Independent experts and advocates from across Utah and the country have raised a long list of concerns about the proposal to create artificial islands on Utah Lake. More than 130 researchers, managers, lawyers, and community leaders submitted six separate letters to the Army Corps of Engineers about the project. Other letters were sent to the Army Corps, but only these six were made available to Conserve Utah Valley.

On January 6th of this year, Lake Restoration Solutions (LRS)—an LLC registered in Delaware—submitted a dredging application to the Army Corps of Engineers describing the Utah Lake islands project. The application confirms that LRS plans to carry out the world’s largest dredged island development, which they describe as both a restoration and improvement project. According to their application, LRS proposes to dredge nearly 1 billion cubic yards of sediment, which they would form into 34 islands covering 18,000 acres. Of the 18,000 acres of islands, 16,000 acres would be “development islands” devoted to commercial and residential development. This would leave only 5% of the current lakebed intact and would require eight years or more of near constant dredging according to LRS’s more detailed original proposal.

Colored photograph of Utah Lake from 1898, courtesy of the Library of Congress.

The six letters bring up dozens of concerns about LRS’s application including mischaracterization of scientific research about the lake, inadequate detail about the proposed activities, and insufficient environmental and economic protections. Several of the letters ask the Army Corps to stop the proposal review until additional details about the project are made publicly available.

One of the letters—led by Utah Valley University’s former Dean of Science Sam Rushforth—points out that the application lacks a restoration plan and fails to show how the project would help the lake. Rushforth’s group writes, “While LRS claims the project is motivated by restoration, the details of how the project would actually benefit the environment are not included in the current application.” The writers list seven ways the proposed project could harm the lake and warn that the project could potentially make the lake permanently dependent on costly interventions such as water recirculators.

Another letter was authored by Brigham Young University (BYU) law professor Brigham Daniels on behalf of the local environmental group Conserve Utah Valley. Daniels describes the application as “undone, under-done, and plagiarized,” contending that the application does not meet the minimum requirements of the Army Corps. Several of the other letters made this same point, pointing out dozens of inadequacies and irregularities in the application.

Map of LRS’s proposed islands overlain by known seismic faults and clusters of springs in the lakebed. Created by BYU Geology professors Greg Carling and Josh LeMonte.

One of the letters was signed by 10 Utah-based community groups, including Deeda Seed from the Center for Biological Diversity, Dixie Heufner from the Utah Citizen’s Counsel, and Lynn DeFreitas from Friends of the Great Salt Lake. Their letter provides a detailed table comparing the application to the Army Corps’ own permit checklist. They find that the application only satisfies 8 out of 51 Army Corps requirements, concluding that “LRS has failed to satisfy these prerequisites, putting the Corps and the public on unfair footing from the outset.”

Another letter led by Ph.D. Ecologist Tara Bishop also concludes that LRS’s application is surprisingly incomplete. They write that LRS does not adequately describe “the effects of dredging, the suitability of the islands for development, or the nature of their ‘restoration’ activities.” Bishop provides a list of 36 critical questions that need to be answered before the public and the Corps can assess the permit application. These questions range from basic details about the project timeline and liability to advanced concerns about methods and scientific evidence. Additionally, Bishop points out that LRS tries to establish an “unduly narrow” project purpose that “precludes the consideration of less harmful and risky alternatives.”

Utah Lake as seen from Mount Timpanogos. Photo by Jeff Beck.

The letter with the longest list of signatories was submitted by Ben Abbott, the BYU professor currently caught up in a legal battle with LRS. Abbott’s group of 119 experts describe eight deficiencies in the project, including disregard of available lake studies, inadequate expertise, false claims of endorsements, and an unacceptable burden of economic and environmental liability for the people of Utah. They write, “we need evidence-based management and legislation to protect this unique, beautiful, and dynamic lake. Utah Lake has sustained our predecessors and ancestors for thousands of years. It is now our opportunity and responsibility to sustain Utah Lake for future generations.”

Several of the letters point out how the application conflicts with LRS’s public statements. At the Utah Lake Summit in January of this year, LRS president Jon Benson said the application was “replete with science, data, and all the research that we’ve been doing over the last couple of years.” However, the letters contest this claim, with Rushforth pointing out that the application “does not present any new water or sediment chemistry data.” At the same Summit in January, LRS lobbyist Jeff Hartley said that the application contained “over 100 pages of citations to peer-reviewed science.” Rushforth’s group analyzed the references and found that “The application cites a total of 12 peer-reviewed studies, only 4 of which were published since 1994.”

If the Corps decides that the application is complete, the project could advance into the scoping phase. This process decides what kinds of preliminary studies need to be included in the Environmental Impact Statement (EIS). If the Corps makes that decision, the scoping process will be open to the public for 30-45 days. The Corps is still accepting pre-scoping comments on the application, which can be submitted here.

 Sailboats cross Utah Lake near sunset. Photo by Derrick Thurman.

In addition to the federal permitting process, LRS’s proposal is now facing political and community resistance. Several cities in Utah County, including Provo and American Fork, passed resolutions against the island proposal, and more than 9,000 citizens have signed a petition to repeal the 2018 law that allows the state to privatize portions of the lakebed and surrounding land. Additionally, the state legislature almost unanimously passed HB240 earlier this year, which strengthens oversight of any potential land transfers.

Here is the list of the five letters, followed by the full versions below:

1. Utah Lake island application lacks restoration plan and fails to demonstrate benefits or need. Dr. Sam Rushforth (Dean Emeritus of the College of Science at Utah Valley University) and 26 other experts.
2. Expert letter of opposition to Utah Lake Restoration project. Dr. Ben Abbott (assistant professor of aquatic ecology at Brigham Young University) and 118 other experts.
3. Utah Lake Restoration Project application is incomplete and insufficient. Dr. Tara Bishop and 22 other experts.
4. Undone, under-done, and plagiarized. Dr. Brigham Daniels on behalf of Conserve Utah Valley.
5. Deficiencies, missing data, and murky scope. Deeda Seed from the Center for Biological Diversity and 9 other Utah-based environmental groups.
6. The application does not provide evidence of legitimate restoration. Rob Dubuc from FRIENDS of Great Salt Lake.