The ledger and bankability in action
Purpose
This section illustrates how the ledger framework can be applied to Great Salt Lake policy questions, including conservation, leasing, and water project proposals, through the lens of bankability: the recurring increase in Great Salt Lake inflow or retained storage that can reasonably be attributed to an action.
Types of Policy Actions This Framework Evaluates
This page applies the bankability framework to four main categories of policy action:
Conservation — reducing consumptive use within a water right system (M&I outdoor, agricultural depletion savings). The underlying right remains; only the saved portion changes.
Voluntary leasing and donation — temporarily transferring use of all or part of a water right or its use, or permanently transferring a water right or its use to an environmental purpose, so that water is allowed to flow toward the lake rather than being diverted.
Project-based actions — infrastructure or operational changes that alter routing, storage, delivery pathways, or timing within the system.
Shepherding — administratively managing existing flows through the river corridors and canals toward the lake, typically by coordinating or acquiring seasonal use of water rights so that water remains in or returned to the channel and is routed to the lake rather than being depleted and lost from the basin. Shepherding does not retire the underlying right and is generally a time-limited arrangement. Its bankable benefit depends critically on Zone 2 conditions at the time of delivery: in wet years when the wetland transition zone is saturated, shepherded water passes through to the open lake; in drought years, it is largely absorbed by Zone 2 recharge and managed refuge consumption before the balance reaches open lake water. For detailed treatment of shepherding bankability by basin, see the FAQ section on Zone 2 dynamics and the wetland recharge threshold and habitat needs.
These categories differ in durability, routing, and bankability. The reference cases below illustrate how the framework distinguishes among them.
Example Analyses
The examples below are methodological illustrations. They apply the GSL Accounting framework to documented transactions and proposals to show how the bankability analysis works in practice. They are not determinations regarding the legal validity, administrative status, or regulatory compliance of any specific water right, change application, or demand reduction program. All values are derived from publicly available State of Utah records, presented here for analytical purposes only.
These examples illustrate accounting structure and physical delivery concepts rather than predict exact project outcomes. Actual lake response depends on hydrologic conditions, operations, and routing. The reported values may be affected by measurement assumptions.
Taken together, these examples illustrate that bankability is not a characteristic of conservation (demand reduction) alone, but also of the interaction between legal authority, hydrology, routing, and measurement. Projects that save identical quantities of water can produce very different Great Salt Lake benefits, depending on where they occur within the system and how the conserved water is delivered. The ledger provides a consistent framework for evaluating those differences.
For the complete order-by-order accounting of all 25 water rights currently tracked in the State’s Distribution Accounting Tool (DAT), including 24 active orders and one withdrawn application, see the Dedicated Water Reconciliation page. It provides the full accounting identities, wet- and dry-regime treatment, quantified and unquantified benefits, and reconciliation to the DAT’s cumulative balance.
Great Salt Lake Dedicated Water Reconciliationf53436 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 7.25Note: 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-feetWhat 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 | 0.357Huntsville 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.
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 11,887Interpretation
- 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 DepletionThe 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 | 9.000North 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.
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 5,757The 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 DeliveryWhat 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 | 4.000Welby 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.
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 DiversionFor 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 | 14.000Compass 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.
What These Cases Demonstrate
Across all examples, the same pattern holds:
- Water closest to the lake is most reliable
- Water that reduces depletion is more valuable than water that shifts timing
- Large upstream numbers are often reduced before reaching the lake due to hydrologic factors
Surviving bankable volume benefits the lake.
Using This Framework
The bankability framework is designed to be applied in a structured, repeatable way to evaluate specific actions, programs, and proposals within the Great Salt Lake system. The same definitions—depletion, delivery, timing, and measurement at the lake—are used regardless of the source of water or type of intervention. This allows different initiatives to be evaluated on a comparable basis, using consistent physical and accounting constraints rather than program-level assumptions.
Any proposal can be expressed in this framework by translating its reported or order-authorized quantity into its bankable component—the recurring increase in lake inflow or retained storage that can reasonably be attributed to the action. This requires explicitly accounting for consumptive use, return flows, routing losses, timing constraints, direct lake withdrawals, and operational variability. The objective is not to estimate theoretical savings, but to determine what physical lake benefit is durable, measurable, and supported by the available record.
When applied consistently, the framework allows different categories of action—upstream conservation, system reoperation, and near-lake reductions—to be evaluated within the same structure. The result is a comparable set of bankable volumes that can be used alongside the water ledger to assess their contribution to maintaining or increasing lake elevation.
How to Use with AI
This framework can be used with any AI assistant or large language model to evaluate bankability in a consistent and traceable way. The model should be constrained to the definitions and relationships established here, with no substitution of alternative assumptions. The goal is to ensure that all estimates of “water savings” are translated into bankable lake accretion using the same accounting logic.
Provide the following inputs:
- Initiative type (e.g., agricultural leasing, industrial reduction, system reoperation)
- Location (relative to the lake: upstream basin, mid-system, near-lake)
- Baseline diversion and depletion (kaf/year)
- Return flow characteristics (fraction and timing)
- Delivery pathway (routing distance, infrastructure, constraints)
The following prompt translates the bankability framework into a structured evaluation tool. It is intentionally detailed. Each step reflects a specific accounting constraint within the system—depletion, return flow, routing, timing, and delivery to the lake.
The objective is not to simplify analysis, but to ensure that any estimate of “water savings” is fully reconciled to bankable inflow under consistent definitions. When used correctly, the prompt produces outputs that can be directly compared across initiatives and aligned with the water ledger.
Prefer a purpose-built option? Open the Great Salt Lake Accounting Analyst (GSLAA), which is configured to apply the Great Salt Lake Accounting Standard (GSLAS) and the published definitions, datasets, and accounting relationships used throughout this site.
Prompt: Evaluate Bankability of Water Initiative
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