Summary of damage that the Logan River Watershed Project will do to our community if we do not stop it NOW
Oppose spending your federal, state and local tax dollars on misguided MEGA-irrigation PROJECT
called the Logan River Watershed Project
Small changes are not going to improve this project . IT needs a top to bottom overhaul.
Two Rivers Coalition
Briefing about the damage and flaws of the Logan River Watershed Project
Logan River Watershed Draft Plan–environmental impact statement (DEIS) and Logan River System Stewardship
https://www.nrcs.usda.gov/state-offices/utah/logan-river-watershed-project
Prepared by the Two Rivers Coalition for lawmakers, decision makers and the public.
Three sections:
1) concerns about the DEIS process and content;
2) specific stewardship requests for the Logan River system; and
3) win-win proposal.
DEIS PROCESS CONCERNS
The DEIS presents an inadequate range of alternatives under NEPA
Why it matters: National Environmental Policy Act (NEPA) requires federal agencies to rigorously evaluate all reasonable alternatives. This is a legal standard, not a suggestion.
Evidence: Only two nearly identical action alternatives ($280M and $308M) and a no-action alternative. There is no alternative flood control, no partial project (e.g., flood control only), no phased approach, no conservation-first scenario.
Design-phase corrections are not a substitute for a complete DEIS
Why it matters: The DEIS comment period is the only formal opportunity for public input. Once a Record of Decision is issued, there is no legal obligation for further public engagement.
Evidence: Project sponsors and the Cache Water District board have publicly stated that concerns can be addressed in the design phase, which is incorrect as a matter of NEPA law.
The firm that drafted the DEIS is also reviewing and compiling public comments, creating a potential conflict of interest
Why it matters: JUB Engineers, the contracted author of the DEIS, stands to receive substantial engineering work if the $308 million project proceeds, creating a financial incentive that calls into question its objectivity in fairly characterizing public opposition.
Evidence: Public comments are overwhelmingly critical of the project; dismissive statements by project sponsors about those comments suggest the public record may not be compiled with the impartiality that a federal NEPA process requires.
DEIS FINANCIAL CONCERNS
The $308M cost is nearly 90% federal funds and three times the annual national PL 83-566 budget
Why it matters: This single project would consume more than three years of the entire national Watershed Protection and Flood Prevention Act budget, crowding out worthy projects nationwide. Congressional appropriators and every other state competing for PL 83-566 funds have a direct interest in how this classification is applied.
Evidence: The DEIS's preferred alternative includes 120 miles of buried pressurized irrigation pipeline whose primary purpose is to deliver irrigation water to shareholders. This is the same water that has flowed through open canals for a century and a half. The DEIS classifies much of this pipeline cost as "Flood Prevention" rather than "Agricultural Water Management," on the theory that removing irrigation water from the canals reduces the volume of water available to overflow during storm events. However, the DEIS's own economic analysis allocates 92% of the flood damage reduction benefit to the "Agricultural Distribution and Stormwater increment" and only 8% to the "Floodplain increment," confirming that flood control is largely an incidental co-benefit of the irrigation system, not its primary purpose. Classifying $137.6M of irrigation pipeline costs as Flood Prevention (100% federal cost share) rather than Agricultural Water Management (75% federal cost share) shifts approximately $34M in costs from the project sponsors to federal taxpayers. See Draft Plan–EIS, Table 6-3, p. 6-5.
The benefit-cost ratio of 1.1 would very likely fall below 1.0 under complete and accurate analysis
Why it matters: A BCR below 1.0 means the project costs more than it returns; it would not meet the federal threshold for investment under PL 83-566. A BCR of 1.1 is the thinnest possible margin of justification for a $308M project, and it is the kind of finding that OMB uses to reject or defer projects under independent scrutiny.
Evidence: Every quantified benefit flows to utilities and shareholders; the North Branch is assigned no environmental or recreational value; an unsupported 3.5% population growth rate (actual: 0.8–2.9%) inflates projected demand; and the most financially critical variable, secondary water connection revenue, is excluded from the analysis entirely because it is "too uncertain."
Lower-cost flood control alternatives were never evaluated
Why it matters: The $169M Urban Flood Control component is the project’s largest single cost. If cheaper alternatives exist, the entire financial justification shifts.
Evidence: Automated head gates that drain canals ahead of forecasted storms, using 48–72 hour weather forecasts now routinely available, are never mentioned in the DEIS despite being technically feasible and far less costly than piping the canal system.
The secondary water system may not be affordable or financially sustainable
Why it matters: If uptake is insufficient, all three cities and their taxpayers bear the O&M costs. The DEIS acknowledges connection rates are “the single most impactful variable” but excludes revenue projections from the economic analysis.
Evidence: The DEIS excluded secondary water revenue entirely because it is “too uncertain,” leaving the most financially critical variable unexamined in a $308M project. Affordability of the proposed Secondary Water System is a deep concern in a community where all elementary schools are Title 1 schools, meaning they receive federal financial assistance through the U.S. Department of Education because they serve a high percentage of children from low-income families.
DEIS ENVIRONMENTAL CONCERNS
The North Branch of the Logan River is not treated as a river
Why it matters: The South Branch, which only serves three public parks, receives explicit river protections, a guaranteed 25 cfs minimum flow, and $300K/year in Trout Unlimited funding. The North Branch, upon which Logan was founded, receives none of this despite serving 13 parks and recreation areas along its corridor.
Evidence: The DEIS refers to the North Branch as a "canal corridor," assigns it no economic, environmental, or recreational value, and acknowledges flows would drop to zero during extreme drought, which has occurred three times since 2000, in 2002, 2021, and 2022. It fails to acknowledge that the North Branch is a natural perennial stream, not a man-made canal, and that any use of a natural stream to convey appropriated water must not deteriorate its water quality or diminish its quantity for the purposes the stream naturally serves: fisheries, aquatic habitat, recreation, and community amenity. The Logan River bifurcates into two natural rivers that together create the Logan Island. Both branches would carry perennial flows under natural conditions, and both deserve protection as the rivers they are.
The project will increase consumptive water use, harming the Great Salt Lake
Why it matters: The Logan River feeds the Bear River, the GSL’s largest inflow source. Every acre-foot of water consumed locally is an acre-foot that does not reach a lake in crisis.
Evidence: President Trump requested $1B for the GSL; Governor Cox declared a drought emergency urging conservation; the LDS Church sent ~30,000 acre-feet to the GSL. This project moves in the opposite direction. GSL strike team identified Logan River as critical source of water for GSL.
Replacing open canal conveyance with pressurized pipe does not conserve water at the basin scale
Why it matters: Seepage from open canals recharges aquifers and sustains downstream flows. Capturing it upstream reduces water available to downstream users and natural systems, including the GSL.
Evidence: Downstream users have successfully sued over return flow capture on the Malad River (Bear River tributary), upper Snake River, and other Western rivers where upstream efficiency improvements reduced downstream supply.
Open waterways are foundational to community health
Why it matters: A project of this scale should improve public access to the Logan River system and preserve open flowing waterways as the community amenity and ecological resource they are, not cover or diminish them in favor of buried infrastructure and maintenance corridors.
Evidence: Salt Lake City, Provo, and other Utah municipalities are actively investing in river restoration and daylighting projects precisely because open waterways improve public health, reduce urban heat, increase property values, and strengthen community identity. This project should move in the same direction.
Experts on the design of urban waterways and community engagement should be on the project
Why it matters: A project that will reshape the urban river experience for generations of Logan residents should include landscape architects and urban river design specialists — not just engineers optimizing pipe networks and canal drainage.
Evidence: There are numerous qualified landscape architecture firms specializing in urban river interface and community engagement. A list of such firms can be provided on request.
LOGAN RIVER SYSTEM STEWARDSHIP REQUESTS
Establish a science-based fixed minimum flow for the North Branch of the Logan River
Why it matters: The South Branch, which serves 3 parks, has a guaranteed 25 cfs minimum for trout fisheries; the North Branch, which serves 13 parks and recreation areas and was documented in living memory to have superior trout fisheries, deserves equivalent science-based protection.
Evidence: The North Branch river corridor includes 13 parks and recreation areas compared to the South Branch’s three; without a fixed minimum, flows are subject to rationing that can reduce them to near zero.
Calculate minimum instream flows above First Dam, before Kimball Decree rationing
Why it matters: Minimum flows set below the Kimball Decree rationing threshold are not meaningful protections. During irrigation season rationing the flows would be prorated to a fraction of the stated minimum, leaving both branches without adequate base flow for healthy trout fisheries and natural stream function.
Evidence: Stream gage data shows the Kimball Decree apportionment was in effect by July in 20 of the past 26 years, by August in 25 of 26 years, and in all 26 years during September and October. The 2026 irrigation season opened in April with prorated flows.
Restore natural perennial base flow to the North Branch year-round by ending the practice of closing the Crockett head gates at the end of irrigation season
Why it matters: The current practice of diverting the entire natural perennial flow into the South Branch at season’s end causes an annual fish kill, eliminates approximately 6 miles of natural river infiltration and aquifer recharge, and impairs vested downstream water rights.
Evidence: This practice has severely degraded the North Branch trout fisheries. Natural river infiltration supports neighboring wells — when river recharge is eliminated, nearby wells run dry.
Redirect water the project claims to “conserve” (currently seepage that recharges the aquifer and sustains downstream flows) to instream flows and Great Salt Lake leasing rather than to additional irrigation consumption
Why it matters: The GSL airshed affects a far greater population than any potential irrigation use of this water. Preserving the GSL is the highest beneficial use of water in this watershed. This water is not newly created; it currently performs essential hydrologic functions that should not be sacrificed for lawn irrigation.
Evidence: The project predicts approximately 5 cfs of water currently seeps from open canals into the aquifer and returns to the river system. Dedicating this to instream flows and GSL leasing represents a genuine public benefit rather than additional upstream capture and consumptive use.
Evaluate leasing supplemental Logan River water rights to the Great Salt Lake, beyond the water the project proposes to redirect from seepage to irrigation
Why it matters: New Utah law protects water rights leased for instream flow to the GSL. Leasing unused portions of Logan River system rights protects those rights while delivering water to the lake that needs it most.
Evidence: Revenue from GSL leasing could offset infrastructure and O&M costs that sponsors currently propose to fund with $308M in federal and local taxpayer funds, creating a financially sustainable alternative to the Preferred Alternative.
Win-win proposal
• Maintain science-based minimum instream flows in both branches of the Logan River calculated above First Dam before Kimball Decree rationing, by leasing the unused portion of Logan River water rights to the Great Salt Lake. New Utah law protects leased water rights, so water rights holders are fully protected.
• Restore year-round natural base flow to the North Branch by ending the practice of closing Crockett headgates at irrigation season’s end, returning the river to its natural perennial state through Logan’s 13 riverside parks.
• Rather than capturing seepage that currently recharges the aquifer and sustains downstream flows, redirect that water to instream flows and Great Salt Lake leasing, where it delivers the greatest public benefit.
• Address flood risk directly and at far lower cost with automated canal headgates and targeted piping where needed to route flood flows away from homes and businesses.
• Result: open channel water system preserved, water rights protected, water reaches the Great Salt Lake, flood risk reduced, North Branch maintained for community wellbeing and restored as a perennial river through 13 parks — at a fraction of the cost of the DEIS Preferred Alternative.
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