A project of this magnitude could bring real benefits to Box Elder County. It could also impose costs and commitments on the region that last for decades. The question is not whether to develop, but whether a 35-year, 9 GW industrial commitment receives the deliberation its scale calls for. The factual record below is drawn from MIDA documents, state filings, federal pipeline filings, and peer-reviewed reporting, and is offered in service of that deliberation.
If you have 30 seconds at the microphone
A project of this scale deserves the full process its scale calls for. This is ancestral Shoshone land. It sits in the watershed of a lake the state has declared in emergency, and home to a species the federal government is now reviewing for ESA listing. There is no public record yet that tribal consultation has been initiated, and the federal review pathways have not been disclosed. I would ask the Commission to take the time to get those answers on the record before consent. A decision this large will outlast all of us in this room. It deserves to be made with full information.
Section IWhat this place is
Reason 01
This is ancestral Shoshone land.
The Promontory area is documented in published archaeology and in the Tribe's own history as ancestral wintering ground of the Northwestern Band of the Shoshone Nation, the federally recognized tribe headquartered in Brigham City itself. The Treaty of Box Elder was negotiated and signed at Box Elder on July 30, 1863. The Promontory Caves are the type assemblage for the "Promontory Phase" (1250 to 1350 CE), with collections held at the Natural History Museum of Utah. The Bear River Massacre site sits in the same regional landscape.
NHPA Section 106 and Executive Order 13175 require meaningful tribal consultation when federal action affects historic properties of cultural significance. The public record does not yet show that consultation has been initiated for the Stratos project area.
Reason 02
A federal listing review is underway.
On January 23, 2026, the U.S. Fish and Wildlife Service issued a positive 90-day finding on the petition to list the Wilson's phalarope as threatened under the Endangered Species Act, advancing the petition into a 12-month status review. Up to 60 percent of the global population of the species uses Great Salt Lake during fall migration. The species' population has declined approximately 70 percent since the 1980s. The Service identifies declining inflows reaching the lake as the central concern.
Stratos's water-rights application 13-4148 would withdraw 1,900 acre-feet per year of new industrial water in a tributary basin to that same lake, during the active 12-month review.
Reason 03
It runs against the direction of state water policy.
The Utah Legislature has spent four consecutive sessions (2022 to 2026) on Great Salt Lake water-recovery legislation. There is a Great Salt Lake Commissioner. The 2024 Strategic Plan describes the lake as in systemic decline. In 2025 the state spent $30 million to acquire and retire 144,000 acre-feet of US Magnesium's water rights to send more water to the lake. Compass Minerals voluntarily donated more than 200,000 acre-feet per year back. HB 453 (2024) tripled the severance tax on lake-area mineral extraction to incentivize voluntary reductions.
The trajectory of state policy has been the retirement of industrial water rights in this basin. A new 1,900 acre-feet industrial extraction in a tributary drainage moves in the opposite direction. The project sits hydrologically upgradient of Locomotive Springs, whose flow has already declined more than 50 percent per USGS measurement. The reconciliation between this application and the broader state policy direction is a fair question for the record.
Section IIThe operational record
If the project is built, here is what is already on the record.
9 GW
Full buildout target
2.8×
Utah's avg. electricity use, at one site
1,900 ac-ft
Industrial water rights filing (App. 13-4148)
The pipeline arithmetic is tight.
The Ruby Pipeline's federally certificated daily capacity is 1.5 billion cubic feet of natural gas. A 9 GW gas plant at best-in-class combined-cycle efficiency (55 percent) would require approximately 89 percent of that mainline capacity. At simple-cycle efficiency, demand exceeds the pipeline by roughly 40 percent. Ruby already serves contracted West Coast utilities. How is the gas to be delivered?
A water-rights filing is on record.
Application 13-4148 requests 1,900 acre-feet per year for "Power Plant and Data Center; Steam Generation" from Salt Wells Spring Stream in Hansel Valley, about 619 million gallons, equivalent to roughly 10,000 Utah residents at the state per-capita rate. The "steam generation" use category is documentary evidence that the project relies on water-cooled gas generation. The protest deadline is May 5, 2026.
The tax structure is a substantial reduction.
MIDA reduced the standard energy-use tax on the project area from 6 percent to 0.5 percent, a 92 percent reduction. The development agreement also provides an 80 percent rebate of property tax on the compute campus and 100 percent personal-property tax relief via rebate. The headline "$30M per year for Box Elder County" should be read alongside what would have been collected at standard rates over the project's stated 35-year life.
Utah's regulatory framework has narrow direct application.
Utah has no statewide PUE (energy-efficiency) ceiling, no statewide WUE (water-efficiency) ceiling, no mandatory data-center water-use reporting law, and no 100-year water-supply demonstration requirement. SB 132 (2025) created an explicit "closed private generation system" pathway that exempts off-grid data-center campuses from Public Service Commission rate regulation and Integrated Resource Planning review. "We will comply with all applicable Utah requirements" is, in this regulatory landscape, a statement with limited specific content for off-grid data centers.
Section IIIHow to participate
The actions below are how the public engages with decisions of this magnitude under existing Utah and federal process. They are how the system is designed to work. None of them prejudges the outcome; all of them help ensure the record is complete before consent.
- Attend the May 4 public comment meeting at 4:00 PM at the Brigham City Fairgrounds, Art Building. The April 27 hearing was held without taking public comment; May 4 is the next opportunity. Bring written remarks; ask for time at the microphone.
- File a water-rights protest on Application 13-4148 before May 5, 2026. Online at waterrights.utah.gov. $15 per protest. Cite groundwater impact, Locomotive Springs flow, and Great Salt Lake tributary depletion during active Wilson's phalarope ESA review.
- Contact USFWS Region 6 (Mountain-Prairie) regarding the project's water-rights application falling within an active 12-month status review for Wilson's phalarope, a species dependent on Great Salt Lake.
- Submit written comment to the Box Elder County Commission requesting (a) full federal-review pathway disclosure, (b) tribal consultation before consent, and (c) public release of the development agreement at least 30 days before any final vote.
- Coordinate with Utah Rivers Council, FRIENDS of Great Salt Lake, the Audubon Society, the Center for Biological Diversity (Wilson's phalarope petitioner), Save Our Canyons (MIDA / NEPA expertise), and the Bear River Water Conservancy District.