generation or gas processing facility on the proposed parcels. The county's findings report Likewise, treats the proposed natural gas power plant as a new use requiring a conditional use permit, not the continuation or expansion of an existing facility. This project is a 400-megawatt continuously operating natural gas power plant with 800 to 1,600 megawatt-hours of energy storage, accompanied by permanent industrial infrastructure, year-round operations, new traffic patterns, emissions, noise, lighting, and long-term industrial footprint. Nothing in the findings report meaningfully analyzes that expanded scale and intensity.

The presence of upstream gas development does not establish site compatibility for a centralized power generation facility, and it does not excuse the site-specific analysis the ordinance requires. Relatedly, the findings report does not meaningfully analyze water use or wastewater impacts associated with a large natural gas power plant which will be operating for decades. While the project narrative makes generalized statements about low water use and reuse water, there is no substantial or substantive analysis of cumulative water demand, wastewater generation, or disposal impacts within an arid basin where water resources are already constrained. Those impacts bear directly on public welfare and long-term land stewardship, yet they were not addressed in the findings. The Commission also accepted without evidence the claim that a significant portion of Basin natural gas has nowhere to go and that this power plant is therefore necessary.

There is nothing in the Wellshot Energy LLC natural gas findings report nor in the project record that substantiates that claim. No market analysis, no pipeline capacity study, no regulatory finding supports the idea that 30% of Basin gas is stranded. Unsupported assertions cannot substitute for evidence, particularly when they are used to justify a- Second, the finding that the site is of adequate size and dimensions relies only on anchorage. Section 813.4 requires more than anchorage. It requires a determination that the use will not be materially detrimental to adjoining and surrounding properties.

The findings report did not analyze increased industrial traffic in the recreational corridors in that region, noise and visual impacts beyond traversal boundaries, fragmentation of wildlife movement through a known corridor, or cumulative impacts on access routes serving Nine Mile and the Green River- Nine Mile Canyon and the Green River. Without that context, the finding lacks substantial evidence. Third, the commission deferred required findings to future conditions. The ordinance allows conditions only after required findings are made. Conditions cannot substitute for missing findings or cure fundamental site incompatibility.

Here, approval relies on future permits and agency approvals to address impacts that should have been analyzed upfront. That approach shifts the burden from