but availability is subject to prior rights, seasonal priorities, river administration, and coordination with the E33 exchange.
• Control: Historical industrial use under the changed portion must cease, diversions are commissioner-administered, and annual advance notice is required for use of the NJIC diversion.
• Measurement: All diversions must be metered with totalizing recording devices, reported annually, and reconciled with diversions under E33.
• Durability: The approval is fixed-time and expires November 30, 2035, unless extended.

Durability under wet and dry regimes

Wet / high-flow years

• More water may remain available after senior Lower Jordan River rights are satisfied.
• Actual environmental delivery could approach the 18.387 kaf annual ceiling.
• The order does not establish that this maximum delivery occurs routinely.

Implication:

Wet-regime benefit is not quantified and must be determined from metered and reported environmental delivery.

Dry / low-flow years

• Prior-right administration may materially reduce water available for environmental delivery.
• Industrial, exchange, and river-operating conditions may affect realized delivery.
• The order establishes no guaranteed minimum environmental quantity.

Implication:

Dry-regime benefit is not quantified and must be determined from metered and reported environmental delivery.

Critical distinction

The project removes:

• historical industrial consumptive use.

It does NOT create:

• new basin yield,
• additional watershed inflow.

Unlike agricultural conservation projects, this initiative reallocates an existing industrial water use to environmental purposes while preserving historical depletion limits established under the water right.

Bottom line

The Kennecott Replacement Application provides a well-controlled mechanism for converting water historically authorized for fully consumptive industrial uses to Great Salt Lake environmental purposes. Its annual legal ceiling is 18,386.77 acre-feet, but its realized benefit depends on water availability, prior-right administration, actual measured delivery, and reconciliation with the E33 exchange. The project therefore has high ex-post bankability—delivered water can be measured and verified—but no defensible representative dry- or wet-year quantity can yet be derived from the order alone. Its principal long-term limitation is that the fixed-time approval expires November 30, 2035, unless extended.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f53574                 |    18.387     |       -        |       -

Kennecott Replacement is a high-bankability industrial conversion project.

• Replaces historical industrial consumptive use.
• Delivers water directly to Great Salt Lake environmental purposes.
• Strong hydrologic benefit, but long-term durability depends on extension or permanent conversion.

Unlike the withdrawn predecessor application, f53574 becomes the operative authorization for this water right. It demonstrates that industrial water can be redirected to Great Salt Lake with relatively high hydrologic confidence, although its long-term bankability ultimately depends on whether the fixed-time authorization is renewed or made permanent.

f53788 Utah & Salt Lake Canal Company

Shareholder-based agricultural fallowing

The Utah & Salt Lake Canal Company (U&SLCCo.) project establishes a voluntary shareholder program allowing participating irrigation shareholders to temporarily dedicate their water to Great Salt Lake while preserving the underlying water rights. Rather than dedicating the canal’s entire diversion right, individual shareholders annually elect to remove irrigated acreage from production, with the associated historical consumptive use dedicated for environmental purposes on Great Salt Lake sovereign lands.

The State Engineer expressly distinguishes diversion from depletion. Although the maximum annual diversion is 45,673.3 acre-feet, environmental accounting is based on the calculated historical depletion associated with the shares and mapped acreage actually enrolled each year. The maximum State Engineer depletion estimate is 22,734.02 acre-feet. Water above the applicable depletion quantity remains available to satisfy existing Lower Jordan River rights.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 59-3499 (f53788) and State Engineer Order.

Order-authorized quantities and participation limits

Interpretation

• Voluntary shareholder participation.
• Annual dedication based upon irrigated acreage removed from production.
• State Engineer independently estimates historical depletion.
• Return flows remain available for downstream water users.
• Annual accounting based upon actual participating shareholders.

Variability drivers:

• shareholder participation
• annual irrigated acreage
• crop evapotranspiration
• hydrologic conditions
• commissioner administration

Ledger translation

Because the system:

• retires irrigated acreage,
• measures historical depletion,
• preserves downstream return flows,

the accounting identity becomes:

Maximum Diversion
          ≠
Annual Lake Accretion

Annual Bankable Benefit =
Reported Depletion Associated with
Shares and Acreage Enrolled That Year

Annual Maximum = 22,734.02 acre-feet

What is bankable

The bankable component is the historical depletion calculated for the shares and mapped irrigated acreage enrolled in the program each year.

For every year the application is exercised, the company must report:

• each participating shareholder and the number of shares dedicated;
• diversion and depletion totals for each shareholder;
• total enrolled shares and corresponding diversion and depletion;
• mapped parcels removed from irrigation; and
• any dedicated water spilled back to the Jordan River.

Irrigation depletion is calculated using the State Engineer’s project-specific rate of 29.81 inches per acre per year. Annual diversion cannot exceed 45,673.3 acre-feet, and annual depletion credit cannot exceed 22,734.02 acre-feet.

The order does not establish representative dry- and wet-year participation rates. Consequently, the existing 18 kaf dry estimate is an unsupported planning assumption, while the 25 kaf wet estimate exceeds the legal depletion ceiling. Annual bankable benefit should instead equal the depletion reported for that year’s participating shares and acreage.

What is NOT fully bankable

• Full diversion volume (45.67 kaf) is not lake accretion.
• Annual participation varies by shareholder.
• Return flows remain available to downstream users.
• The authorization expires after ten years unless extended.
• Actual annual accounting depends upon participating acreage.

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      High
Timing                         Medium
Control                        High
Measurement                    High
Durability                     Medium

• Proximity: Water is administered through the Lower Jordan River system near Great Salt Lake.
• Timing: Shareholders elect participation annually, with enrollment, depletion calculations, and parcel maps reported before each irrigation season.
• Control: Irrigation use on enrolled parcels must cease, canal diversion must be reduced by the enrolled amount, and operations are directed by the Utah Lake/Jordan River and Lower Jordan River Commissioners.
• Measurement: Shareholder-level diversion and depletion are reported annually, participating acreage is mapped, and water spilled back to the Jordan River must be measured and reported.
• Durability: The authorization is fixed-time and expires May 31, 2036, unless extended; participation also varies annually.

Durability under wet and dry regimes

Wet / high-flow years

• More shareholders and irrigated acreage may be enrolled.
• Greater participation may increase the calculated depletion dedicated to Great Salt Lake.
• Annual bankable credit cannot exceed the 22.734 kaf legal depletion ceiling.

Implication:

Wet-regime benefit is not predetermined; it equals the reported depletion associated with that year’s enrolled shares and acreage.

Dry / low-flow years

• Fewer shares or acres may be enrolled.
• Reduced participation produces a smaller calculated depletion credit.
• The order establishes no guaranteed minimum participation or environmental benefit.

Implication:

Dry-regime benefit is not predetermined; it equals the reported depletion associated with that year’s enrolled shares and acreage.

Critical distinction

The project removes:

• historical agricultural consumptive use.

It does NOT create:

• new basin yield,
• additional watershed inflow.

Most importantly, the State Engineer explicitly rejects diversion as the accounting metric. Instead, annual environmental credit is based upon independently calculated historical depletion associated with participating irrigated acreage. This methodology closely mirrors the central accounting principle of the Water Ledger.

Bottom line

The Utah & Salt Lake Canal Company project establishes one of the portfolio’s strongest prospective accounting systems. It requires annual shareholder enrollment, parcel mapping, shareholder-level diversion and depletion calculations, cessation of irrigation on enrolled acreage, protection of historical return flows, and commissioner oversight. Its annual benefit is therefore verifiable once the participation report is filed. However, neither a recurring 18 kaf dry benefit nor a 25 kaf wet benefit is supported by the order, and 25 kaf exceeds the 22,734.02 acre-foot legal depletion ceiling. The appropriate annual bankable quantity is the reported depletion associated with that year’s enrolled shares and acreage.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f53788                 |    45.673     |       -        |       -

Note: Annual bankable benefit equals reported participating-share depletion and may not exceed 22.734 kaf.

Utah & Salt Lake Canal Company is a high-bankability agricultural conservation project.

• One of the strongest depletion-based accounting frameworks in the portfolio.
• Annual accounting tied to actual participating shareholders.
• Protects downstream return flows while dedicating measured consumptive use to Great Salt Lake.

The Utah & Salt Lake Canal Company order may represent the clearest example to date of the transition from diversion accounting to depletion accounting. By independently estimating historical consumptive use and requiring annual shareholder-level reporting, the State Engineer adopted an accounting framework that closely aligns with the Water Ledger principle that durable Great Salt Lake recovery is achieved by reducing consumptive depletion—not simply by redirecting diverted water.

f53110 Ontario Drain Tunnel

Imported water dedicated to Great Salt Lake

The Ontario Drain Tunnel project dedicates imported water conveyed from the Ontario Mine Tunnel to Great Salt Lake through the Jordan River system. Unlike agricultural conservation projects that create environmental water by reducing historical consumptive use, this project redirects an existing imported supply for public use, wildlife management, fisheries, recreation, and sovereign lands associated with Great Salt Lake. The approved routing allows water to move through the Provo River, Jordan River, Surplus Canal, Goggin Drain, and associated Farmington Bay conveyance structures depending upon operational conditions.

Because the water originates outside the Utah Lake/Jordan River basin, the State Engineer explicitly recognizes that it is fully consumptive within the basin where it is imported. As a result, there is no historical irrigation depletion to reconstruct and no downstream return-flow obligation comparable to agricultural projects. The principal accounting uncertainty instead becomes annual diversion operations and transmission losses through the delivery system.

Sources

Utah Division of Water Rights — Fixed-Time Change Application 55-11103 (f53110) and State Engineer Order.

Order-authorized rate and annualized equivalent

Component                              Quantity
---------------------------------------------------
Maximum diversion rate                 9.636 cfs
Annualized gross maximum*              6.977 kaf
Credited annual delivery          Metered, net of loss
Water source               Ontario Drain Tunnel
Authorization expires              Feb. 28, 2036

Interpretation

• Imported water supply.
• No historical agricultural depletion.
• No irrigation return-flow reconstruction.
• Metered annual diversion.
• Multiple approved routing alternatives to Great Salt Lake.

Variability drivers:

• imported water availability
• transmission losses
• commissioner operations
• routing decisions
• hydrologic conditions

Ledger translation

Because the system:

• imports water from outside the basin,
• directly routes water toward Great Salt Lake,
• measures actual diversion,

the accounting identity becomes:

Maximum Diversion Rate
          ≠
Annual Lake Benefit

Annual Bankable Benefit =
Measured Ontario Tunnel Water
Released for Environmental Use
− Commissioner-Assessed Losses

What is bankable

The bankable component is Ontario Drain Tunnel water actually diverted, measured, released into the approved conveyance system, and credited after transmission losses assessed by the Provo River Commissioner.

The order authorizes a maximum year-round diversion rate of 9.636 cfs. Continuous diversion at that rate for 365 days would equal approximately 6,977 acre-feet, but the order does not authorize or guarantee a fixed annual acre-foot quantity.

Because the source is imported into the Utah Lake/Jordan River drainage, the State Engineer considers it fully consumptive within the receiving basin. No historical agricultural-depletion reconstruction is required. Nevertheless, annual benefit depends on:

• actual Ontario Drain Tunnel flow;
• the quantity diverted and released;
• commissioner-assessed transmission losses;
• reservoir and conveyance operations; and
• routing through the Provo River, Jordan River, Surplus Canal, and Farmington Bay delivery structures.

The existing 5.0 kaf dry and 6.8 kaf wet figures are not derived in the order. They should be replaced by actual annual measured delivery records when available.

What is NOT fully bankable

• Annual deliveries vary.
• Transmission losses occur through the Provo and Jordan River systems.
• Multiple routing options create operational variability.
• Authorization is fixed-term (10 years).

Bankability assessment

Factor                         Rating
-------------------------------------------
Proximity                      Medium
Timing                         Medium
Control                        High
Measurement                    High
Durability                     Medium

• Proximity: The imported water enters through the upper Provo River system and must travel through reservoirs and the Provo–Jordan conveyance network before reaching Great Salt Lake.
• Timing: Year-round diversion is authorized, but delivery timing depends on reservoir operations, routing choices, flow conditions, and management decisions.
• Control: Historical uses must cease, diversion under related application a51924 must be reduced correspondingly, and operations are directed by the Provo River and Upper and Lower Jordan River Commissioners.
• Measurement: All Ontario Drain Tunnel diversions and Provo River releases must be measured and reported; the Provo River Commissioner assesses transmission losses, and controlling works and metering are required.
• Durability: The fixed-time approval expires February 28, 2036, unless extended.

Durability under wet and dry regimes

Wet / high-flow years

• Source flow and operating conditions may permit greater environmental delivery.
• Gross delivery could approach the 6.977 kaf annualized equivalent of the 9.636 cfs order limit.
• Credited benefit must be reduced by commissioner-assessed transmission losses.

Implication:

Wet-regime benefit is not predetermined; it equals measured, loss-adjusted environmental delivery.

Dry / low-flow years

• Source flow, reservoir operations, or routing decisions may reduce delivery.
• Commissioner-assessed losses may further reduce the credited quantity.
• The order establishes no guaranteed annual minimum delivery.

Implication:

Dry-regime benefit is not predetermined; it equals measured, loss-adjusted environmental delivery.

Critical distinction

The project contributes:

• imported water from outside the basin.

It does NOT rely upon:

• reduced agricultural depletion,
• historical consumptive-use reconstruction,
• irrigation fallowing.

Instead, the accounting focuses almost entirely on measured delivery and conveyance efficiency, making this one of the simplest projects in the portfolio from a ledger perspective. The State Engineer specifically notes that the imported water can be considered fully consumptive within the receiving basin and requires commissioner oversight to account for transmission losses and protect existing rights.

Bottom line

The Ontario Drain Tunnel project is one of the portfolio’s clearest accounting cases because its source is imported water rather than reconstructed depletion reduction. Every acre-foot of Ontario Tunnel water successfully delivered and credited after commissioner-assessed losses represents additional water within the Great Salt Lake system. The order authorizes a maximum rate of 9.636 cfs—approximately 6.977 kaf if sustained continuously for 365 days—but does not establish a fixed annual quantity. Annual bankable benefit should therefore equal measured, loss-adjusted environmental delivery.

Initiative             | Order maximum | Bankable (Dry) | Bankable (Wet)
                       |    (kaf)      |     (kaf)      |     (kaf)
------------------------------------------------------------------------
f53110                 |     6.977†    |       -        |        -

† Gross annualized reference only; not a fixed or guaranteed annual order quantity.

Ontario Drain Tunnel is a high-confidence imported water project.

• Adds water from outside the basin.
• Benefits depend on measured delivery rather than depletion accounting.
• One of the cleanest accounting cases in the dedicated water portfolio.

Unlike agricultural dedication projects, the Ontario Drain Tunnel does not create environmental water by reducing historical consumptive use. Instead, it increases Great Salt Lake inflow by redirecting an imported water supply, making actual metered delivery—rather than depletion reconstruction—the principal accounting metric.

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