I’ve been studying lakes since 2007. In 15 short years, I’ve worked on aquatic ecosystems from Alaska to France to the Tibetan Plateau. I’ve never encountered a waterbody as important or imperiled as Utah Lake.
The lake seems out of place and out of time. A fragment of freshwater cupped by the 200,000-square-mile Great Basin. A remnant of the Pleistocene that has witnessed some of the most dramatic events in geologic and human history, including the draining of Lake Bonneville and the rise and fall of dozens of Indigenous and immigrant civilizations.
Like most waterbodies in the U.S., Utah Lake has problems, including algal blooms and invasive species. However, decades of cooperative science and community-based restoration have put Utah Lake on the road to recovery. The June Sucker are rebounding, invasive species are being removed, public access is expanding, and algal blooms are declining for most of the lake. Perhaps most importantly, our community is embracing the lake—learning about its unique ecology and renewing our commitments as stewards of this part of God’s creation. Visitation has doubled in just a few years, community groups are organizing service and leisure events, and our leaders are leveraging their funding and influence to protect Utah Lake.
At this crucial moment of healing, a limited liability company called Lake Restoration Solutions (LRS) is proposing to turn Utah Lake into a construction site for the world’s largest dredged island complex. They claim without evidence that their island city will help the lake and are asking the people of Utah to give them an undisclosed amount of public land within and around the lake as compensation. Though LRS has disclosed few details about its island developments, leaked documents suggest they could make $11 billion from the land transfer alone. You can read LRS’s dredging application here and six independent evaluations of the project here.
I wrote a blog post last November describing seven problems with LRS’s proposal. There have been major revelations since then, and I thought an update was in order. This post is longer than the last one, but I hope you take the time to read it. Whatever your current position on the island project, this issue is too important to stay on the fence. Utah Lake needs all of us to be informed and engaged. I look forward to your criticisms and questions in the comments.
Problem #8. Failure to answer questions about liability
One of the biggest concerns about this project is the enormous economic and environmental risk it imposes on the people of Utah. LRS is proposing a 20+ year construction experiment using unproven methods at an unprecedented scale. If engineering, environmental, or economic complications occur at any time, LRS is a limited liability company that could declare bankruptcy and walk away. They have repeatedly failed to explain who would be responsible for cleanup if the project goes belly up.
American Fork’s mayor asked LRS President Jon Benson about this directly at the Utah Lake Commission meeting in January. Benson responded, “that’s an interesting question . . . It’s a legal question it sounds like to me about liability, and I’m not sure I know the answer right away.” Benson turned to an LRS permitting specialist, who said, “I can kind of hedge around, but I don’t know that I have the exact answer of liability.” LRS has been giving this same non-answer for years (listen to CEO Ryan Benson table the issue in this 2018 recording).
Under pressure from a skeptical public, LRS changed its narrative in February. Just over an hour into this contentious Vineyard city council meeting, Jon Benson dismissed concerns about economic and environmental risks as “emotional” and then claimed, “there’s not risk—financial risk to the state beyond the 10 million dollars as I’ve tried to be clear about and articulate”. He was referring to the $10 million loan guarantee given to LRS by the state legislature in 2021. However, he was conveniently ignoring the much larger risk of a failed project, which could leave our community with billions of dollars of environmental cleanup and decades of lost recreation, conservation, and economic benefits.
A few days later at an invitation-only event at the Grand America Hotel, LRS leadership mentioned their intention to put up a performance bond for the work. I was encouraged by this news, but whether it provides real protection depends on the details. For example, if LRS uses federal funds for the performance bonds (they are seeking $893 million from the EPA), the liability still falls on taxpayers. Likewise, if they only bond enough to finish the dredging or construction, it leaves the public with the cost of removing the islands and restoring the lakebed should their experiment damage the lake, as more than 130 independent experts believe it would.
It is not a surprise that LRS is cagey about responsibility. One of the hallmarks of megaprojects like this is a push to privatize profits while socializing the risks. Andrew South, a professor of Civil and Construction Engineering from BYU, gave a speech on the topic in February:
Megaprojects bring a full slate of known risks, but a proportionately higher number of unknown risks. Who bears the burden of these risks? Evidence has demonstrated that regardless of contractual risk transfer, when challenges grow large enough, it is always the public and its government that pay the cost. Whether financial, environmental or social. Unintended consequences due to future technical challenges and unforeseen negative economic or environmental impacts are not paid by project promoters, but by the generations of the public.
Parasailers enjoy a Utah Lake sunset from the sky. Photo by Jared Tamez.
Problem #9. Failure to tell us what they plan to do
Paradoxically, the further along this project gets, the murkier the details become. LRS’s original 2017 proposal was the clearest picture of their plans we’ve seen. The former project leads provided a timeline (>30 years), estimates of the island population (up to 500,000), details about invasive species removal (poisoning the entire lake with rotenone), and a general breakdown of the proposed $6.5 billion budget. They were even forthcoming about the fact that dredging a billion cubic yards of sediment would take “60 dredgers working 20 hours a day, six days a week, for eight years.” The project was no more viable than it is today, but at least we knew what they were trying to do.
When the Benson brothers took over sometime in 2019, they pulled a Bruce Wayne and took the project underground. To my knowledge, LRS has still not organized a single public meeting, though they have spent “years meeting with interested parties and government officials”. For their Army Corps dredging application, they had to disclose 48 closed-door meetings in 2021 alone, not counting meetings with politicians and investors (though some of these meetings have since come to light through GRAMA and FOIA requests). This lack of public engagement is stunning for a project that describes itself as “the largest fresh water restoration project in the United States” and Utah’s biggest public-private partnership.
While avoiding public input, LRS has been trying to distance themselves from unpopular aspects of their proposal. For example, in the February Vineyard city council meeting, LRS was asked about their claims that the islands might house 500,000 people. Jon Benson seemed indignant: “It’s in the proposal, and now we’re getting blasted for it.” However, when asked to give an updated estimate, Benson said, “I don’t want to give a number that I have to come back and say we need a little more to make it work.” For the rest of the meeting, Benson dodged all logistical questions. The placement of roads—not their call. The number and configuration of islands—impossible to know. Opposition from Provo, American Fork, and Orem—unfair and uninformed. The infamous skyscrapers from their promotional materials—only in there because of environmentalists! “The placement of islands could change a lot, it could change significantly, or no islands. I mean, there’s a lot of ways this could go as we get into this process.”
There has also been a blurring of detail in LRS’s written materials. At the Utah Lake Summit in January, Benson promised that their forthcoming Army Corps application would be “replete with science, data, and all the research that we’ve been doing”. At the same event, their lead lobbyist Jeff Hartley said the application had “over 100 pages of citations to peer-reviewed science”, falsely claiming that they were legally prohibited from sharing the application with the public. When the application finally came out, it was easy to see why they didn’t want to release it. There was less specificity than had been in the 2017 proposal and almost no science, new or old.
Here is an excerpt of an independent review of the application led by Sam Rushforth, the emeritus dean of the College of Science at UVU with more than 50 years of research experience on Utah Lake:
While the application does include a required wetlands survey, it does not present any new water or sediment chemistry data. Likewise, it provides no new evidence that the proposed modifications would be beneficial to Utah Lake in any way. Instead, LRS claims that they will perform this research later, in some cases after the beginning of dredging.
In addition to not presenting new data, LRS disregards many available studies about Utah Lake. The application cites a total of 12 peer-reviewed studies, only 4 of which were published since 1994… The disregard of this information—whether intentional or unintentional—is not reassuring from a group that claims to be capable of reengineering the lake from the bottom up.
All six groups that have made their analyses of LRS’s application public note the lack of clarity about what is being proposed. LRS seems to have learned that specificity is dangerous. If you never pin down your plan, you can always dismiss criticisms as premature or sue critics that are on the right track.
In summary, LRS is very confident that their project will be awesome for the lake and our valley. They just don’t think we need to know how, who, when, or why. The nebulousness leaves me with the same feeling as this Vineyard city council member: “You’re saying, ‘We have an idea, and it could take all these various forms, but we don’t really have any substance beyond that,’ so I don’t see why we are debating it.”
The project layout from LRS's application to the Army Corps of Engineers. The application is supposed to allow the public and the Corps to evaluate the potential environmental impacts of the project. Unfortunately, the application only satisfied 8 out 51 Army Corps requirements, based on an independent analysis led by Deeda Seed. They conclude, “LRS has failed to satisfy these prerequisites, putting the Corps and the public on unfair footing from the outset.”
Problem #10. Backwards science
Since our first encounter in 2018, it’s been clear that LRS has an unconventional understanding of the scientific method. They have ignored available studies, never reached out to the Utah Lake Science Panel, and made repeated blunders about basic science. For example they claimed that Utah Lake evaporation was not a source of downwind precipitation, they interpreted the most pertinent lake sediment study backwards, and they’ve refused to share the methods behind their claims of massive project benefits (LRS was recently forced to admit that their water storage and evaporation numbers were largely made up when challenged by actual water managers and hydrologists). I initially thought these rookie mistakes were just a consequence of inadequate expertise, but now I fear that LRS’s anti-science tendencies are rooted in a conflict of interest that goes much deeper. They’ve decided what the lake needs based on a business model.
I pointed out last November that LRS had “no PhD-level environmental or ecological scientists” on their team. This observation was based on their own materials, including multiple team rosters, their proposal, and their website. If I was wrong, they could have easily corrected the record by releasing their list of scientists. Instead, they responded by suing me for $3 million, filing a motion to keep their list of experts confidential, and releasing the name of a single PhD engineer, who they falsely claimed had 7,000 peer-reviewed publications. The bluster and fibs didn’t surprise me—we’ve seen a lot of this from LRS—but their confusion about engineers and scientists was puzzling.
Any major restoration project needs both scientists and engineers. The scientists diagnose the problem, sharing their data and recommendations publicly to explore multiple options. After stakeholder and public input, a restoration plan is developed, which the engineers implement. Just as scientists can’t carry out restoration without engineers, not even the world’s best engineers can help an ecosystem if not guided by rigorous science. Dr. Hans Paerl, a global expert in lake restoration described one such engineering first blunder in this recent episode of Radio West.
Lake Taihu is one of the largest freshwater lakes in China, and not dissimilar to Utah Lake in some respects (large, shallow, and lowland), though its algal bloom and pollution problems are much worse. In the early 2000s, some well-intentioned politicians and engineers decided to try a hard-path engineering shortcut. Rather than doing the difficult work of reducing wastewater and agricultural nutrient sources, they began an extreme campaign of dredging and hydrological modification. The misguided modifications cost $5 billion and ended up making the algal blooms much worse, cutting off the water supply for ~20 million people. Dr. Paerl gave the following synopsis:
The problem is that the engineers got in the room first… It was a decision that was made without really taking the ecology of the system into consideration. I think the lesson is that ecological systems, they don’t operate like physical things like building a building or a bridge or a dam—you know physical structures that engineers would typically work on.
With the stakes of Utah Lake restoration so high, why would LRS disregard available evidence and try to stifle scientific debate? I’ve concluded that it’s because their business model only works if they build and sell islands. Rather than beginning with research into what the lake might need, LRS started with a funding mechanism: selling land on artificial islands. They have been dredging up justifications and arguments to support this path ever since. When investors have millions or billions of dollars riding on a pre-selected “solution,” there is a pretty strong incentive to disregard any contradictory evidence and disparage any skeptical experts. Though LRS’s supporters say they are the only ones concerned with “science and facts,” LRS’s conflict of interest won’t let them consider any options that don’t involve islands. As one community leader in Saratoga Springs said, “LRS has never met a problem that can’t be fixed by islands.” George Handley described LRS’s single mindedness this way:
The myth [of an irreparable Utah Lake] has persuaded many of our elected officials that only a proposal to create and pave islands in the middle of the lake will save it. This is the mindset of the surgeon who never met a problem that surgery couldn’t solve. It’s time for a second opinion. It is our collective responsibility to ask what the body of the lake is telling us it really needs.
In restoration ecology, like in medicine, the first rule is to “do no harm.” That requires extremely rigorous analysis of all available evidence and clear-eyed consideration of all available options.
An American avocet hunts and looks for a mate on Utah Lake. Photo by Jeff Beck.
Problem #11. Disdain for debate and free speech
The constitutionally protected right to free speech is especially important when deciding issues of public concern. As Americans and Utahns, it is our responsibility to scrutinize and speak out about proposals that impact our community. The future of our state’s largest freshwater lake is certainly such an issue.
LRS says they welcome criticism and debate, but their actions tell a different story. Rather than demonstrating the viability of their proposal in the public square, LRS has used legal actions to silence critics and sought to influence “interested parties and government officials” behind closed doors through political favors, campaign donations, and offers of real estate. They have attacked the character of anyone who questions them and then played the victim when confronted with details from their own proposal and past statements.
Their fear of open dialogue has led them to suppress questions and criticisms on both social and traditional media. LRS has deactivated comments on their YouTube channel and banned so many people from their Facebook page that sailors from the Utah Lake Yacht Club created a parallel site to allow actual discussion. I have heard from multiple reporters that LRS has harassed them when their coverage wasn’t completely complementary.
If they have such a great project, why is LRS so anxious to avoid free speech and debate? Their statements give us some clues. When asked about public involvement this last summer, their CFO stated, “we are just about to really commence on our public outreach,” and that the public should “just kind of keep on monitoring the progress to show their support.” In January, their lead lobbyist said, “we welcome the opportunity to tell you what we’re doing. We’ve done it lots of times, we have lots of events, lots of forums, and we will have more. You will hear about it.” In February, their president said their public events would start in April.
It’s not the delayed timeline that disturbs me most (heavens knows, I’m 6 months behind on everything at this point); it’s their conditions on speech that raise red flags. LRS only wants “constructive” criticism. They only want the kind of “free” speech that supports and advances their project. They envision a one-way relationship where they inform us of their plans, and we cheer them on from the sidelines.
This patronizing belief is evident in their public relations campaign. LRS still hasn’t bothered to host a single event for public input, but they have expended substantial resources on billboards, paid TV and radio spots, and catered press conferences. At the same time, LRS has falsely claimed it would be inappropriate for the public or experts to weigh in at this stage, as if they are somehow entitled to a multi-year monopoly on the airwaves.
Unfortunately, this disdain and dismissal of the public appears to be a pattern. LRS’s CEO has spent years fighting to keep the public from knowing how he used millions of dollars of tax money to lobby against endangered species. LRS’s lead lobbyist apparently considers himself so far above public accountability that he dismissed Draper citizens as clowns and trolls when they pointed out his major conflicts of interest and potential misuse of their tax money.
LRS’s campaign to advance their project through intimidation and attacks has caused real damage to legitimate restoration efforts, creating an environment of distrust and suspicion in our community. After LRS served local community group Conserve Utah Valley with an invasive subpoena, Craig Christensen said:
We try to work in good faith to bring more transparency and collaboration to solve issues surrounding the challenges facing Utah Lake. We wish the developers would focus on involving the public in their plans instead of using the law to antagonize those who want to participate.My lawyer Whit Krogue captured LRS’s position even more succinctly when she wrote, “LRS’s actions suggest that it does not want public involvement…until it has the resources, permitting, and legislative support to overcome it.”
Ron Madson took us out for a sail last month, and we couldn't resist going for a dip. Between their negative advertising about the lake and their intimidation lawsuit, LRS seems to be trying to keep us from visiting or talking about Utah Lake. Do we want to live in a society where only those who can afford to retain permanent legal counsel can fully participate in public debate? Will we tolerate legal actions that dodge the hard questions and instead seek to silence citizens who are trying to understand and speak out about what is going on? These are no longer rhetorical questions.
Problem #12. Double speak and double standards
One of the most consistent and discouraging behaviors I’ve seen from LRS is dishonesty. From misrepresenting the history and status of the lake to mischaracterizing their own lawsuit, they seem to have a moving standard of truth. Maybe this kind of factual flexibility is typical in real estate speculation, but when the future of Utah’s largest freshwater lake is at stake, we need an absolute commitment to transparency and rigor. Here are eight inconsistencies and blatant deceptions that I think are pertinent as we decide if LRS is a trustworthy partner.
1. LRS has grossly misrepresented current and past restoration work on Utah Lake, claiming in essence that nothing is being done. At the same time, LRS is waging a major media campaign to stoke negative stereotypes about the lake, calling it gross, broken, a cesspool, and an eyesore. In reality, a coordinated restoration program including hundreds of innovative and highly successful projects has put the lake on the road to recovery. For example, state and local partners achieved ~80% carp removal and 70% phragmites control in less than a decade, senior water rights have been secured, nutrient limits have been tightened, and habitat restoration of lakeshore and lakebed is expanding. Thanks to these efforts, the June Sucker are rebounding, lake visitation is rising, and algal blooms are declining. Rather than learning from and supporting these innovative and successful restoration efforts, LRS portrays current work as futile pilot programs. According to LRS, islands are our only option for “comprehensive restoration”.
2. Depending on who they are talking with, LRS will either say their project is shovel-ready, or that they are years away from even starting. For example, they told the Vineyard city council, “This is going to be a long process though, and I think people are thinking we’re about to go do something. We’re not even close to starting dredging.” At the same time, leaked financial materials they were circulating to potential investors indicated that dredging and raw land sales were planned for 2023.
3. Tangled timelines are part of a larger LRS mischaracterization about the environmental permitting process. LRS has falsely claimed that they were prohibited from releasing their Army Corps application and that it’s not appropriate for experts or the public to weigh in about their project until the NEPA process officially begins. The opposite is true. Best practices and LRS’s own invitation from last year invite robust public participation from the very beginning of project design. More broadly, LRS has misrepresented the Army Corps and NEPA as infallible protections against all environmental harm. Jon Benson stated “if it’s going to make it worse, you wouldn’t receive the permits. The project would end at that at that stage.” In fact, over 99% of projects submitted for NEPA and Army Corps review are approved. A recent report on the Army Corps notes:
Two National Academy of Sciences panels and the Department of the Army Inspector General concluded that the Corps has an institutional bias for approving large and environmentally damaging structural projects, and that its planning process lacks adequate environmental safeguards. Less environmentally damaging, less costly, nonstructural measures that would result in the same or better outcomes are routinely ignored or given short shrift. This results in projects that are unnecessarily destructive, costly, and, in many cases, simply not needed.
NEPA is not a guarantee that federal bureaucrats will protect us from irresponsible projects. It is a mechanism that allows local citizens to defend themselves by actively asking questions, challenging stated benefits, and demanding details. LRS’s misrepresentations are meant to discourage public debate and give a false sense of security about their project.
4. When I called LRS’s funding structure “shady” last November, it turns out I’d only scratched the surface. LRS has been all over the map about their funding amounts and sources. They have described the project as Utah’s largest public-private partnership but claim that no taxpayer dollars will be spent. Nevertheless, they are seeking $893 million in subsidized federal loans—representing potentially $200 million of taxpayer-funded financial benefit. Their private sector funding is just as convoluted. In 2019, they claimed to have global investors lined up for the various project phases. Last year, they said they had “signed engagements with some of the largest environmental and impact-oriented funds in the world,” who they couldn’t identify because of nondisclosure agreements. They now say their funding is “all from domestic sources but mostly just from here in Utah.” However, it is unclear if this refers to the actual funding sources or the U.S.-based financial institutions managing the investments.
5. LRS claims their project will deliver “$6.5 billion dollars of environmental work—improvements to be done for the lake.“ However, their project budget reveals that most of this investment would be used to build and develop islands—activities that would damage not restore the lake. Indeed, they appear to have backed away from almost all true restoration work, leaving the habitat, invasive species, and water work to the state and local partners who are already making excellent progress. This led a government official who previously supported islands to tell me that LRS’s project brings zero added value, “Everything that’s being promised is already being executed.”
6. LRS has falsely claimed to be working with or endorsed by multiple community, city, state, and federal organizations. In December, LRS told the press they’d received a “fabulous endorsement” from the EPA. However, the actual announcement showed that LRS was one of only eleven projects not invited to submit an application to the EPA’s loan program. The Mayor of Vineyard told me that LRS said they had permitting in place and were “under contract” with the EPA—presumably one of the reasons the mayor signed a letter committing $5 million of city funds to the project without city council approval. LRS’s investment pitch reads, “LRS is a private/public partnership between the LRS team, government agencies, the state of Utah, local municipalities, and renowned real estate developers.” However, the state says it hasn’t received the required information to even evaluate the proposal, and except for Vineyard’s unauthorized letter, LRS hasn’t identified any supporting cities. LRS has falsely claiming that local environmental groups were on board, and they have been called out by a federal official for falsely stating that they were working with their organization.
7. Despite standing to make billions in taxpayer-subsidized profits, LRS insists that it’s their critics who have ulterior motives and personal agendas. They have accused their opponents of lacking transparency and spreading misinformation, even when that misinformation comes from LRS’s own materials and statements. They have asked to be personally invited to any opposition meetings, though they have never invited or even allowed critics to attend their events. They have strangely complained about not being allowed to share their data, though the state has been waiting for more details since 2018. They have criticized cities who have met with their opponents, though LRS has repeatedly met with city, county, and state officials with no representation from the other side.
8. Most personally, LRS has repeatedly misrepresented their own lawsuit against me. In February, when we responded to their allegations and counter-sued under Utah’s anti-SLAPP statute, LRS circulated a press release to the media. Though their lawsuit specifically seeks an injunction that would permanently prevent me from making any “derogatory” comments about their proposal in the future, here is how they described their lawsuit (the underlining is their own):
In our complaint, we ask that Mr. Abbott stop making false statements about Lake Restoration Solutions and its Project to restore Utah Lake. We also ask that those false statements be removed from Mr. Abbott’s social media and other websites.
Notably, we do not ask him to stop participating in the public process or sharing his criticisms and opinions about the Project… The complaint focuses solely on his defamatory and false statements.
They closed their press release by accusing me of grandstanding, as if them suing me was somehow my master plan. “We intend to prove our case in a court of law, while Mr. Abbott seems intent on creating a public spectacle to promote his own personal agenda.”
Representative Casey Snider asks questions about the behavior and approach of LRS during the committee hearing of HB240. The law amended the 2018 HB272 that paved the way for the transfer of Utah Lake sovereign land to private developers.
Problem #13. A history of misusing public funds and ethical conflicts
As a scientist, I naively assumed that the Utah Lake debate would be decided by scientific evidence. The lawsuit forced me to take a much deeper look into the relationships behind the island proposal. As I dug into the background of the proponents, I was shocked and saddened by what I found. I hate personal attacks, but I believe these details are directly pertinent to the question of whether LRS is the right group to take the reins of Utah Lake restoration.
As shallow as they are in scientists, LRS is deep in lobbyists and lawyers. They have six registered lobbyists, including Jeff and Greg Hartley, who have been described as some of the most powerful influencers on capitol hill because of their connections with former Speaker of the House Greg Hughes. During their time with the former speaker, Hughes was caught in a dizzying string of controversies that led to a federal probe into conflicts of interest with UTA and his resignation from the Inland Port Authority just weeks after appointing himself because of undisclosed land holdings. Self-described oil and gas “dirty lobbyist” Jeff Hartley himself has been caught up in a series of ethical conflicts. Hartley was simultaneously lobbying for the city of Draper and Geneva Rock, he physically prevented journalists from recording arrests during an Inland Port protest, and he is still working for both the City of Vineyard and LRS without disclosing the conflict to the city council in an apparent breach of contract.
Even more concerning, LRS’s CEO Ryan Benson has a history of faux-conservation activities and personal enrichment from public funds. Though he presents himself as a champion of the private sector, his two environmental consulting firms have together taken $12 million in taxpayer dollars while refusing to disclose how they used the funds. Big Game Forever (BGF) has been seeking to delist the gray wolf (a species that does not currently occur in Utah), and Stag Consulting has been trying to keep the greater sage grouse (which is in decline across the West) from being listed as threatened.
Questions about state payments to Benson’s organizations led to a legislative audit, which found BGF had comingled private funds with state money, and that there were inadequate safeguards and fiscal accountability. Benson reported to the state that BGF had more than 100,000 members, but independent reporting found fewer than 600 members, based on the membership fees reported in taxes.
Indeed, Benson’s anti-science advocacy has raised the ire of hunters and sportsmen across the West, who have spoken out about his companies' misuse of hunting license fees, attacks on public land and public hunting, and concerns about shifting money among 10 nonprofit and private organizations. Randy Newberg, one of the most prominent hunters in North America, takes Benson's groups to task, calling them "Johnny-come-latelys" and "carnies of crisis" who have muddied the water and harmed collaborative restoration and conservation efforts:
I'm referring to a group that tried to say they were representing hunters in the wolf issue, and they screwed us over so bad that if they would have just shut up and went home, we would have a way better outcome, a quicker outcome... I mean let's face it, there are some people who know that a crisis is an opportunity to profit, and nobody has built a franchise model any better than those groups out of Utah. And I don't mean to make this a bash those guys thing, but they stick their nose where it doesn't belong, they don't have any professional qualifications like you do. They’re manned by attorneys and other stuff.
Benson's groups even got called out by three of the most powerful pro-hunting organizations in the country when they emailed a press release to all 535 members of the U.S. congress falsely claiming endorsement. The groups issued a joint public statement to disavow all affiliation:
Today the National Rifle Association, Safari Club International and the Congressional Sportsmen’s Foundation publicly disavowed a misleading press release distributed on Friday, March 11th to congressional offices and other outlets. The press release blatantly misrepresents the position of these organizations regarding legislation to delist gray wolves under the Endangered Species Act...Due to the blatant misrepresentation contained in the press release circulated by these two groups, any claims they make in the future should be thoroughly investigated and independently confirmed.
In combination with multiple donations to county and state politicians, LRS looks much more like a political action committee than a restoration company.
Consulting firms run by LRS CEO Ryan Benson have received more than $12 million since 2012 for largely undisclosed state and federal lobbying (financial data from government transparency details: BGF and Stag Consulting).
Problem #14. Misleading comparisons
LRS insists that artificial islands are routinely used for ecological restoration, and that there are more than 70 comparable projects in the U.S. alone. They have cited Sea World, Galveston, Florida’s Venetian Islands, New Orleans, and Dubai as examples of why we shouldn’t be afraid of dredging. Even though these projects are much smaller than the Utah Lake islands, let’s dig a little deeper into LRS’s examples.
LRS claims that projects like theirs are common and highly successful. This comparison by Conserve Utah Valley shows that there are indeed several artificial island projects around the world. However, it also shows that the size and budget are way out of proportion for this project. LRS’s plan would be the world’s largest dredged island chain and the largest dredging project ever considered by the EPA or Army Corps.
In the 1940s, the city of Galveston tried repeatedly to use taxpayer money to dredge and fill an area in the East End Flats. Though the reclaimed land would be for private real estate development, the Mayor of Galveston called it “the biggest bargain ever offered to the taxpayers.” A concerned citizen wrote a Warning to Taxpayers in the local newspaper, concluding, “Galveston is well stocked with egotistical, self-appointed planners and brain trusters, who are always ready to furnish the scheme if taxpayers can be deceived into putting up the cash.” Citizens voted down the proposal, though the developers eventually moved forward with their own money, contributing to extensive wetland destruction.
Florida’s island chains near Miami are another illuminating case study. Biscayne Bay was a vibrant lagoon and estuary. During a land boom in the 1920s, the U.S. Army Corps of Engineers hastily constructed about a dozen “spoil” islands with dredged sediments from the bay. The islands and causeways disrupted circulation and put thousands of people in areas vulnerable to flooding. The dredging altered the bathymetry of the bay, exacerbating the effects of a category 4 hurricane in 1926, which devastated the developments. By 1930, plans for additional islands were cancelled to avoid “further mutilation of the waterway”. However, 75% of the bay had been dredged and coastal wetlands had been almost eliminated. Erosion from the spoil islands increased turbidity, killing vegetation, coral, and other sea life across the bay. To this day, more than half of the remaining sea floor is barren, and invasive plant specifies dominate the spoil islands. This may look like success to LRS because “ultra-luxury” estates were built on the islands, including the Anheuser-Busch mansion where Al Capone vacationed.
Zooming out a bit, we see that dredging and land creation projects have caused some of our nation’s worst ecological degradation and even human tragedies such as flooding during Hurricane Katrina. A recent report on Army-Corps-approved projects gave the following context:
The environmental damage has been so great that Corps projects are recognized as one of the leading reasons that North America’s freshwater species are disappearing five times faster than land based species and as quickly as rainforest species. Large-scale structural projects planned and constructed by the Corps have also increased flood risks for many communities, reduced water quality, impaired recreational opportunities, and damaged economies that rely on a healthy environment.
If we consider international examples, artificial islands have an even worse track record. China’s 940-acre Ocean Flower Island project cost $24 billion and destroyed coral reefs and oyster beds. Because of environmental shortcuts, 39 high rises had to be demolished, contributing to the developer’s $300 billion of debt. Japan’s Kansai Airport became the most expensive civil works project in modern history. Despite having some of the world’s best engineers, the artificial island sunk 8 feet more than expected (it continues sinking today). Between the cost overruns and continued instability, the project is considered one of the world’s largest geotechnical engineering disasters, costing more than $30 billion.
An overview of the six island chains that were planned for the coast of Dubai.
Most famously, the artificial islands in the Persian Gulf demonstrate how it is possible for a single enterprise to simultaneously be an economic failure, an environmental disaster, and a human rights catastrophe. The attempted construction of more than six archipelagos of islands in Dubai created massive ecological damage, including triggering algal blooms, degrading water quality, eroding coastlines, and asphyxiating sensitive coral ecosystems. Despite cutting costs by using forced labor, the developers ended up $60 billion in debt.
The similarities between the Dubai islands and LRS’s scheme are more than skin deep. LRS’s Director of Planning & Design is Robert Scott, who is described in LRS documents as the general manager of design and planning for Palm Deira and The World (two of the failed Dubai archipelagos). When I and others brought up this point, LRS said it was an unfair criticism because Scott was just the architect. LRS has since gone to great lengths to distance itself from the Dubai islands, including suing me for pointing out the connections. They may have even let Scott go, who no longer appears on LRS’s team page.
Screen capture of LRS’s private presentation to state officials from September of 2020. In February of 2022, Jon Benson told the city of Vineyard that “Dubai and this project have nothing in common, in my opinion.”
To their credit, LRS has brought up one island creation project that is motivated by restoration. Marker Wadden is a Dutch project to undo damage from a botched land creation attempt from last century. In 1932, the Dutch completed a “closure dike” that cut off a 420 square-mile bay of the North Sea. The Dutch intended to drain the area to create polders, but the land reclamation stalled in the 1960s. After completing another mega-dike in 1976, the huge Markerwaard development was indefinitely put on hold because of political and environmental concerns. However, the massive hydrological modifications were already doing their damage. The dikes transformed what was previously a dynamic and productive tidal ecosystem into a series of stagnant reservoirs. The artificial shorelines provided little habitat, and the loss of tidal circulation caused the water to turn brackish and then fresh. The changes also disrupted sediment transport causing erosion and the accumulation of silt. These alterations killed off the benthic community and caused a cascade of ecological collapses.
Since 2012, the Marker Wadden project has been trying to mitigate some of this damage by creating uninhabited artificial tidal flats and wetlands. Thanks to public funding, the project has been partially successful, and the media coverage has been overwhelmingly positive. However, Marker Wadden has also revealed the limitations of this kind of damage control. A 2021 analysis of the project found that most of the initial promises were not achieved. For example, using locally dredged silt proved expensive and slow, so the dredging company imported sand from another project, undermining two of the original project goals (removing silt from the reservoir bottom and developing new dredging techniques). Likewise, the scientific research activities were cut, and the water quality goals were replaced by a focus on island size and speed of construction. The authors conclude, “Whereas the public value to be created was initially broadly defined, it fell apart in disconnected tracks.”
However, I don’t want to bash Marker Wadden. It’s just a project that is trying to make the best of a bad situation. The main lesson from this story is that megaprojects and miracle cures bring along huge risks. We should fix Utah Lake by restoring its water flow and reducing pollutants, not by trying to make it into something it never was. Unlike the Great Salt Lake, which we sliced and diced into six independent basins, Utah Lake is still intact. That means we still have a chance at real restoration—at least if we can dodge the silver bullets. As taught in both ecology and environmental engineering, the chief cause of problems is solutions.
I’ll end with a comparison that LRS has never mentioned, but one that I think is extremely relevant. Lake Balaton is a large and shallow lake in Hungary with similar chemistry and hydrology to Utah Lake. Starting 150 years ago, a series of mistakes triggered a familiar cycle of interventions and unintended consequences. Flow control structures were installed to keep the lake level from fluctuating. Invasive eels and carp were introduced to supercharge the fishery and decrease algal blooms. Barriers were constructed to protect the shoreline from ice and wave erosion. This taming of the lake let development extend right to the shoreline, leading to wetland destruction and nutrient loading from wastewater. In the 1970s, the lake’s food web and ability to remove pollutants collapsed, causing toxic algal blooms and mass fish kills. A recent study on Lake Balaton’s mismanagement sounds uncannily like a description of LRS’s proposal.
Reasons for the negative results/impacts of the introduced interventions are: insufficient level of technical or scientific knowledge at the time of planning and implementation; poor decision support systems and mechanisms; insufficient consultation with local people and experts of other fields; lack of integrated approach, both in terms of territorial and interdisciplinary aspects; and pursuing of short term economic or political benefits.
Thankfully, the local community learned from these failures and changed directions in the 1990s. Just like the June Sucker Recovery Program, scientists and managers implemented a community-driven restoration plan. This included wastewater treatment, restoration of wetland habitat, agricultural improvements, and even some targeted dredging. As expected, the lake’s recovery was not immediate. However, the community stuck with the adaptive management plan, and over 20 years, the lake began to heal. Though full recovery will likely take another few decades, Lake Balaton is now an international tourist destination and a major source of national pride.
Native vegetation recovers after phragmites removal near Saratoga Springs. Science-based restoration and community support are bringing new life to Utah Lake. Will we be wise enough to let the sun rise or repeat the mistakes of the past? In this delicate moment of recovery, we need everyone informed and engaged. Photo by Jeff Beck.
So, what can we do?
The first thing is to repeal the law that opened the door to giving away our sovereign lands. Look up your state representative and senator and ask them if they will help repeal HB272 from 2018. You don’t need to moralize or shame them—there were many sincere legislators who believed the law would help the lake. Indeed, most of the legislature voted for the amendments this last session that added some guardrails to the process (thank you Representative Stratton and Senator Bramble!). However, we need to reestablish the lake's constitutional protections for sovereign land so we can get back to real restoration work. LRS is going to complain that we need to let the process play out. However, they have already had three years to prove they were capable of restoring the lake, and they haven't even submitted the required information to the state. Do we really want to keep subsidizing their venture while they undermine legitimate education and restoration efforts?
You can also submit a comment to the Army Corps expressing your thoughts, questions, and concerns. Send your respectful email to the point of contact here.
Finally, you can go explore and enjoy the lake. There is nothing more motivating and rejuvenating than experiencing Utah Lake. There are a bunch of great ideas on the Utah Lake Commission website. Share your experiences with your family and friends to help our community rediscover this amazing ecosystem at the heart of our community.
As the lake freezes, rafts of windblown ice create unique patterns. Let's make sure the lake is still here for our kids and grandkids.
