55 ELR 10186 ENVIRONMENTAL LAW REPORTER MAR/APR 2025
GREAT SALT LAKE, ENVIRONMENTAL
CRISES, AND SECURITIES LIABILITY
by Elisabeth Parker, Brigham Daniels, Abigail Allen, and Corinne Doerner
This Article examines the intersection of environmental crises and financial disclosure obligations through
the lens of Great Salt Lake. As the lake shrinks to unprecedented levels, the resulting dust storms, diminished
snowpack, and destabilized ecosystems increasingly threaten both the public health and economic viability
of Utah’s most populous region, and economic impacts will extend far beyond industries directly dependent
on the lake. These environmental threats can translate into material financial risks for publicly traded com-
panies and municipal bond issuers, potentially necessitating disclosure under existing securities law. While
industries directly reliant on the lake’s ecosystem may already face disclosure obligations, these will expand
to include more sectors and geographic areas if the lake is allowed to continue to shrink. The Article argues
that recognizing these growing securities liabilities presents a powerful additional reason for urgent policy
interventions to restore the lake and safeguard the region’s long-term economic viability. This case study
shows how localized environmental crises generate systemic vulnerabilities across economic sectors, with
implications for similar situations worldwide.
SUMMARYSUMMARY
Elisabeth Parker is a Senior Attorney and Senior Fellow at the Wallace Stegner Center’s Law & Policy
Program at the University of Utah, S.J. Quinney College of Law, an Adjunct Associate Professor of Law
at the S.J. Quinney College of Law, and the Law & Policy Lead for the Great Salt Lake Project. Brigham
Daniels is a Professor of Law at the S.J. Quinney College of Law, Co-Director of the Wallace Stegner
Center, and Director of the Great Salt Lake Project. Abigail Allen is an Associate Professor of Accounting
and the LeAnne Albrecht Fellow at the Marriott School of Management at Brigham Young University.
Corinne Doerner is a Research Fellow at the Wallace Stegner Center’s Great Salt Lake Project.
Unless Utah makes major cha nges to the status quo,
Great Salt Lake is heading towa rd an ecological
tipping point. If reached, the lake, particu larly
the dried lakebed, threatens to unleash an “environmental
nuc lea r bo mb.”1 Its fallout wil l include not only an ecologi-
cal disaster for one of the West’s keystone ecosystems, but
also severe air pollution that threatens the livability of the
Wasatch Front—Utah ’s most populous region and home
to more than 2.6 million people.2 Most alarmingly, it is
increasingly clear that the policy tools currently available
are insucient to meet the challenge. W hile hope remains
that the region will nd the wi llingness to take the neces-
1. Christopher Flavelle, As Great Salt Lake Dries Up, Utah Faces an “Environ-
mental Nuclear Bomb,” N.Y. T, June 7, 2022, at A1.
2. World Population Review, Utah Population 2024, https://worldpopulation-
review.com/states/utah-population (last visited Feb. 21, 2025); B
W. A ., E M N R G S
L F O C (2023), https://www.researchgate.net/
publication/366876763.
sary steps, without dramatic changes, failure seems just a
matter of time.
is Article examines a facet of what many Utahns
might consider the unthinkable: a future where a dried
Great Salt Lake begins to transform into a Great Salt Dust
Bowl. e environmental threats of a dry ing lake have
understandably captured worldwide attention, as the lake
has lost approximately half its historic volume in just sev-
eral decades.3 However, a drying lake threatens more tha n
just the region’s environment. It also puts into peril the
region’s economic future.
In fact, long before the lake’s ecosystem collapses or
the region becomes unlivable, businesses will react as
the Wasatch Front becomes an undesirable location for
businesses and additional investment. If the la ke moves
closer and closer to the brink, its degradation will gener-
ate expanding circles of material risk to Utah’s businesses.
3. Melissa Cobo et al., A Desiccating Saline Lake Bed Is a Signicant Source of
Anthropogenic Greenhouse Gas Emissions, 7 O E 1414, 1420 (2024),
https://doi.org/10.1016/j.oneear.2024.07.001 (“Human consumptive wa-
ter uses, including agriculture, urban uses, and solar ponds, have led to a
signicant recent decline in lake levels, resulting in a roughly 50% reduction
in lake surface area by the time of this study (2020).”).
Authors’ Note: The authors thank the excellent editors at
ELR and also Prof. Michael Gerrard, who posed a question
that ultimately inspired this Article.
