Request for Public Documents (Water Lease Payments & Water Letters for New Construction)


From: The ECHO-Association <>
Subject: GRAMA Request – Water Right Lease Payments & Water Letters
Date: January 19, 2021 at 10:16:40 AM PST
To: Jennifer Hawkes <>, Eric Hawkes <>

Dear Emigration Canyon Deputy Mayor Jennifer Hawkes and EID Financial & General Manager Eric Hawkes of the Simplifi Company,

As operator of water system no. 18143, you have been contracted by Emigration Improvement District (“EID” aka Emigration Canyon Improvement District aka ECID) to maintain and control access to governmental records. (See “Brief of Appellant” at the website administered by the Emigration Canyon Home Owners Association available at

During the 2021 EID budget hearing, you refused to clarify why projected revenue from water-right lease contracts had doubled for the current calendar year, despite the fact that the permanent changes to EID water right “57-7796” are currently pending before the Utah Third District Court and the Utah Court of Appeals, and you have consistently refused to acknowledge that all water sources currently in operation by the Simplifi Company are now expressly contingent upon court approval (see

Moreover, it appears that you have both demanded and collected payments from 98 property owners unaware of both pending water litigation and documented groundwater mining of Emigration Canyon’s Freeze Creek Aquifer (see and

As such, we submit the attached GRAMA request regarding water-right lease payments and water letters issued for new construction in Emigration Canyon.

Please note that failure to provide timely access to the requested governmental documents will be prosecuted to the fullest extent of the law to include injunctive relief and/or recovery of attorney fees and costs under Utah Code Ann. § 63G-2-802.

Kind Regards,

Mark Christopher Tracy
Emigration Canyon Home Owners Association


GRAMA-Water Lease:Water Letters