Here’s my letter to Utah DWQ about the US Magnesium Canal Extension Project.

You should write one too! You can use my text to help you write your own letter (but make it shorter - mine is too long).

Due by October 27th, 2022.

TO: Andrea Kilbane
Utah Division of Water Quality
akilbane@utah.gov, wqcomments@utah.gov
PO Box 144870
SLC, UT 84114-4870

October 18, 2022

Regarding:  Draft Section 401 Water Quality Certification for the US Magnesium Canal Continuation Project in Gilbert Bay of Great Salt Lake.

Dear Utah Division of Water Quality,

I’m calling on the Utah Division of Water Quality to reject US Magnesium’s proposal to extend their canals several miles further into Gilbert Bay of Great Salt Lake down to 4185 feet of elevation. 

I’m a native Utahn and a resident of Salt Lake City for the past 25 years.  I’ve spent hundreds of hours slogging through the mud at Great Salt Lake with my camera, photographing birds. Lately, I’ve been documenting more cracked mud, bleached microbialites, and dead brine shrimp than birds.

Gilbert Bay of Great Salt Lake supports one of the most unique and productive wildlife habitats anywhere on the continent. This ecosystem already hangs by a thread due to record low water. If the lake continues to drop, we face catastrophic collapse of the food chain. The State of Utah recognizes this fact and has appropriated hundreds of millions of dollars to help save this ecosystem by getting more water into the lake. Now, US Magnesium is asking permission to deliver the final blow by extending their water intake canals in Gilbert Bay so they may continue to drain the lake unabated.

Water quality in Gilbert Bay is protected under a Class 5A designation for the beneficial uses of “frequent primary and secondary contact recreation, waterfowl, shorebirds, and other water-oriented wildlife, including their necessary food chain.” The US Magnesium canal extension project will clearly and unambiguously degrade Gilbert Bay, both by lowering water levels and by altering the chemical composition of the remaining water. The project threatens to destroy a natural waterway and its world-class bird habitat, undermines the State’s own efforts to protect the lake, and jeopardizes all other beneficial uses of Gilbert Bay.

I urge the Utah Division of Water Quality to act responsibly to protect Gilbert Bay and deny US Magnesium the 401 Water Quality Certification for their canal extension project.  My reasons are further detailed below.  

1.  The waters of Gilbert Bay are protected for the purposes of “frequent primary and secondary contact recreation. Gilbert Bay is used for hunting, swimming, wading, bird watching, wildlife photography, camping, beach activities, and many types of boating. The project will make Gilbert Bay unhealthy, unsafe, and increasingly inaccessible for all types of water-based recreation.

• The project will expose people to direct contact or immersion in the deepest sediments and waters of Gilbert Bay where deadly concentrations of mercury, selenium, arsenic, and other pollutants are concentrated.

• People will be harmed by inhalation of harmful gases and dust released from newly exposed areas of lakebed during recreation.

• People harvesting waterfowl anywhere nearby may consume unsafe levels of mercury and other heavy metals as the birds forage in increasingly polluted water and sediments at the bottom of Gilbert Bay.

• The canal extension project will create new hazards related to reduced navigability of the waterway, such as stranding and failure of emergency responses.

• Two state parks and their facilities on Gilbert Bay – some of the only public recreation facilities anywhere on Great Salt Lake - will be made unusable for water-based recreation. Access to the waters of the bay will become increasingly limited and hazardous.

2.  The waters of Gilbert Bay are protected for “waterfowl, shorebirds, and other water-oriented wildlife, including their necessary food chain.”  Microbialites on the lakebed of Gilbert Bay are the basis for its highly productive food chain.  The microbialites feed brine flies and brine shrimp, which feed millions of waterbirds and their predators, including humans. The canal extension project threatens the entire ecosystem by desiccating microbialites and by degrading water quality in the remaining areas of the bay.

• Microbialites of Gilbert Bay are found almost exclusively between 4185 and 4195 feet of elevation. The proposed canal extensions down to 4185 feet will expose many of the bay’s remaining microbialites at the surface, where they will dry out, destroying their vital food production for birds.

• Salinity in Gilbert Bay is already at the upper limit of ecosystem tolerance. Microbialites, brine flies, and brine shrimp not lost to desiccation will succumb to high salinity in large sections of the bay as water pools in the lower parts of the lakebed and becomes isolated from freshwater inflows.

• Loss of the bay’s food production will devastate waterbirds, including dozens waterfowl and shorebird species. Eared Grebes and Wilson’s Phalaropes are two species that may face endangered status if their food source in Gilbert Bay is destroyed.

• By changing the concentration and surface proximity of mercury, selenium, arsenic, and other pollutants now sequestered in the deeper waters and sediments of the bay, the canal extension project will degrade water quality and impact all levels of the food chain, directly threatening wildlife and people who consume waterfowl that have foraged at the lake. 

Gilbert Bay of Great Salt Lake is already dangerously low at below 4189 feet, and every inch of water lost harms the lake’s viability and its potential to rebound in the future. The US Magnesium proposal to extend its canals to 4185 feet may buy the company a year or two of operating time, but it devastates a natural waterway and a vibrant ecosystem of hemispheric importance for birds and for people. Allowing this canal extension project to move forward would constitute gross negligence by the Utah Division of Water Quality and a violation of the public trust by the State of Utah.

If the State of Utah would like to help US Magnesium continue to access water from Great Salt Lake, the only viable option is to broker a solution that raises lake levels first so that US Magnesium’s existing canals can function as designed.

Sincerely,

Mary Anne Karren, PhD
Utahn, Wildlife Photographer
Salt Lake City, UT 84124
maryannekarren@gmail.com
https://www.maryannekarren.com/