The corridor

01

01 · EXECUTIVE SUMMARY

The Great Salt Lake has fallen 11 feet in four decades. At its November 2022 low of 4,188.5 feet, the lake's surface area had collapsed from 1,700 square miles to roughly 800 square miles—a loss of more than half its extent. The decline is driven by human water use: agriculture consumes 65 percent of the basin's depletion, municipal and industrial use 23 percent, and mineral extraction roughly 9 percent. The state's own analysis, completed by the Great Salt Lake Strike Team in 2026, identifies a deficit of 800,000 acre-feet per year of additional inflow needed to restore the lake to a healthy minimum elevation of 4,198 feet. This prospectus describes a project to deliver 1,000,000 acre-feet per year—125 percent of the state's stated need—through a gravity-fed aqueduct system that generates revenue sufficient to finance itself.

The project is not price-sensitive; it is discount-rate sensitive. The delivered cost of water is $1,171 per acre-foot, which is below the Salt Lake City commercial summer rate of $1,821 per acre-foot and the household top tier of $2,586 per acre-foot. The project's financial return depends entirely on the discount rate applied to its cash flows. At 7 percent, the project is negative. This is not a weakness in the structure; it is the controlling fact. The project is sized to serve a 50-year horizon at a cost of capital that reflects the risk profile of a long-lived infrastructure asset. A venture-rate discount rate is not the appropriate test.

The project's revenue does not come from water sales alone. Water represents approximately 17 percent of segment revenue. Power is the money. The corridor is built as 32 segments, each carrying one node with its own pump station and data centre. Generation is solar and wind on the easement, firmed by pumped storage in the collection pools; the corridor carries 2,326 megawatts of average sellable generation after a 445-megawatt continuous pumping load. The nodes are designed to be sold or leased to cloud-service operators and other high-density computing users. The power revenue is the primary driver of project economics. Water sales provide margin and de-risk the power business. The combination is what makes the project financeable.

The project is structured in 32 independent segments, each 25 miles long, each with its own intake, its own terminus, and its own revenue stream. This modular design means that if funding is lost at segment 12, segments 1 through 11 are complete, operational, and generating revenue. No segment depends on the completion of any other segment. This independence is a requirement of the financing structure and a condition of the environmental review. Each segment must be able to justify its own existence on its own merits, independent of the others.

The project requires two distinct funding mechanisms. The first is a $25,000,000 appropriation to conduct a comprehensive feasibility study. This study will verify the hydrology of the Great Salt Lake basin, confirm the volume of water available for diversion, establish the precise route of the aqueduct system, quantify the right-of-way acquisition costs, and validate the power-generation assumptions embedded in the financial model. This study is the prerequisite to all subsequent action. It is not a design study; it is a go/no-go study. Its completion will either confirm that the project is feasible or identify the specific barriers that prevent it.

The second funding mechanism is the creation of a state-chartered Authority that will issue revenue bonds to finance the construction and operation of the aqueduct system. The state will not appropriate the capital cost of the pipe. The state will appropriate the $25,000,000 study cost and will grant the Authority the right to appropriate water from the Great Salt Lake basin and to sell that water and the power generated by the system. The Authority will borrow against the revenue stream generated by water sales, power sales, and ancillary services. The bonds will be non-recourse to the state, meaning that if the project fails to generate sufficient revenue, the bondholders have no claim on the state treasury. This structure is standard for infrastructure finance and is the only structure that allows a project of this scale to be financed without consuming the state's entire bonding capacity.

Three material uncertainties remain unresolved and are disclosed here because they will be discovered in diligence if they are not disclosed now. First, the hydrology of the Great Salt Lake basin has not been independently verified at the scale required by this project. The Strike Team's estimate of an 800,000 acre-foot annual deficit is the best available number, but it is an estimate. The $25,000,000 study will either confirm it or revise it. If the actual deficit is substantially smaller than 800,000 acre-feet per year, the project's scale may need to be reduced, which would reduce its revenue and its ability to service debt. Second, the route of the aqueduct system has not been finalized. The Utah corridor is 800 miles long and costs $27.7 billion. An alternative route is 1,550 miles long and costs $53 billion. The alignment study will determine which route is feasible; until it does, the financial model carries both scenarios. Third, the structure of the Authority's debt—whether it will be non-recourse to the state, or whether the state will provide a compensated moral obligation through sovereign-land revenue or other sources—has not been determined.

The project's counterfactual is not a number. It is a state. If the lake continues to decline, the surface area will continue to shrink, the salinity will continue to rise, the ecosystem will continue to degrade, and the assessed value of property in the surrounding valleys will reflect that degradation. The project does not prevent this state; it reverses it. The choice is not between the project and the status quo. The choice is between the project and continued decline.

02

02 · THE PROBLEM

The Great Salt Lake sits 6.5 to 7 feet below the elevation the State of Utah has determined necessary to sustain the ecosystem that depends on it. At the current trajectory, that gap widens. The lake requires an additional 800,000 acre-feet of annual inflow to reach 4,198 feet—the healthy minimum established by the Great Salt Lake Strike Team convened by the Governor's office and staffed by the University of Utah, Utah State University, and the Gardner Policy Institute. Our target of 1,000,000 acre-feet per year exceeds that need by 25 percent, providing headroom against forecast error and future climate adjustment.

The deficit is not a drought problem. It is a depletion problem. The lake loses water because humans take it. The Strike Team's 2026 analysis attributes 65 percent of anthropogenic depletion to agriculture, 23 percent to municipal and industrial use, and approximately 9 percent to mineral extraction. Of the agricultural share, cattle feed—alfalfa and grass hay—accounts for 908,729 acre-feet per year, or 57 percent of all human-caused depletion in the basin. This is more than three times the volume consumed by municipal and industrial users combined.

The mechanism is straightforward. Water diverted from the basin for irrigation does not return to the lake. Some fraction returns as treated effluent or groundwater recharge; the remainder is consumed by the crop or lost to evaporation. Alfalfa, grown on 791 square miles of irrigated land in the basin—70 percent of all basin acreage in cattle feed—consumes 617,034 acre-feet annually. Grass hay consumes 291,695 acre-feet. Both are irrigated at an allocation of approximately $300 per acre-foot, a price set by statute and subsidy rather than by market. The crops are sold into a national and international market where alfalfa trades at a price that does not cover the full cost of the water used to grow it in an arid basin where that water is the limiting resource.

Utah produces approximately 2 percent of the nation's alfalfa supply. The crop is sold because it meets a price. The buyer may be a dairy operation in California, a feedlot in Texas, or a livestock operation within Utah. The mechanism is identical: water is diverted, the crop is grown, the water is consumed, and the lake receives no return. The allocation price of $300 per acre-foot is the policy lever. It is also the reason the deficit persists.

The state has pursued conservation for 25 years. The Strike Team's analysis shows that conservation efforts over that period have added 1,665 acre-feet per year to average annual inflow to the lake. This represents 0.2 percent of the 800,000 acre-foot deficit. The empirical finding is unambiguous: asking people to want less does not close the gap. Conservation is necessary. It is not sufficient.

The lake's decline is not new. In November 2022, the surface elevation fell to 4,188.5 feet, the lowest recorded level. At that elevation, the lake's surface area had contracted from approximately 1,700 square miles at the historic average of 4,200 feet to roughly 800 square miles—a loss of more than half the lake's extent. The decline has been interrupted by good snowpack years. In 2022 and 2023, two consecutive years of above-average precipitation raised the lake 6.5 feet. The recovery was real and temporary. Without a structural change in water supply, the lake will return to decline.

The hydrological baseline is fixed. The basin receives approximately 2.1 million acre-feet of annual inflow from precipitation and snowmelt. This figure does not change materially with policy. The demand for water in the basin—agricultural, municipal, industrial, and mineral—currently exceeds the sustainable supply. The deficit is the difference. Closing it requires either reducing demand or increasing supply. The state's own analysis concludes that demand reduction through conservation alone cannot achieve the target. The plan increases supply.

Agricultural water in the basin is held under appropriative rights administered by the state engineer. The $300 per acre-foot figure used here is an allocation rather than a market price: it reflects what irrigation water costs a holder under that allocation, not what the water would clear at if it were sold. It is lower than the price paid by municipal and industrial users—the Salt Lake City commercial summer rate is $1,821 per acre-foot; the household top tier is $2,586 per acre-foot—because agricultural water is allocated by statute, not by market. The plan does not propose to change this allocation. It proposes to add supply sufficient that the lake reaches its target elevation even as the current allocation structure remains in place.

The deficit is also not a problem that will solve itself through demographic change. Municipal and industrial water demand will increase. Agricultural demand is more stable, but the acreage in production and the crops grown respond to price and to the availability of water. At the current allocation price, the incentive to conserve water in agricultural use is weak. The plan does not rely on that incentive changing. It assumes the current structure persists and sizes the supply accordingly.

The state's healthy minimum for the lake is 4,198 feet. The bill that authorizes this plan sets the target at 4,205 feet—seven feet higher, providing additional margin. At 4,205 feet, the lake's surface area is approximately 1,850 square miles. The salinity remains in the range that sustains Artemia franciscana, the brine shrimp that forms the base of the food web supporting the migratory bird population. The elevation is measurable, the salinity is measurable, and the bird population is countable. These are the metrics by which the plan's success will be judged.

The deficit exists because supply is insufficient. Conservation has reduced the rate of increase in demand. It has not reduced demand below supply. The plan closes the gap by adding 1,000,000 acre-feet of annual inflow. This volume represents approximately 38 percent of the current total inflow to the lake. It is the volume the state's own analysis determined necessary to restore the lake to a level where the ecosystem it supports can persist.

03

03 · THE NODE — THE UNIT

The controlling finding is structural: each segment of the corridor is a complete, standalone asset. An intake or lift station, a pressurised pipe, a pump station, a data centre, and a recharge facility form a closed loop that generates revenue, consumes water, and returns it. The segment does not require the next segment to function. It does not require Salt Lake City at the end of the line. It does not require the lake to exist.

This changes the unit of analysis from a 32-segment, 800-mile corridor to a modular node that can be deployed anywhere the hydrology and the grid permit. It changes the capital structure from a single $27.7 billion ask to a series of $1 billion asks, each with its own revenue stream and its own payback. It changes the risk profile from "the entire project fails if one segment fails" to "you lose that segment's revenue and keep the others." Most importantly, it changes the product from water to time—the three to seven years saved by avoiding the interconnection queue.

The Standalone Node Economics

A single node, built to specification, costs $1.0 billion in capital. It comprises a 25-mile segment: intake or lift, pressurised transmission main, pump station rated for 100 MW continuous tenant load, 72.7 MW of sellable generation on the easement, and a recharge basin. It moves acre-feet per year. It generates 100 MW of thermal load cooling and 72.7 MW of grid-sellable power.

The revenue model runs two cases: merchant power at $45/MWh, and time-to-power at $75/MWh. The merchant case represents grid sales at current forward prices. The time-to-power case represents a lease to a data centre operator who values the avoided interconnection wait at a premium to merchant rates.

Merchant case ($45/MWh):

Power revenue: 72.7 MW × 8,760 hours × $45/MWh = $28.7 million per year.

Waste heat recovery down the district energy ladder: This is the thermal offtake from the data centre's closed-loop cooling system, priced at $25/MWh equivalent, delivered to district heating and cooling loads. The figure is modelled; it is not measured. The comparable is Stockholm Data Parks, where the utility pays for rejected heat at this order of magnitude.

Replenishment credit: 50 percent of the node's water is eligible for replenishment credit under the Bonneville Environmental Foundation's Water Restoration Certification program, priced at $1,303/AF (equivalent to $4/kgal). This yields $20.4 million per year. This credit is live in Oklahoma and other donor-basin states. On the Utah leg, it is worth zero. §408's mandate fails additionality; the credit is foreclosed. See the risk register, section 09, for the disclosure.

Total merchant revenue: $65.0 million per year.

Cash yield on $1.0 billion capital: 6.5 percent.

Simple payback: 15.4 years, excluding construction-period interest.

Time-to-power case ($75/MWh):

Power revenue: 72.7 MW × 8,760 hours × $75/MWh = $47.8 million per year.

Waste heat recovery: (unchanged).

Replenishment credit: $20.4 million per year (unchanged).

Total time-to-power revenue: $84.1 million per year.

Cash yield on $1.0 billion capital: 8.4 percent.

Simple payback: 11.9 years, excluding construction-period interest.

The premium to merchant is the value of time—the three to seven years the tenant saves by avoiding the interconnection queue. It is not a subsidy. It is not a guarantee. It is a lease rate that a data centre operator will pay because the alternative is waiting for grid connection while the facility sits dark and unproductive.

The interconnection queue held approximately 2,600 GW at the start of 2026. Median wait to commercial operation is approaching five years for utility-scale projects; data centres specifically face up to twelve years. Behind-the-meter generation converts this five-to-seven-year utility wait into a twelve-to-eighteen-month equipment and commissioning schedule. A 100 MW tenant earning lease revenue three years earlier than it would on grid connection is not buying cheaper electricity. It is buying three years of a revenue line it otherwise would not have had. That is what carries the premium.

The Water Margin

The same node, on the same segment, with the same capital, generates a water margin of $14.6 million per year. This is the revenue from selling acre-feet per year at $1,639/AF, less the delivered cost of $1,171/AF. The delivered cost is reconstructed from the source-and-uses analysis in section 06; it excludes construction-period interest. The price is 90 percent of Salt Lake City's commercial summer rate of $1,821/AF, published in the FY27 rate schedule.

The water margin is 17 percent of total node revenue in the merchant case and 17 percent in the time-to-power case.

This is the finding that reorganises the entire prospectus: water is 17 percent of segment revenue. Power is the money. The water is the differentiator—the thing that makes the cooling stack work and the thing that makes the asset defensible to a county commission. But it is not the thing that carries the project.

The Cooling Stack

The node's data centre tenant operates a 100 MW facility. It requires cooling. The choice of cooling technology determines three things: the power consumption of the cooling system itself, the water consumption of the cooling system, and the condensing temperature of the facility's processors.

Three options exist: evaporative (wet tower), dry air-cooled, and once-through cold pipe.

Evaporative tower (the industry standard):

Power consumption: 30 MW.

Water consumption: 1,662 acre-feet per year.

PUE (Power Usage Effectiveness): 1.30.

Dry air-cooled (the alternative):

Power consumption: 40 MW.

Water consumption: 50 acre-feet per year.

PUE: 1.40.

Once-through cold pipe (the node's design):

Power consumption: 10 MW.

Water consumption: 0 acre-feet per year (the water is the coolant; it is returned to the recharge basin warmer, not smaller).

PUE: 1.10.

The once-through cold pipe beats the evaporative tower on both axes simultaneously. It consumes 20 MW less overhead—175 GWh per year. At $45/MWh, this is worth $7.9 million per year to the tenant. At $60/MWh, $10.5 million. At $90/MWh, $15.8 million. The tenant is not being asked to give anything up. It is a better machine that happens to be the honest one.

The water that flows through the cooling loop is not potable. It is treated to a standard sufficient for heat exchange—non-corrosive, non-fouling, free of biological growth. It is not treated to drinking water standard, which is among the most expensive parts of a supplier's cost of service and confers no benefit whatsoever on a machine. Non-potable delivery is cheaper to produce, and section 07 requires that this cost advantage be passed through as a lower rate.

The water leaves the cooling loop warmer than it entered. It is then recharged to the aquifer or the surface basin. It is not consumed. It is not destroyed. It is not exported. It is returned.

This is the mechanism that answers the three objections raised at every county planning commission in America: it burns fossil fuel (it arrives with its own generation on the easement); it drains the grid (the collection pools are pumped storage at 1.025 kWh/AF-ft, approximately 80 percent round-trip efficiency, and discharge at peak); it drains the water (once-through cold loop, non-consumptive, then recharged).

The Overbuild and the Break-Even Utilisation

The node is sized for a 100 MW tenant load and carries 72.7 MW of average sellable generation on the easement. Generation is deliberately built above the level the pumping duty alone requires: 1.5 times capacity costs 1.275 times capital, because approximately 45 percent of a node's cost — right-of-way, permitting, interconnection, trench and intake works — does not scale with capacity at all. Unit cost falls accordingly.

The overbuild costs 1.275× the capital of a right-sized facility. The break-even utilisation on the overbuild is 55 percent. This means that if the tenant uses only 55 percent of the facility's capacity, the overbuild pays for itself through grid sales. Above 55 percent utilisation, the overbuild is pure upside. Below 55 percent, the overbuild is a cost.

The break-even utilisation on the incremental capacity is 55 percent. The question is therefore not whether the additional capacity sells, but whether more than half of it ever sells. It is also a hedge: if the tenant fails or relocates, the node can operate as a pure generation and cooling asset, selling power to the grid and waste heat to the district energy system. The node does not require the tenant to survive.

Segment One: The Found-Head Route

Segment One is the first node to be built. It is the proof of concept. It is the segment that establishes the capital cost, the revenue model, the permitting pathway, and the operational baseline for all segments that follow.

Segment One's capital cost is $1.35 billion. This is higher than the $1.0 billion model node because Segment One includes the intake structure and the initial recharge basin, both of which are more expensive to build than to replicate. Segments 2 through 32 are modelled at $850 million each, reflecting the replication of proven design and the elimination of first-of-a-kind costs.

Segment One is sited on a found-head route. This means the intake elevation and the recharge elevation are such that the natural gradient of the terrain provides head—elevation difference—that reduces the pumping load required to move water from intake to recharge. The found-head criterion is the primary site-selection filter. It is the reason the node works at all. A route without found head requires more pumping, more power, more capital, and lower returns. The alignment study will identify candidate routes and rank them by found head, by distance to grid interconnection, by distance to data centre markets, and by right-of-way acquisition risk.

No county, reservoir, intake, or quarry site is named at this stage. The alignment study's first deliverable is the identification of the route and the naming of the specific locations. Until that study is complete, the prospectus states only the selection criteria and the capital model that flows from them.

Segment One's revenue model is identical to the standalone node: $65.0 million per year in the merchant case, $84.1 million per year in the time-to-power case. Simple payback on a node is 15.4 years in the merchant case and 11.9 years in the time-to-power case. ⚠ Those figures include the replenishment credit. Net of it — which is the only case that applies on the Utah leg, where the statutory mandate fails the additionality test — the same node returns $44.6 million and $63.7 million a year, or 22.4 and 15.7 years. Both are stated because a reader will derive the second one first.

The independent utility of Segment One is the foundation of the financing structure. Each segment's financing and permitting documents state standalone utility as the reason for its existence. This is not a legal fiction. It is the operational fact: Segment One generates revenue, consumes water, and returns it, without requiring any other segment to function. If Segment Two is never built, Segment One still works. If the lake never reaches 4,205 feet, Segment One still works. If Salt Lake City never buys a drop, Segment One still works.

This independent utility is the reason the project can be financed in tranches, permitted in tranches, and built in tranches. It is also the reason the project can survive the loss of any single segment without cascading failure. It is the structural fact that makes the corridor a portfolio of assets rather than a single bet.

04

04 · THE CORRIDOR — THE AGGREGATE

The project is 32 segments of equal length, each 25 miles, spanning 800 miles of continuous right-of-way. Each segment operates independently; the aggregate is the sum of their hydraulic and electrical properties, not a dependency chain. Lose funding at segment 12 and segments 1 through 11 have independent utility and can be financed separately. This independence is structural and is the controlling de-risking feature of the plan.

The Gradient and Storage

The corridor runs from the donor basin to the Great Salt Lake. Water moves toward the lake along its entire length; the lake is the terminus, not the source.

The pumping load to move 1,000,000 acre-feet per year against this head requires 3.90 terawatt-hours of electrical energy annually, or 445 megawatts of continuous power. This is the baseline load that the corridor's generation must satisfy before any power reaches the grid.

The gradient permits collection pools at intervals along the route. A pool held at head stores energy, recoverable through reversible turbines at 80 percent round-trip efficiency. The corridor's storage capacity inverts the duty cycle from a liability into an asset. When solar generation is surplus, the pumps reverse and store water in the pools. When solar generation is absent, the pools release through turbines, generating power on demand.

The pools require covers to prevent evaporative loss. The solar canopy that generates power for the pumps is the same canopy that covers the pools. This structure performs three functions: generation, storage control, and evaporation prevention. The cost is borne once.

The Heat Ladder

The corridor is a linear structure with a continuous water flow at 40–50 degrees Fahrenheit. This cold is a utility, not a byproduct. The first tenant is a hyperscale data centre, which rejects heat at approximately 0.96 terawatt-hours per year per 100 megawatts of installed capacity. The data centre's cooling system uses the cold water directly, achieving a Power Usage Effectiveness of 1.10 compared to 1.30 for a wet cooling tower and 1.40 for a dry tower. This efficiency gain saves 20 megawatts of power and 1,662 acre-feet of water consumption annually per 100-megawatt facility.

The data centre's rejected heat arrives at 24–30 degrees Celsius. Controlled-environment agriculture—vertical farms, greenhouse operations—operates optimally at 18–24 degrees Celsius. The data centre's waste heat, after passing through a heat exchanger, supplies the greenhouse. The greenhouse's thermal mass and the passive geothermal effect of the buried structure reduce the cooling load further.

The third rung is aquaculture and algae cultivation at 24–30 degrees Celsius, using the same water stream after the greenhouse.

The fourth rung is anaerobic digestion at 35–38 degrees Celsius. The corridor's sewer system captures 100 percent of wastewater from the built core. Anaerobic digesters operating at mesophilic temperatures (35–38 degrees Celsius) process this sewage, producing biogas at approximately 27 megawatts of continuous thermal equivalent per 250,000 residents. The digesters also recover phosphorus and nitrogen and potassium. Phosphorus has no synthesis route and is mined from finite reserves; recovery from wastewater is a strategic commodity production.

The fifth rung is ambient-temperature irrigation and aquifer recharge. Water exits the system at or near ambient temperature and is available for agricultural use or return to the lake.

Each rung is chosen on temperature alone. The cascade emerges from the thermodynamic properties of the processes.

The Canopy and Found Head

The built core of the corridor is 100 to 200 feet wide and trenched approximately 30 feet below grade where feasible. The total right-of-way is 800 feet wide. The remainder of the 800-foot right-of-way is array only: fixed-tilt and tracking solar, wind turbines, and agrivoltaic crops in the footprint between turbine bases. The solar canopy over the built core and the collection pools covers the trenched utilities.

The precedent is Project Nexus, a canal-top solar installation in California operated by UC Merced. The Nexus project demonstrated that a canal carrying water for irrigation can support a solar array without structural modification to the canal itself, that the shade reduces evaporative loss from the water surface, and that the cooler air under the canopy reduces the ambient temperature in the surrounding area. The corridor applies this principle at scale: 800 miles of continuous canopy, with the added benefit that the water is moving at 40–50 degrees Fahrenheit.

The route selection criterion is found head. The corridor does not follow the shortest path; it follows the path that maximizes elevation gain relative to distance, subject to permitting and right-of-way constraints. Found head is head that exists in the landscape and requires no dam construction. The Indiana route, which is longer and flatter, requires constructed head and costs approximately $53 billion. The Utah route, which is shorter and steeper, requires less constructed head and costs approximately $27.7 billion. The difference is found head.

Generation and the Easement Width

The pumping load is 445 megawatts continuous. The corridor's solar and wind generation must satisfy this load before any power reaches the grid.

A standard large-diameter pipeline permanent easement is 75–100 feet wide. The corridor requires approximately 30 additional feet of width to generate the power necessary to pump the water. The easement width is the decision variable, and the width determines the revenue.

At 800 feet of total right-of-way width, the corridor carries 2,326 megawatts of average sellable generation after a 445-megawatt continuous pumping load. Fixed-tilt solar alone accounts for 1,779 megawatts of nameplate capacity within 128 feet of easement width. These figures are stated as a measure of what a right-of-way 0.15 miles wide can carry. They are not a claim about the state's electricity supply.

The corridor operates on an annual net zero energy basis. Solar does not generate at night, and the pumps operate continuously. The operating mode is: pump when power is surplus (typically midday), generate from storage when power is scarce (typically evening and night). The corridor is grid-connected by definition because it sells power to tenants and to the wholesale market. The real operation is surplus power sold at midday and power purchased from the grid at night. This is the optimal use of pumped storage.

The Built Core and Utilities

The built core is 100 to 200 feet wide and 800 miles long, occupying 14,545 acres or 22.7 square miles. The core is trenched approximately 30 feet below grade where feasible, and the trench contains five utilities in a single excavation:

Water serves as working fluid, coolant, and gravity battery. Electrical transmission carries power generated by the corridor to tenants and the grid, eliminating the need for a separate transmission right-of-way. Fibre optic cable serves the compute facilities and the control systems for the corridor itself; trenching accounts for 80–90 percent of fibre installation cost, and this cost is borne once. Natural gas distribution serves existing infrastructure and receives biogas from the digesters. Sewer collection captures 100 percent of wastewater from the built core and routes it to the digesters.

The maintenance model is novel in the American context: nothing is ever dug up again. Every street cut, every emergency excavation, every utility locate for the life of the corridor occurs in a corridor a person can walk down. This eliminates the cost and disruption of repeated excavation and the risk of utility strikes.

The Nodes and Independence

Each 25-mile segment is a node. A node consists of an intake, a terminus, a collection pool, a data centre campus, a greenhouse complex, and a section of the built core. Each node is financed independently and has independent utility. The utility of node 1 is conveyance: it moves water from the donor basin intake toward the state line. The utility of node 2 is the same, plus the power generated by the gradient between nodes 1 and 2. The utility of node 12 is conveyance, power, and the thermal services provided by the heat ladder. If funding for node 13 is not available, nodes 1 through 12 operate as a complete system, with node 12 serving as the terminus and the water returning to the lake or being used locally.

This independence is the reason the project can be financed in stages and the reason the loss of any single segment does not compromise the viability of the others. It is also the reason the project can be extended: each additional segment is a known cost with a known return.

05

05 · HIGH BASIN RULES AND THE RATE

The economic viability of a high-density compute facility in an arid corridor is determined by the ratio of energy-to-water consumption. For a 100 MW facility, the choice of cooling technology dictates the difference between a profitable operational margin and a terminal resource deficit. A wet-tower cooling stack requires approximately 1,662 AF/yr of water and consumes 30 MW of power to maintain a PUE of 1.30. A closed-loop, cold-pipe system requires 50 AF/yr and consumes 10 MW, achieving a PUE of 1.10. The difference—1,662 AF/yr and 20 MW—is the margin that determines the project's ability to fund its own replenishment.

The High Basin Rules do not function as a regulatory prohibition on technology, but as a commercial tariff that prices the cost of atmospheric loss. The project provides two distinct pricing tiers: a discounted rate for compliant, low-loss operations, and a gravity-taxed rate for evaporative operations. Because the project controls the primary inputs—the water and the power—the standard is enforced through the price of the commodity rather than through inspection.

THE THREE COMPLIANT PATHS

A tenant qualifies for the discounted tariff by selecting one of three technical paths. These paths ensure that the water remains within the basin's hydrological cycle, either through physical containment or through the prevention of atmospheric loss.

1. Closed Loop, De-natured Water

In this path, the tenant utilizes a closed-loop system where the water is treated to a de-ionized, mineral-free state. Because the water is de-natured, it is suitable for high-efficiency heat exchange without the risk of scaling. The water-to-load ratio is approximately 1:7,870. The primary cost of the water is the treatment; the volume consumed is negligible. The cost of this water is lower than the commodity rate, as the loss to the atmosphere is effectively zero. The supply of de-natured water is restricted to closed-loop tenants to maintain the integrity of the loop and the stability of the tariff.

2. Full Desalination Service

The tenant purchases a water-as-a-service model. The project provides a continuous, treated flow where the molecule remains in the project's custody. The tenant pays for the service of desalination and delivery rather than a volume of raw water. By maintaining custody of the water, the project ensures that the return-flow-to-lake ratio remains at the maximum theoretical efficiency. This path is a direct substitution for traditional industrial water use, returning nearly every gallon to the basin through the project's own recovery infrastructure.

3. The Dome: Capture

This path utilizes evaporative cooling within an enclosed, captured environment. The vapor generated by the cooling process is condensed and returned to the loop. This allows the tenant to utilize the efficiency of evaporative cooling while maintaining the hydrologic integrity of the basin. The capture mechanism ensures that the water is not lost to the atmosphere, but is instead recycled into the project's recovery-and-return infrastructure.

THE NON-COMPLIANT PATH: THE GRAVITY TAX

The third option is to utilize open, evaporative cooling to the atmosphere. This is not prohibited, but it is priced to reflect the cost of the commodity. Under the High Basin Rules, a tenant choosing an evaporative path is subject to the gravity-taxed rate.

Water lost to the atmosphere is priced at its replacement cost, because that is what it costs to replace. This is not a tax and not a penalty: it is the same cost-of-service principle applied to every other connection on the system, applied to a use that returns nothing. Because the project must fund the replenishment of the lake, the cost of replacing a gallon lost to the air exceeds the cost of a gallon delivered to a pipe. The atmospheric-loss rate ensures that the cost of the loss is borne entirely by the user creating it.

For a 100 MW facility, the logistics of a wet-tower system require approximately 989 truckloads of water-related logistics per day, compared to 46 truckloads per year for a closed-loop system. The atmospheric-loss rate is set to make the 989-truckload scenario economically inferior to the 46-truckload scenario. The tax recovers the cost of the lost volume.

THE REACH OF THE TARIFF

The legal and commercial structure of the project is split into two distinct jurisdictional reaches: the statute and the tariff.

The statute, as drafted in the Utah-specific legislation, governs the regulatory environment within the state. It establishes the baseline for the commissioner's authority and the legal standing of the watershed trust. It provides the legal floor for the project's existence within the state's jurisdiction.

The tariff is a commercial contract that governs the movement of the water itself. Because the project's infrastructure—the pipe and the power—crosses state lines, the tariff is the mechanism that carries the standard. The tariff is not legislation; it is a term of sale. Whether a tenant is in Utah or in a subsequent segment in a different state, the price of the water is tied to the method of its use. The standard travels with the water.

The decision to sign a power purchase agreement or a water-service agreement is a decision of resource-density. The corridor provides four scarce assets: generation, land, an immediate interconnection-free path to power, and a guaranteed water supply. The High Basin Rules ensure that the scale of the project—the 1,000,000 AF/yr target—is not a drain on the basin, but a mechanism for its recovery. By pricing the loss, the project makes the most efficient machine the most profitable machine.

06

06 · THE DONOR BASIN

The export ban and the evaporative rules do not apply in the donor basin. Utah Code §73-32-402 restricts the export of Great Salt Lake water and §73-32-409 governs the return fractions that determine how much of a diverted gallon comes back. Neither statute reaches beyond Utah's borders. In Indiana and Oklahoma, the water is subject to the withdrawal regimes of those states—registration in Indiana's case, riparian allocation in Oklahoma's—and to the interstate compacts that do not include them. The mechanism that moves water from the donor basin to Utah is not a diversion under Utah law. It is a storage-and-recovery arrangement under the Water Supply Act of 1958, which already exists as a statutory pathway for contracting federal reservoir storage.

Forecast-Informed Reservoir Operations (FIRO) is a joint program of the Army Corps of Engineers and Scripps Institution of Oceanography's Center for Western Weather and Water Extremes. FIRO operates at Lake Mendocino and Prado Dam. The mechanism is straightforward: a downstream water user contracts with the Corps to draw a federal reservoir down ahead of a forecast precipitation event. The empty storage absorbs the flood that would otherwise spill. The water that was drawn down moves through the system year-round, and the downstream user pays for the storage space and the operational cost of the drawdown. The Corps fulfills its statutory flood-control mandate. The downstream user receives water on a predictable schedule instead of a one-month window.

FIRO is an existing operational framework tested over a decade. It is the mechanism that already moves water in the western United States under federal authority.

The donor basin in this case is the Ohio River basin in Indiana and the Arkansas River basin in Oklahoma. Both basins are outside the Mississippi River Compact, which is currently being negotiated among ten states. Indiana and Oklahoma are not parties to that compact and are not subject to its restrictions. The water in their basins is not claimed by the compact states.

Both basins experience repeated flooding. Indiana's southern counties, which drain to the Ohio River, have experienced flooding events in 2008, 2011, 2019, and 2023. The Arkansas River basin in Oklahoma experienced a major flood in 2019. The Corps of Engineers maintains flood-control infrastructure in both basins under a statutory mandate to reduce flood damage. A storage-and-recovery contract with the Corps allows the Corps to fulfill that mandate while generating revenue for the federal government and providing water to a third party.

The Water Supply Act of 1958 authorizes the Secretary of the Army to contract with states and municipalities for the storage of water in federal reservoirs. The contract specifies the volume, the duration, the price, and the operational rules. The stored water is the property of the contracting party for the duration of the contract. The Act has been used for municipal water supply, irrigation, industrial use, and interstate transfers. It is a settled mechanism with an established legal framework.

The Goldfields Water Supply Scheme has moved water from Perth to Kalgoorlie in Western Australia since 1903. The scheme is approximately 330 miles long and uses eight staged pump stations. It has operated continuously since then to support mining operations in the interior. It is the successful comparable that shares this plan's architecture: a long-distance pipeline, multiple pump stations, a national government as the contracting authority, and a donor basin that benefits from flood control and contract revenue.

Renewable Water Resources, a proposal to move water from the San Luis Valley in Colorado to the Front Range, died not on engineering or capital grounds but on donor-basin consent. The San Luis Valley is an agricultural region. The proposal would have exported water that the valley's farmers depended on. The state of Colorado opposed it. The project could not proceed without the consent of the donor basin.

The donor basin must benefit from the transaction. The benefit cannot be theoretical, environmental, or deferred. It must be immediate, measurable, and material.

In Indiana, the benefit is flood absorption. The Corps of Engineers maintains a database of flood damage by county and by year. A storage-and-recovery contract that draws down a federal reservoir ahead of a forecast event reduces the peak flow in the river and reduces the flood damage downstream. The benefit to the county is the reduction in flood damage. The county experiences that benefit in the form of reduced insurance costs, reduced infrastructure repair costs, and reduced business interruption.

In Oklahoma, the benefit is the same. A storage-and-recovery contract that draws down a federal reservoir ahead of a forecast event reduces the peak flow in the river and reduces the flood damage downstream.

The secondary benefit in both basins is property tax revenue. The plan requires the construction of intake facilities, pump stations, and associated infrastructure in the donor basin. These facilities are real property subject to property tax at the county's own rate. That revenue is contingent on the construction of the facilities, which is a condition of the contract.

The contract is structured so that the donor basin cannot be harmed. The water that is drawn down is water that would otherwise flood. The water that is recovered is water drawn from federal storage, not from the donor basin's aquifer or surface water. The donor basin's water rights are not diminished. The donor basin's water supply is not reduced. The donor basin's farmers and municipalities continue to use the water they have always used. The only change is that the federal government operates its reservoirs in a way that reduces flood damage and generates revenue.

The Water Supply Act of 1958 requires the consent of the state. Indiana and Oklahoma must agree to the contract. The governor must sign it. The legislature must appropriate the funds if any state funds are required. The contract is negotiated with the donor basin, not imposed on it. The donor basin has the power to refuse.

The plan does not propose to take water from Texas or Kansas. Both states are currently rationing their own water supplies. Kansas is proposing a reduction in pumping over twenty years. Texas is experiencing the steepest single-year decline in the Ogallala Aquifer on record. Neither state can consent to an export because neither state has water to export. The physical reality is the barrier.

Indiana and Oklahoma have water to spare because they flood. They flood because they receive more precipitation than they can use. The mechanism that moves that water to Utah is the same mechanism that reduces their flood damage. The donor basin benefits from the transaction. The donor basin consents to the transaction.

In Oklahoma, groundwater is allocated to the overlying landowner under state law. If water is recharged into an Oklahoma aquifer, the recharged water is by default the property of the landowner who owns the land above it. No storage-and-recovery regime exists in Oklahoma law. The recharged water is a gift unless the state enacts a statute that treats it differently.

This is not a problem for the plan's first phase, which draws water from federal surface storage and does not recharge an aquifer. It is a problem for later phases if the plan expands into Oklahoma groundwater storage. The plan has three options: own the land above the aquifer, enact a statute on the template of Utah Code §73-32-409(6)(b) that treats recharged water as the property of the recharging party, or never recover the recharged water and treat it as a gift to the overlying landowner. These options are priced in that order. The most expensive is to own the land. The least expensive is to give the water away. The middle option is to negotiate a statute with the state of Oklahoma. This question is open and is resolved before the plan enters the second phase of expansion into Oklahoma groundwater.

The first phase proceeds under the Water Supply Act of 1958 and under FIRO, which is an existing mechanism with an established legal framework. The donor basin consents because the donor basin benefits. The contract is negotiated, not imposed. The precedent is successful. The mechanism is settled.

07

07 · THE LEGISLATIVE SEQUENCE

The strategy is a two-stage sequence: a surgical legislative strike to establish regulatory-market conditions, followed by the 2027 creation of the Infrastructure Authority. The first stage is the "Short Bill"—a four-provision, zero-appropriation legislative vehicle designed to establish the legal and political baseline for the project. The second stage is the "Long Bill"—the 2027 expansion into the full-scale infrastructure authority.

The Short Bill is not a substitute for the project; it is the mechanism that makes the project possible. It is designed to pass within the current or upcoming legislative cycle, utilizing the interim-committee calendar to shape the debate before the full session convenes. Because it carries no appropriation and targets a single, high-salience industry, it is a low-cost, high-leverage entry point.

The Two-Stage Sequence

The relationship between the two bills is one of sequence, not compromise. The Short Bill creates the "Findings"—the permanent, legislative record of fact that provides the legal authority for the Long Bill.

The Short Bill consists of four provisions:

1. No potable water to a thermal load facility for heat rejection (§410(3)): This is the non-tradeable core. It regulates the use of public water supplies for industrial cooling. It is a regulatory baseline, not a subsidy.

2. No evaporative cooling at a thermal load facility (§410(4)): This is the tradeable provision. It is the provision that will be negotiated in committee to secure the grid-contribution requirement.

3. Waste heat recovery/offer obligation (§410(2)(d)): This is the market-maker. It mandates that heat above a specific grade must be offered to adjacent takers. This provision creates the thermal-service economy.

4. Generation at 1.5× peak load: This ensures that every new industrial load is a net-positive contributor to the grid, rather than a drain on capacity.

The Short Bill is designed to focus the debate on a single sector. By concentrating on industrial cooling, the coalition remains broad and the political cost remains low. The scale of the project is not the subject of the Short Bill; the regulatory environment is.

The Long Bill, scheduled for 2027, is the realization of the infrastructure. It is the creation of the Authority to manage the 1,000,000 AF/yr conveyance. The Long Bill is the full-scale implementation, but it cannot exist without the regulatory foundation of the Short Bill.

The Strategy of Findings

The most critical component of the Short Bill is not its operative text, but its "Findings." In legislative practice, an amendment can strip a provision, but it rarely strikes a "Finding" that has been entered into the record. The Short Bill is drafted to embed specific, empirical findings into the state's permanent record.

The primary finding is that a zero-return use is a greater consumptive use than a partial-return use, regardless of the user's classification. This is the legal mechanism that allows the 2027 Authority to address the 65% agricultural depletion (per the 2026 Strike Team data). By establishing this finding in the Short Bill, the legislature provides the legal cover to apply the same logic to the larger-scale water-use shifts in the Long Bill.

The Short Bill's findings serve two purposes:

1. They establish the arithmetic once, in statute. A legislative finding that a use returning no portion of the water applied is a greater consumptive use than one returning a portion — stated without regard to purpose or to the classification of the user — is available to every bill that follows. Findings are not fiscally scored and are rarely amended out. ⚠ The 4,200-foot floor discussed in this section is not yet drafted into the bill; the instrument currently carries the 4,205-foot target alone.

2. They protect the project from litigation. A finding that is part of a passed law is a matter of legislative fact. When the two-stage sequence reaches the 2027 scale, the "Findings" will be the primary defense against challenges to the Authority's mandate.

The Split: Trading the Negotiable for the Core

The "Split" is the deliberate media and legislative strategy of the Short Bill. It recognizes that the negotiable provisions and the core requirements serve different roles.

The negotiable provisions—the regulation of evaporative cooling and the mandate for heat recovery—are what the industry will contest. These are the provisions that will be the subject of committee-level negotiation. The core requirement—the 1.5× peak load generation and the prevention of water loss—is what the public and the legislature will support.

The strategy is to lead with the core requirement to build a broad coalition, and then use the negotiable provisions as the subject of committee discussion. The goal is to arrive at a version of the bill that is technically feasible and economically manageable, while preserving the core requirement. The core requirement is never traded away.

The "Split" allows the project to move through the legislative process without the weight of the full-scale infrastructure. It allows the political cost to be distributed over two cycles. The Short Bill is the foundation that makes the Long Bill possible.

The Target and the Floor

The relationship between the 4,200 ft floor and the 4,205 ft target is the final piece of the sequence. The 4,205 ft target is the goal of the 1,000,000 AF/yr project. The 4,200 ft floor is the regulatory constraint.

The 4,200 ft floor is the level at which the lake's ecological and economic functions are preserved. The 4,205 ft target is the goal of the infrastructure. The five-foot gap is the operational margin.

The 4,205 ft target is the baseline for the 2027 Authority. The 4,200 ft floor is the baseline for the 2025 Short Bill. By setting the floor at 4,200 ft, a clear boundary is established for the regulatory environment. The 4,205 ft target is the metric by which the success of the infrastructure will be measured. The gap is the buffer that allows for the operational reality of the project.

The sequence is complete. The Short Bill establishes the rules of the game; the Long Bill plays the game. The findings of the first become the authority of the second.

08

08 · CAPITAL AND STRUCTURE

The project is structured as two distinct assets sharing a single, continuous right-of-way. This separation is a requirement of federal credit eligibility and is the primary mechanism for managing the project's capital-intensive nature. The physical reality is a single easement; the legal and financial reality is two borrowers.

The Two-Borrower Structure

The project divides into two primary assets: the Water Conveyance (the Pipe) and the Energy Corridor (the Generation). While they occupy the same footprint, they are governed by different regulatory frameworks, different revenue models, and different federal funding-eligibility rules.

Asset A: The Water Conveyance (The Pipe)

• Function: Transport of water from source to terminal basin.
• Primary Revenue: power sales, thermal service, and water delivery at cost of service.
• Primary Funding Source: WIFIA (Water Infrastructure Finance and Innovation Act).
• Constraint: WIFIA is strictly for water-related infrastructure. If the solar-generation assets were integrated into the water-conveyance entity, the energy-specific credits and guarantees would risk classification as an ineligible "benefit" to a water project.

Asset B: The Energy Corridor (The Generation)

• Function: Generation and transmission of renewable energy via the solar-over-pipe and wind-on-easement infrastructure.
• Primary Revenue: Power Purchase Agreements (PPAs) and Investment Tax Credits (ITC).
• Primary Funding Source: DOE Title 17 (Loan Guarantees).
• Constraint: Title 17 disallows projects that have benefited from other federal grants or loan guarantees. By maintaining the Energy Corridor as a separate borrower from the Water Conveyance, the project ensures that the energy-only assets remain eligible for DOE-specific credit, even as the water-conveyance assets utilize WIFIA.

The physical reality of the corridor allows energy-generation assets to be built on the existing, permitted, and surveyed footprint of the water-conveyance assets. This means the hardest input in the energy business—the right-of-way—is a by-product of the water business. The two-borrower structure allows the project to capture the maximum available federal credit from both the EPA and the DOE without the assets being stacked into a single, ineligible pool.

The Economic Driver: Discount-Rate Sensitivity

The project is not price-sensitive; it is discount-rate sensitive. The cost of capital is the controlling variable. The primary driver of the project's viability is the spread between the cost of debt and the rate of return on the infrastructure-grade assets.

The project's return is modeled on infrastructure-grade returns. The delivered cost of $1,171/AF is significantly lower than the current SLC commercial summer rate ($1,821/AF) and the household top-tier rate ($2,586/AF), providing a wide margin in the delivery-cost-to-revenue ratio. This margin is the baseline for the water-conveyance-only model.

The project's ability to absorb higher discount rates is its primary defense against market volatility. The return on investment is driven by the scale of throughput and the stability of substitution-based revenue. Because the project is designed to replace existing, high-cost water-use scenarios with lower-cost, high-return-fraction delivery, the return is built into the delta between the current cost of water and the project's delivered cost.

The NPV at 3% is +$15.6 bn; at 4%, +$9.4 bn; at 5%, +$5.1 bn; at 6%, +$1.9 bn. The project turns negative at 7% discount rate.

Capital Recycling and the Financing Ladder

The capital-intensive nature of the initial build requires a structured approach to debt servicing and capital recycling. The project is designed to move from a high-cost construction phase to a low-cost, stabilized-operation phase.

The Financing Ladder

1. The Seed (State-Level Appropriation): The initial appropriation of $25,000,000 from the State of Utah creates the Authority. This capital funds the $25 M hydrology study, the legal establishment of the entity, and the filing of federal applications.

2. The Primary Build (WIFIA/Title 17): The bulk of capital is raised through the two-borrower split. WIFIA covers the water-conveyance-only costs; Title 17 covers the energy-corridor-only costs.

3. The Balance (Green Bonds): Remaining capital requirements are met through private-market issuance of ICMA-aligned Green Bonds, backed by the combined, but segregated, revenue streams of the two assets.

Capital Recycling (Illustrative)

As the project reaches operational stability and the seasoning period for federal loans is complete, the project will move toward capital-recycling strategies. The following is an illustrative model of debt-load management:

Phase	Action	Illustrative Rate
Phase 1: Construction	Build-out of segment one and initial corridor	6.0% (Targeted)
Phase 2: Seasoning	Stabilization of delivery and PPA contracts	N/A
Phase 3: Refinance	Refinancing of construction debt into long-term bonds	4.5% (Targeted)

Note: The 4.5% refinance rate is an illustrative target for modeling purposes and is not a guaranteed rate. The 6.0% build rate is the projected cost of capital during the initial capital-outlay phase.

The Role of Sovereign-Land Revenue

The project's ability to service its debt is further supported by revenue generated from management of the sovereign-land easement. The project is not merely a conduit for water and power; it is a manager of a high-value, linear-asset corridor.

Revenue from easement management—including agrivoltaics, agroforestry, and other permitted-use activities—is structured to provide a secondary, non-correlated revenue stream. This revenue is categorized as sovereign-land revenue and is used to offset the operational costs of the maintenance-access corridor.

In the event of a shift in primary revenue streams (e.g., a change in the water-delivery rate), sovereign-land revenue provides a buffer. This revenue is not a subsidy but a direct result of efficient use of the linear footprint. The project is designed so that the cost of maintaining the easement is partially offset by the assets that occupy it.

Risk and Constraint Management

The structure of the project is designed to mitigate the two greatest risks to large-scale infrastructure: regulatory rejection and capital shortfall.

Regulatory Rejection (The Split-Asset Defense)

By maintaining two separate borrowers, the project prevents a single regulatory decision from collapsing the entire capital stack. If a federal-agency ruling affects the energy corridor's eligibility, the water-conveyance asset remains intact and operational. If a water-policy shift affects delivery rates, the energy-corridor assets remain a viable, independent revenue generator.

Capital Shortfall (The Scaling Defense)

The project is built in segments. Each segment stands alone—lose funding at segment 12 and you have 11 working data centers. The incremental-build model ensures that the project can scale according to the availability of federal-credit windows and the rate of private-market absorption.

The Cost of Interest

The capital-requirement figures provided in the financial models exclude construction-period interest. The payback period and the delivered cost per unit of water are calculated based on principal capital outlay. The simple payback is 22 years (Utah) and 27 years (Indiana). The impact of construction-period interest is a variable that will be addressed in the final debt schedule and refinance plan.

Summary of the Capital Position

The project is a dual-asset, single-easement investment. It leverages the physical reality of the corridor to maximize the legal reality of the capital stack.

• The Water-Conveyance Asset provides the base-load infrastructure and the primary revenue driver.
• The Energy-Corridor Asset provides the high-margin growth potential and the secondary revenue driver. Water is approximately 17% of segment revenue; power is the money.
• The Two-Borrower Structure ensures that the project can access the full breadth of federal-credit programs without the risk of cross-asset disqualification.

The project is not a single, massive capital ask. It is a series of segmented, manageable investments that build a permanent infrastructure corridor. The return is not found in the value of the water, but in the efficiency of the delivery and the stability of the discount-rate environment.

09

09 · REVENUE AND RETURN

The project's largest revenue line is power. Water is approximately 17 percent of segment revenue — $14.6 million a year against $28.7 million from generation — and the plan is built on that ordering rather than against it. Water revenue comes from the spread between delivered cost and existing municipal and industrial rates, and it is a real line; it is not the line the asset depends on. Because the cost of delivery is fixed by the physics of the gradient, the project is not price-sensitive; it is discount-rate sensitive.

THE REVENUE MODEL

The revenue model rests on four categories: power, water substitution, thermal service, and assets that are named but not priced.

Primary: Water Substitution

The core revenue is generated by the sale of water to municipal and industrial users at a rate below their current marginal costs. The delivered cost is $1,171/AF. In the Utah corridor, the water counterparties are municipal and industrial users. The revenue is captured by displacing existing high-cost water use. Because the project delivers water to the terminus, it facilitates a substitution: for every acre-foot of water sold to a municipal user, the return to the lake is maximized by the displacement of higher-loss-fraction uses (such as residential irrigation).

Secondary: Thermal Service

The project generates a secondary revenue stream through the sale of rejected heat to data center tenants. At a price of $25/MWh, the thermal service generates $18.0 M/yr per node. This is priced against comparable industrial heat-offtake-as-a-service models, such as those utilized in Stockholm and Toronto. This revenue is independent of the water-delivery-to-power ratio and provides a secondary margin to the infrastructure-grade returns.

Ancillary: Unpriced Assets

The following assets are integral to the project's physical footprint but are assigned no revenue in this model to ensure the base case remains conservative:

• Pumping Load: The 445 MW continuous pumping load is an essential operational requirement and an ancillary-services-capable asset. It is named as a load, but its potential value in frequency regulation or grid-balancing is unpriced.
• Dark Fibre: The conduit capacity represents a potential stage-two revenue stream. It is named as a capacity-ready asset but is assigned a value of $0 to prevent the inflation of the current-period NPV.
• DI Water: The production of $0.3 M/yr per node in deionized water is an operational byproduct. It is not a revenue line; it is a cost-offset or a secondary byproduct of the cooling process.

THE REVENUE AND RETURN TABLE

The following table compares the full-build base case against a single-segment deployment to demonstrate scalability and the impact of the capital-to-revenue ratio.

Metric	Corridor (32 segments)	One node, standalone
Total capital deployed	$27.7 bn	$1.0 bn
Fully built	Year 12	Year 1
Power	—	$28.7 M/yr
Water margin	—	$14.6 M/yr — approximately 17% of revenue
Thermal service	—	$18.0 M/yr
Replenishment credit	—	$20.4 M/yr — ⚠ $0 on the Utah leg
DI water	—	$0.3 M/yr — not a revenue line
Dark fibre; pumping as ancillary services	—	named, unpriced
Total revenue	—	$65.0 M/yr merchant · $84.1 M/yr time-to-power
Net of the credit	—	$44.6 M/yr · $63.7 M/yr
Simple payback	Year 22 (Utah) · Year 27 (Indiana)	15.4 yr · 11.9 yr — net of credit 22.4 yr · 15.7 yr
Cumulative cash, year 50	$54.7 bn (undiscounted)	—

Power is the largest single line and water is roughly a sixth of revenue. That ordering is the

central finding of this plan and it is what distinguishes the asset from a water transfer: the

project does not depend on selling water to earn, and it does not depend on earning to deliver water

to the lake.

⚠ The corridor column is drawn from the 32-segment deployment model and the node column from the

standalone-node model. They are different bases and have not been reconciled to a single set of

books; the completed-segment revenue figure of $59 M/yr and the node figure of $65.0 M/yr are not

the same quantity. A single reconciled model is owed before this table is relied on.

Note: Segment 1 assumes completion of intake and terminus works. The $59M/yr figure represents completed segment revenue. Segment 1 capital of $1.35 bn includes intake and terminus; segments 2–32 are modeled at $850 M each. Simple payback excludes construction-period interest.

THE LOGIC OF SUBSTITUTION

The economic viability of the project is found in the spread between the delivered cost and the existing municipal-industrial rate. The project does not create a new market; it enters an existing one where the cost of water is already being paid at a higher rate.

In the Salt Lake City area, water cost is tiered. The current municipal-industrial rates provide the ceiling for the project's revenue potential. The SLC commercial summer rate is $1,821/AF and the household top-tier rate is $2,586/AF. At a delivered cost of $1,171/AF, the project provides a measurable saving to the end-user.

The return to the lake is a function of the substitution ratio. Because the project targets the displacement of existing uses, the return-flow fractions are critical. The model assumes the following estimated return fractions:

• Indoor use: ~95%
• Pools: ~70%
• Lawn: ~12%

When the project sells an acre-foot of water to a municipal user, it does not add a new loss to the basin; it substitutes a high-loss-fraction use with more efficient delivery. In the case of a residential-to-municipal substitution, the net effect on the lake is the recovery of the difference between the previous loss and the new, more efficient delivery. These fractions are estimates; the plan commits to publishing measured fractions as open data derived from §73-10-34 metering and CVWRF records.

THE REPLENISHMENT CREDIT AND THE UTAH CASE

In the Utah leg, the replenishment credit is valued at $0. The mandate of §408 ensures that the credit does not function as a revenue-generating mechanism for Utah-based assets. §408's requirement fails additionality; the credit is worth zero on the Utah leg.

In the donor-state leg, the replenishment credit is valued at $20.4 M/yr per node (priced at $1,303/AF, Bonneville Environmental Foundation WRC at $4/kgal). This is a thin-market asset. The credit is subject to the availability of regulatory-driven credits. Because the market for these credits is narrow, the model treats the credit as a secondary benefit rather than a primary driver of base-case returns. Node economics are always shown net of the credit. The primary revenue remains the water-substitution delta.

THE SENSITIVITY OF THE RETURN

The project's returns are not sensitive to the price of water, as the municipal-industrial rates provide a significant buffer. Instead, the project is sensitive to the discount rate applied to capital deployment.

The capital-intensive nature of the project means that the primary risk is the timing of deployment versus the timing of revenue catch-up. The project requires significant capital deployment before the full-scale revenue of the 32-segment build is realized.

The project is highly profitable at the rates typical of public-sector or infrastructure-grade debt. It becomes loss-making at the rates required by private equity or venture-scale capital.

Discount Rate	NPV at Year 50	Status
3%	+$15.6 bn	Positive (Federal Credit/WIFIA)
4%	+$9.4 bn	Positive (Public/Green Bond)
5%	+$5.1 bn	Positive (Investment-Grade Debt)
6%	+$1.9 bn	Positive (Infrastructure Equity)
7%	Negative	Negative (Private Equity Hurdle)

The project is designed for the 3% to 5% range. At these rates, the project provides a decisive social and economic return. At the 7% threshold and above, the project does not meet the requirements of private-sector-only capital. The project is an infrastructure-scale asset, not a venture-scale play.

10

10. RISK REGISTER

The project succeeds or fails on the resolution of fourteen material uncertainties. This section names each, states what breaks at its failure, and identifies who resolves it and when. A risk that is disclosed early is a risk that can be priced. A risk disclosed late is a risk that cannot.

Hydrologic Sufficiency

The risk: The project is sized at 1,000,000 acre-feet per year. The Great Salt Lake Strike Team, convened by the Gardner Policy Institute, University of Utah, and Utah State University, estimates the lake's deficit at 800,000 acre-feet annually to reach a healthy minimum elevation of 4,198 feet. Our target is 125 percent of that stated need. The margin exists as headroom against uncertainty in the Strike Team's own modeling and as optionality to reach the bill's stated target of 4,205 feet rather than the state's 4,198-foot recommendation. However, the 1,000,000 acre-foot figure itself has not been independently verified against the basin's actual hydrologic balance.

What breaks: The project's NPV at a 5 percent discount rate depends on the accuracy of the 1,000,000 acre-foot target. The project remains positive across a range of plausible deficits but loses fundable margin if the true deficit is materially smaller than estimated.

Who resolves it and when: The $25,000,000 hydrology study appropriated in the bill (§14) will establish the basin's water balance at monthly resolution across a 50-year hindcast and a 50-year forward projection under three climate scenarios. The study will be conducted by the U.S. Geological Survey in partnership with the Utah Division of Water Resources and will be completed within 24 months of appropriation. The project's financing will not close until the study is complete and the 1,000,000 acre-foot target is either verified or adjusted. If adjustment is required, the capital plan will be remodeled and the prospectus will be updated before any segment enters construction.

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NEPA Independent Utility and Litigation Posture

The risk: The project comprises 32 segments, each capable of operating independently. This modularity allows the project to proceed incrementally, to refinance as capital costs decline, and to survive the loss of funding for any single segment. It is also a vulnerability in federal permitting. The National Environmental Policy Act requires that an agency not segment a project to avoid preparing a single environmental impact statement. If a challenger argues that segments 1 through 32 are a single "connected action" and that the government approved segment one without analyzing the cumulative effects of all 32, the entire project can be enjoined pending completion of a full EIS.

What breaks: An injunction would delay segment one, breaking the financing and forcing a restart.

Who resolves it and when: The independent-utility record must be built before litigation, not after. Each segment's permitting documents—the Record of Decision, the biological opinion, the water-rights determination—will state explicitly that the segment is economically viable, hydrologically complete, and environmentally justified on its own merits. The financing documents for segment one will cite these determinations as the basis for the segment's existence. This record will be complete and in the administrative file before segment one enters construction. The record will be built by the project's counsel in coordination with the Bureau of Reclamation and the U.S. Army Corps of Engineers, and will be complete within 12 months of the bill's enactment.

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Route Alignment and Right-of-Way Cost

The risk: The project's capital cost is $27.7 billion for the Utah corridor (intake to terminus, 800 miles) and approximately $53 billion for the Indiana route (1,550 miles). The difference is not merely distance; it is the number of counties crossed, the density of existing infrastructure, the prevalence of agricultural versus urban land, and the political economy of right-of-way acquisition in each state. The alignment study has not yet been completed. Until it is, the route length is uncertain, the right-of-way cost is unpriced, and the capital plan is illustrative.

What breaks: A route-length error of 500 miles changes the capital plan by $24 billion. A right-of-way cost error of 20 percent changes it by $5 billion. Either error is material to the financing decision. The project cannot be funded until the route is known.

Who resolves it and when: The alignment study will be completed by the project's engineering team in coordination with the Bureau of Reclamation and will identify the preferred route, the alternative routes, and the cost of right-of-way acquisition for each. The study will be complete within 18 months of the bill's enactment. Until the study is complete, no county, reservoir, intake, or quarry site will be named in any project document. The capital plan will be updated when the study is complete, and the prospectus will be revised accordingly.

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Return-Flow Fractions and Measurement

The risk: The project's economics depend on the assumption that water sold for indoor use returns 95 percent to the lake, water sold for pool use returns 70 percent, and water sold for lawn use returns 12 percent. These fractions are estimates derived from historical data and hydrologic modeling. They have not been measured directly in the basin. If the true indoor return fraction is materially lower, the project's net contribution to the lake falls and the project's purpose is materially compromised.

What breaks: A material error in the return fractions reduces the project's net contribution to the lake. At the extreme—if all three fractions are at the pessimistic end of their ranges—the project's net contribution falls and the project no longer reaches the state's stated need of 800,000 acre-feet.

Who resolves it and when: Utah Code §73-10-34 requires that all water rights be metered. The Central Valley Water Reclamation Facility, Utah's largest treatment plant at 75 million gallons per day, already meters its discharge to the Great Salt Lake and to municipal and industrial users. The project will establish a measurement protocol that uses CVWRF discharge data, municipal billing records, and basin-wide evapotranspiration modeling to derive the actual return fractions for each use category. The protocol will be published as open data and will be updated annually. The first measurement will be complete within 24 months of the project's first water sale. The fractions used in this prospectus will be updated when measured data becomes available, and the project's net contribution will be recalculated and published. Until measured data is available, every appearance of the 95/70/12 fractions will be labeled as an estimate.

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Replenishment Credit Additionality and Market Depth

The risk: The project generates replenishment credits under the Bonneville Environmental Foundation's Water Restoration Certificate program, priced at $4 per thousand gallons, or approximately $1,303 per acre-foot. However, the credits are worth this price only if they are additional—that is, only if the water returned to the lake would not have been returned absent the project. Utah Code §408, which mandates the project, does not require additionality; it requires only that the project return water to the lake. Because the project is mandated, the water would be returned regardless of whether credits are sold. The credits are therefore not additional, and their market value is $0 on the Utah leg of the project. The Indiana leg, which is not mandated, may generate additional credits, but the market for water restoration credits is thin and the price is volatile.

What breaks: If replenishment credits are assumed to be worth $1,303 per acre-foot and are actually worth $0, the node's annual revenue falls and the node's yield falls. The project remains positive but loses return. More critically, if the project is financed on the assumption that credits are worth $1,303 per acre-foot and the market reprices them to $0, the project's debt service becomes unsustainable and the project defaults.

Who resolves it and when: The project will be financed on the assumption that replenishment credits are worth $0 on the Utah leg. The node's revenue will be calculated net of the credit—that is, the credit will be treated as a bonus if it materializes, not as a revenue line item. On the Indiana leg, credits will be modeled at $1,303 per acre-foot, but the financing will include a stress test in which the credit price falls to $0 and the project's debt service remains sustainable. The stress test will be completed by the financial advisor before segment one enters construction. If the credit market reprices materially downward, the project's financing will be restructured to reflect the new price before any segment enters construction.

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Donor-State Aquifer Ownership and Recovery Rights

The risk: The project will recharge treated water into aquifers in Oklahoma and Indiana to create storage capacity for later recovery. In Oklahoma, groundwater is allocated to the overlying landowner under the rule of capture. No storage-and-recovery regime exists in Oklahoma law. Recharged water is by default a gift to the overlying landowner, and the project has no legal right to recover it. The project could acquire the overlying land, but the cost of acquiring farmland is material. Alternatively, the project could seek an act of the Oklahoma legislature to create a storage-and-recovery regime, but the political economy of that request is uncertain. Alternatively, the project could accept that the recharged water is a gift and never recover it, but then the project is not storage; it is permanent transfer, and the project's economics change materially.

What breaks: If the project cannot recover recharged water in Oklahoma, the project's storage capacity falls and the project's ability to manage seasonal variation falls by the same amount. The project remains viable but becomes less flexible and less valuable. If the project must acquire overlying land, the capital cost rises and the delivered cost rises. If the project must seek an act of the Oklahoma legislature and the legislature declines, the project cannot proceed on the Indiana route and must be restructured to use the Utah corridor only, reducing the project's scale and its economics.

Who resolves it and when: The project will pursue three options in order of preference: (1) acquire the overlying land in Oklahoma and Indiana, (2) seek an act of the Oklahoma legislature to create a storage-and-recovery regime modeled on Utah Code §73-32-409(6)(b), or (3) accept that recharged water in Oklahoma is not recoverable and restructure the project accordingly. The land strategy will be developed by the project's counsel and land advisors and will be complete within 12 months of the bill's enactment. If option 1 is selected, the land acquisition will be priced and included in the capital plan. If option 2 is selected, the legislative effort will begin immediately and will be complete before segment one enters construction. If option 3 is selected, the project's storage model will be rerun and the prospectus will be updated.

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Dormant Commerce Clause and Takings Exposure

The risk: Utah Code §402 prohibits the export of water from the state except as provided by law. The project is an export, and it is provided by law—the bill itself. However, the dormant Commerce Clause of the U.S. Constitution prohibits states from discriminating against interstate commerce. If a challenger argues that §402 is an unconstitutional export ban, the project's legal foundation is compromised. The precedent is Sporhase v. Nebraska (1982), in which the Supreme Court held that groundwater is an article of commerce and that a state cannot ban its export absent a showing of genuine local concern and the absence of less discriminatory alternatives. Utah's genuine local concern is the Great Salt Lake's survival. The absence of less discriminatory alternatives is the project's entire premise—the lake cannot be saved by conservation alone. However, the case is not certain, and litigation would delay the project.

What breaks: If §402 is struck down as unconstitutional, the project's legal authority is eliminated and the project cannot proceed. If the project is enjoined pending resolution of the constitutional question, the project is delayed, breaking the financing. If the project is allowed to proceed but the constitutional question is not resolved until after segment one is complete, the project's refinancing is jeopardized because lenders will not refinance a project whose legal foundation is in litigation.

Who resolves it and when: The project's counsel will prepare a dormant Commerce Clause and takings memorandum before segment one enters construction. The memorandum will analyze Sporhase and its progeny, will articulate the genuine local concern (the Great Salt Lake's survival), will demonstrate the absence of less discriminatory alternatives (conservation alone is insufficient), and will conclude that §402 is constitutional as applied to this project. The memorandum will be published and will be available to any challenger. If a challenger files suit, the memorandum will be the government's opening brief. The memorandum will be complete within 12 months of the bill's enactment. If the memorandum concludes that the constitutional risk is material, the project's counsel will recommend that the bill be amended to clarify the export authority before segment one enters construction.

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Water Supply Act Storage Contracting

The risk: The project will use federal reservoir storage under the Water Supply Act of 1958 to manage seasonal variation and to create the capacity to deliver 1,000,000 acre-feet per year. The Water Supply Act allows the Secretary of the Interior to contract for storage in federal reservoirs, but the statute does not explicitly authorize pre-drawdown—that is, the withdrawal of water from a reservoir before the reservoir is full, with the understanding that the water will be replaced later. The project's pre-drawdown mechanism is modeled on Forecast-Informed Reservoir Operations (FIRO), which is already in use at Lake Mendocino and Prado Dam under a partnership between Scripps Institution of Oceanography's Center for Western Weather and Water Extremes and the U.S. Army Corps of Engineers. FIRO uses seasonal forecasting to optimize reservoir operations and to create storage capacity without physical expansion. However, the Water Supply Act's applicability to FIRO-style operations has not been tested in court, and the threshold at which the Corps must obtain congressional authorization for a new storage contract is unclear.

What breaks: If the Water Supply Act does not authorize pre-drawdown storage, the project must obtain a separate act of Congress for each storage contract, and the project's permitting timeline extends materially. If the threshold for congressional authorization is lower than the project's storage requirement, the project must obtain multiple acts of Congress, and the timeline extends further. If Congress declines to authorize the storage contracts, the project cannot proceed.

Who resolves it and when: The project's counsel will prepare a Water Supply Act memorandum in coordination with the Bureau of Reclamation and the U.S. Army Corps of Engineers. The memorandum will analyze the statute, will review the FIRO precedent, and will determine whether the project's pre-drawdown mechanism fits within the existing authority or requires congressional authorization. The memorandum will identify the threshold at which congressional authorization is required and will estimate the timeline for obtaining it. The memorandum will be complete within 12 months of the bill's enactment. If congressional authorization is required, the project's counsel will draft the necessary legislation and will coordinate with the project's legislative team to introduce it before segment one enters construction.

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Construction-Period Interest and Debt Schedule

The risk: The project's simple payback is 22 years for the Utah corridor and 27 years for the Indiana route. These figures exclude construction-period interest—the interest accrued on debt during the construction phase, before the project generates revenue. Construction will take approximately 8 years for the Utah corridor and 10 years for the Indiana route. During this period, the project will accrue interest on the capital cost at an assumed rate of 4.5 percent. This interest must be capitalized into the project's debt or paid from reserves, and it materially affects the project's delivered cost and payback period. The project's financial model has not yet incorporated a detailed debt schedule that accounts for the timing of construction draws, the timing of revenue generation, and the capitalization of construction-period interest.

What breaks: If construction-period interest is capitalized into the project's debt, the delivered cost rises and the simple payback extends. The project remains positive but loses margin. If construction-period interest is paid from reserves, the project's equity requirement rises and the project's capital structure becomes less efficient.

Who resolves it and when: The financial advisor will prepare a detailed debt schedule that incorporates the timing of construction draws, the timing of revenue generation, and the capitalization of construction-period interest. The schedule will be complete before segment one enters construction. The delivered cost and payback figures in this prospectus will be updated to reflect the debt schedule, and the caveat that construction-period interest is excluded will be removed. If the debt schedule materially changes the project's economics, the prospectus will be revised before any segment enters construction.

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Conflict Disclosure

The risk: The project's sponsors include entities that will benefit from the project's success—water utilities that will sell water, energy companies that will generate power, technology firms that will provide cooling and heating services. These entities have a financial interest in the project's approval and financing. If this interest is not disclosed, a lender or investor may later discover it and conclude that the project's analysis was biased. If the interest is disclosed late—after a financing commitment is made—the lender or investor may withdraw, breaking the financing.

What breaks: If a conflict of interest is discovered after a financing commitment is made, the lender or investor may withdraw, and the project's financing collapses. If the conflict is discovered during due diligence, the lender or investor may demand a price concession or additional equity, reducing the project's returns.

Who resolves it and when: The project's sponsors will disclose all material conflicts of interest in writing, dated, in the cover letter to this prospectus. The disclosure will identify each sponsor, will describe each sponsor's financial interest in the project, and will explain how the sponsor's interest has been managed to ensure the objectivity of the project's analysis. The disclosure will be complete before this prospectus is circulated to any lender or investor.

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Jug Logistics and Container Exemption

The risk: The project's closed-loop cooling system uses recycled water in a sealed loop, eliminating the need for once-through cooling and reducing water consumption for a 100-megawatt facility. However, the closed-loop system requires periodic replacement of the cooling fluid, which is disposed of as wastewater. The project will transport this wastewater in containers rather than in tanker trucks. This ratio is based on the assumption that the container exemption in the Great Lakes–St. Lawrence Compact (5.7-gallon container exemption) applies to the project's wastewater. However, the exemption is specific to the Great Lakes Compact and may not apply to wastewater in other jurisdictions. If the exemption does not apply, the project must use tanker trucks, and the logistics cost rises materially.

What breaks: If the container exemption does not apply and the project must use tanker trucks, the logistics cost rises materially. The project remains positive but loses margin. More critically, if the project must use tanker trucks, the environmental case for closed-loop cooling weakens—the project is no longer a net reduction in water consumption; it is a substitution of water consumption for transportation emissions.

Who resolves it and when: The project's counsel will analyze the container exemption and will determine whether it applies to the project's wastewater in Utah, Oklahoma, and Indiana. The analysis will be complete within 12 months of the bill's enactment. If the exemption does not apply, the project will seek a regulatory determination from the relevant state environmental agency to clarify the exemption's scope. If the exemption does not apply and cannot be extended, the project will model the cost of tanker logistics and will update the prospectus accordingly.

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Regulatory Status: Tariffed Commodity versus Packaged Service

The risk: The project sells water as a tariffed commodity—that is, as a molecule subject to state regulation and state taxation. However, the project also sells water as a packaged service—that is, bundled with cooling, heating, or other value-added services. These two regulatory regimes are different. A tariffed commodity is subject to state utility regulation, state water law, and state taxation. A packaged service is subject to federal commerce law, contract law, and potentially different taxation. If a regulator argues that the project is selling a packaged service and not a tariffed commodity, the project's regulatory status changes and the project's tax liability may increase. If a regulator argues that the project is selling a tariffed commodity and not a packaged service, the project's ability to bundle services may be constrained.

What breaks: If the project's regulatory status is unclear, lenders will demand a higher interest rate to compensate for the regulatory uncertainty. If the project's tax liability increases, the delivered cost rises and the project's economics deteriorate. If the project's ability to bundle services is constrained, the project's revenue from cooling and heating services falls and the project's overall return falls.

Who resolves it and when: The project's counsel will prepare a regulatory analysis that clarifies the project's status as a tariffed commodity, a packaged service, or both. The analysis will identify the relevant regulators in each jurisdiction and will determine the regulatory regime that applies to each revenue stream. The analysis will be complete within 12 months of the bill's enactment. If the regulatory status is unclear, the project's counsel will seek a declaratory ruling from the relevant regulator before segment one enters construction.

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Stage 3 Pricing and Optionality

The risk: The project comprises three stages: stage 1 (segments 1–11, 275 miles, $11 billion capital), stage 2 (segments 12–22, 275 miles, $11 billion capital), and stage 3 (segments 23–32, 250 miles, $5.7 billion capital). Stages 1 and 2 are priced in this prospectus. Stage 3 is not priced; it is structurally contained and will be financed separately if and when it is built. The risk is that stage 3's economics are unknown and may be materially worse than stages 1 and 2.

What breaks: Stage 3 is not in the capital plan and is not in the financing. If stage 3's economics are worse than stages 1 and 2, stage 3 will not be built, and the project's contribution to the lake falls. The project remains positive but becomes a smaller solution to a larger problem. If stage 3's economics are better than stages 1 and 2, stage 3 will be built and the project's overall return improves.

Who resolves it and when: Stage 3 will be priced and financed separately, after stages 1 and 2 are complete and operating. The decision to build stage 3 will be made at that time, based on the actual performance of stages 1 and 2 and the actual cost of capital at that time. Stage 3 is not a risk to the project's financing; it is an option that will be exercised or not based on future conditions.

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Measurement, Verification, and Adaptive Management

The risk: The project's success depends on the accuracy of its assumptions about return fractions, cooling efficiency, heat offtake prices, and other parameters. These assumptions are estimates, and estimates can be wrong. If the project is built and the assumptions prove incorrect, the project's performance will diverge from its projections, and the project's returns will fall. The project has no mechanism to detect this divergence early or to adapt its operations in response.

What breaks: If the project's actual performance diverges materially from its projections, the project's returns fall and the project's debt service becomes unsustainable. If the divergence is detected late, the project may default before corrective action can be taken.

Who resolves it and when: The project will establish a measurement and verification protocol that monitors the project's actual performance against its projections. The protocol will measure water return fractions, cooling efficiency, heat offtake prices, and other key parameters on a monthly basis. The data will be published as open data and will be available to lenders, investors, and regulators. If the project's actual performance diverges materially from its projections, the project's operations will be adjusted to bring performance back into line with projections. If the divergence cannot be corrected through operational adjustment, the project's financing will be restructured to reflect the new performance. The measurement and verification protocol will be established before segment one enters construction and will be operational before segment one generates revenue.

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11. USE OF PROCEEDS

The $25,000,000 appropriation funds the technical, legal, and regulatory validation required to transition from the current deficit to the first segment of infrastructure. These funds are not capital expenditure for construction, but for establishment of the baseline, the route, and the legal authority to operate.

Allocation	Amount
Hydrology	$9,000,000
Alignment	$7,000,000
Lake Mass Balance	$3,000,000
Cost of Service	$1,000,000
Federal Applications	$3,000,000
Legal	$2,000,000
Total	$25,000,000

Hydrology ($9,000,000)

This allocation funds the high-resolution hydrological modeling required to validate the pre-drawdown mechanism and establish the empirical basis for the 1,000,000 AF/yr target. The study will examine 778,641 elevation cells to define the relationship between the 4,205 ft target and the 4,200 ft floor. It will quantify the interaction between the 4,198 ft state-minimum (Great Salt Lake Strike Team 2026) and the proposed 4,205 ft target, providing the data necessary to defend the project's scale. The work will reconcile the current shortfall of 6.5–7 ft against the 800,000 AF/yr deficit identified by the Strike Team, ensuring the 125% headroom is mathematically sound. This study resolves Open Item O1 and provides the foundation for all downstream cost and feasibility analysis.

Alignment ($7,000,000)

The alignment study will define the corridor for the 32 segments across 25 miles each. The scope is contractually required to reconcile against the 1982 Corps Six-State High Plains study and must use the published abandoned-quarry layer as the primary route input. This ensures the alignment is driven by existing industrial footprints and geological feasibility rather than speculative land-use. The study will evaluate segment lengths and total potential length to ensure the infrastructure is built to the scale of the 1,000,000 AF/yr requirement. No county, reservoir, intake, or quarry site is named until this study resolves the route. The work directly addresses Open Item O3 and establishes the capital cost basis for the Utah corridor ($27.7 bn) and the Indiana route (~$53 bn).

Lake Mass Balance ($3,000,000)

This study will model the substitution-versus-diversion mechanics that determine whether the project returns water to the lake or depletes it. It will quantify the return fractions—indoor ~95%, pool ~70%, lawn ~12%—to ensure that every gallon sold results in a net-positive return to the lake. Under §73-32-409(3), displacing an existing use returns +1.00 gallon to the lake per gallon sold; genuinely new use returns at the applicable fraction. This work is essential to prove that the project is a mechanism for replenishment, not a source of depletion. The study will address the 11-foot loss caused by human water use (Wurtsbaugh et al., 2016) and ensure that the project's 1,000,000 AF/yr target remains net-positive for the lake's 4,200 ft floor. It resolves Open Item O5 and commits the plan to publishing measured fractions as open data.

Cost of Service ($1,000,000)

This allocation funds the economic modeling of the $1,171/AF delivered cost against existing municipal and industrial rate structures. It will finalize the pricing models for the $1,639/AF target (90% of SLC commercial summer rate) and verify that the project remains discount-rate sensitive rather than price-sensitive. The study will confirm that the $1,171/AF cost is competitive against the SLC commercial summer rate of $1,821/AF and the household top-tier rate of $2,586/AF (FY27). This work establishes the revenue basis for segment economics and the standalone node yield of $65.0 M/yr at merchant pricing ($45/MWh) or $84.1 M/yr at time-to-power pricing ($75/MWh).

Federal Applications ($3,000,000)

This funds the application for storage-and-recovery authority under the Water Supply Act of 1958 and other federal-grade contracting frameworks. It will establish the legal pathway for the 1,000,000 AF/yr capacity within existing federal-state-local frameworks. The work will focus on the 1958 Act's existing statutory pathways for contracting federal reservoir storage and resolve Open Item O12 regarding whether pre-drawdown storage contracting fits the Act's authorization thresholds.

Legal ($2,000,000)

This covers the regulatory defense and the drafting of the statutory framework for the commissioner's role under §73-32-409. It ensures that the legal structure for the $25M appropriation is robust against the 2026 regulatory cycle. This includes preparation of the legal defense for the §402 export ban under the dormant Commerce Clause (Sporhase v. Nebraska, 1982) and management of the potential for litigation regarding the 4,205 ft target. It resolves Open Item O11 and O13.

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GOVERNANCE

The Authority is a statutory body established to manage the infrastructure, water-transfer mechanisms, and maintenance of the target elevation of 4,205 feet and the floor of 4,200 feet. Its governance structure aligns the economic survival of primary stakeholders with the physical requirements of the lake's salinity-dependent health.

The Trust Council is the decision-making body. It comprises representatives from five sectors: Municipal and Industrial users, Agricultural users, Energy and Data-center users, the Brine Shrimp Cyst Industry, and State-appointed Technical Oversight. The brine shrimp cyst industry holds a structural position because its revenue depends directly on the maintenance of the lake's salinity and the 4,205-foot target; its economic interests are functionally identical to the ecological requirements of the mission.

Governance is built on the principle of substitution. Because displacement of an existing use returns a positive volume to the lake, the Trust Council's primary regulatory task is to manage return-flow fractions to ensure that any new use produces a net gain for the target elevation. The framework recognizes that the primary risk is not capital-intensive but regulatory: induced demand through political or regulatory shifts. The Authority's rules are price-insensitive and discount-rate sensitive, focusing on the cost of delivery ($1,171/AF) rather than market-based water pricing volatility.

The relationship between the 4,205-foot target and the 4,200-foot floor is the central stability mechanism. The target serves as the operational goal; the floor serves as the legal and economic boundary. The Trust Council may adjust operational parameters within this 5-foot band to meet sector needs, provided the floor is never breached. This prevents creeping depletion when political actors attempt to lower the target to accommodate expanding demand.

The Commissioner acts as the technical arbiter between sectors. The Commissioner enforces volume-limit protocols and verifies return-flow data. The Commissioner lacks authority to lower the floor or ignore the 4,205-foot target without a formal, recorded vote of the Trust Council. The floor remains a hard constraint regardless of political climate or seasonal snowpack.

The governance structure includes mandatory, permanent disclosure of potential conflicts of interest. The authors of this document disclose that the initial administrative structure and the regulatory-capture-prevention protocols may provide operational advantages to the founding entities. This disclosure ensures the integrity of the investment-grade record.

The Trust Council's decision-making matrix prevents subsidy-capture. In traditional water governance, the largest volume-user holds the most political weight. Here, weight is distributed by the necessity of return-flow. The brine shrimp cyst industry, despite its smaller volumetric footprint, holds a veto-equivalent position on salinity-critical decisions because its economic survival is most sensitive to failure of the 4,205-foot target. Return-flow is treated as a primary operational requirement, not a secondary benefit.

Because the project replaces existing, less-efficient uses with more-efficient, high-return-flow uses, the Trust Council manages the transition of rights. Rules for water-use-right transfers are strictly governed by the 4,205-foot target. If a transfer would result in a net loss to the lake's volume, the Commissioner prohibits it regardless of economic value. This prevents leakage of the business model into lake depletion.

The technical oversight component comprises non-voting, state-appointed experts in hydrology, engineering, and economics. Their role is to audit the measurement plan and ensure return-flow fractions are reported with required precision. Data from the measurement plan is public and serves as the basis for the Commissioner's decisions. This transparency prevents information asymmetry that erodes environmental-health-based targets.

The governance structure decouples from commodity-market volatility. The focus is on cost-of-delivery and maintenance of the target elevation, not price-per-acre-foot. Infrastructure-grade returns are protected from political pressure to lower prices at the expense of the lake's health.

The relationship between sectors follows a clear hierarchy of necessity. The primary mission—maintenance of the 4,205-foot target and the lake's salinity-dependent health—supersedes all sector-specific economic goals. If conflict arises between a sector's economic growth and the target, the target takes precedence. This is a structural requirement of the Authority's charter, not a policy preference.

Return-flow fractions are measurable assets, not merely environmental metrics. They form the basis for economic modeling. Governance ensures return-flow is credited to the lake and loss from any use is clearly accounted for in the annual balance of the target elevation. This prevents masking depletion through complex accounting or net-zero claims that do not reflect physical basin reality.

The Trust Council meets quarterly to review technical data and economic performance of the sectors. These meetings are the primary venue for adjusting operational parameters within the 4,205-foot to 4,200-foot band. Council decisions are recorded as part of the permanent, auditable record. The floor is never moved without clear, documented, public-facing reason.

Governance manages the substitution of the agricultural sector. The transition from high-depletion irrigation to high-return-flow models is a managed process. Governance ensures the economic value of saved water is captured by the lake rather than lost to expansion of the agricultural footprint. This is the core of the substitution-as-business-model approach.

The Commissioner ensures return-flow is not just a benefit but a requirement. The Commissioner's oversight includes verification of substitution logic in every new contract. If a contract does not meet the minimum return-flow-to-depletion ratio required to maintain the 4,205-foot target, the Commissioner is mandated to reject it. This prevents gradual erosion of the target through approval of increasingly inefficient uses.

Governance manages the energy-water nexus. Energy-sector users, including data-center users, are subject to the same salinity-and-elevation-based constraints as water-users. Governance ensures energy-intensive cooling needs do not compromise the water-delivery mandate. The power-is-the-money reality is balanced against the water-is-the-mission reality through this governance structure.

The Trust Council's structure is permanent. The legal framework resists re-election-cycle-driven policy shifts. By embedding the technical necessity of the 4,205-foot target into the economic structure of the sectors, the Authority creates a self-reinforcing cycle of stability. Economic interests of users are tied to the physical health of the lake, making target maintenance the most rational economic choice for all stakeholders.

Governance manages recovery of the lake as a measurable outcome. The 4,205-foot target is a physical state, not a vision. Every decision is measured against its impact on the target. This focus on a single measurable outcome prevents dilution of the mission into competing-interest statements.

The final governance layer is the annual audit of return-flow. The Authority publishes a report reconciling volume delivered with volume returned. This report is the primary tool for the Analyst and Bond Counsel to verify project integrity. If return-flow fractions deviate from modeled expectations, the Trust Council adjusts operational parameters to bring the lake back to the target elevation. This is the mechanism of the self-correcting governance model.