in and for the county of maricopa - water.az.gov
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Kimberly R. Parks (Bar No. 032828) Janet L. Miller (Bar No. 011963) Arizona Department of Water Resources Legal Division P.O. Box 36020 Phoenix, Arizona 85067 Telephone: 602-771-8472 Fax: 602-771-8687 [email protected] [email protected]
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA
IN RE THE GENERAL ADJUDICATION OF ALL RIGHTS TO USE WATER IN THE GILA RIVER SYSTEM AND SOURCE
W-1 (Salt) W-2 (Verde) W-3 (Upper Gila) W-4 (San Pedro) (Consolidated) Contested Case No. W1-103 ARIZONA DEPARTMENT OF WATER RESOURCES’ OBJECTIONS TO THE REPORT OF THE SPECIAL MASTER ON METHODOLOGY FOR DETERMINATION OF CONE OF DEPRESSION Assigned to the Hon. Mark H. Brain Referred to Special Master Susan Ward-Harris
DESCRIPTIVE SUMMARY: The Arizona Department of Water Resources hereby submits its objections to the Report of the Special Master on Methodology for Determination of Cone of Depression filed November 14, 2018. NUMBER OF PAGES: Thirteen and seventeen-page attachment
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DATE OF FILING: May 13, 2019
Pursuant to the Special Master’s Order dated January 7, 2019, the Arizona
Department of Water Resources (“the Department” or “ADWR”) hereby submits its
objections to the final Report of the Special Master on Methodology for Determination of
Cone of Depression filed November 14, 2018 (“Special Master’s Final Report”). These
objections are supported by the demonstration project and small wells reports submitted
by ADWR, trial and deposition testimony, trial exhibits, and ADWR’s Objections to the
Special Master’s Draft Report on ADWR’s Demonstration Project Report: Cone of
Depression Test Methodology filed May 31, 2018 (“ADWR’s Original Objections”)
included as Attachment 1.
I. Summary of ADWR’s Position
ADWR previously submitted objections to the Special Master’s Draft Report and
continues to stand by those objections in addition to the objections contained in this filing.
ADWR’s foremost disagreements with the Special Master’s Final Report are the
recommendation that the Court reject ADWR’s determination that the cone of depression
analysis could be performed using an analytical method and the recommendation that the
Court adopt the use of the numeric model, MODFLOW, as the methodology for cone of
depression testing. The Arizona Supreme Court stated in Gila IV:
The trial court did not attempt to establish a test for determining a well’s cone of depression because the court lacked pertinent evidence on that issue. Instead, the court recognized that each well must be separately evaluated “to compute drawdown at the ‘subflow’ zone” and that “whatever test ADWR finds is realistically adaptable to the field and whatever method is the least expensive and
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delay-causing, yet provides a high degree of reliability, should be acceptable.” We agree with the trial court (emphasis added).1
ADWR has employed its technical expertise and determined that the analytical
element method, AquiferWin32, is just as reliable as MODFLOW for computing the
steady-state drawdown at the subflow zone boundary relative to the 0.1-foot standard for
small volume and large volume wells. 2 AquiferWin32 will certainly be less expensive
and delay-causing than MODFLOW for these calculations. For medium volume wells,
AquiferWin32 is subject to the same uncertainties as MODFLOW for those wells where
the calculated drawdown is close to the 0.1-foot standard. AquiferWin32 will be more
adaptable to the field than MODFLOW in those cases because ADWR will be able to
examine and adjust the parameters used in the calculations for each individual well
without having to alter the entire model. Repeated calibration of the model would be
required if MODFLOW is used which could potentially impact the results for other wells
in the model and may result in changes to the findings for any wells that have previously
been subject to the cone of depression test.
While ADWR has found that the use of MODFLOW is not necessary, ADWR will
not preclude the use of MODFLOW in areas where it would be expedient to do so because
a generally accepted MODFLOW model already exists. This would be especially true in
areas where ADWR believes future enforcement of the decree will be necessary. In the
San Pedro River watershed, enforcement will likely be necessary in the Sierra Vista
subwatershed, upstream from the St. David Irrigation District. 1 In re Gen. Adjudication of All Rights to Use Water in Gila River Sys. & Source, Gila IV, 198 Ariz. 330, 343, 9 P.3d 1069, 1082 (2000). 2 ADWR has determined that in the San Pedro River watershed, “small volume” wells have steady-state pumping rates of 1.86 gallons per minute (gpm) or less, while “large volume” wells have steady-state pumping rates of 31 gpm or more. Medium volume wells have steady state pumping rates between 1.86 and 31 gpm.
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II. ADWR’s Specific Objections to the Special Master’s Final Report
ADWR’s objections to statements and conclusions contained in the Special Master’s
Final Report are provided below. The statement or conclusion from the Special Master’s
Final Report is first presented in italics followed by ADWR’s response.
“Thus, a groundwater model’s capacity to incorporate the level of complexity present
in the watershed affects the accuracy of the model’s results.” Special Master’s Final
Report at 7.
ADWR agrees with this statement, however, Judge Ballinger’s decision to utilize
steady-state modeling had the effect of greatly simplifying the modeling of the watershed.
The duration of pumping and the volume of water in storage within the aquifer have been
removed from consideration. This simplification explains why the results3 from ADWR’s
use of an analytical element model (AquiferWin32) agree so well with the MODFLOW
results4 for small volume and large volume wells. Depending on their proximity to the
subflow zone boundary, medium volume wells can have calculated steady-state
drawdowns that approach 0.1 foot. The uncertainties associated with the data and
modeling approach utilized, and the very nature of steady-state modeling, means there is
no way to demonstrate which model is more accurate if one modeling method calculates
the drawdown as greater than 0.1 foot and the other method calculates the drawdown as
less than 0.1 foot. Because there is no way to affirm the more accurate answer, other
factors should be considered when choosing a model to calculate drawdown for these
3 “Results” does not mean the actual drawdown value calculated, but whether that drawdown value is greater than or equal to 0.1 foot, or less than 0.1 foot. 4 See Table 1 of ADWR’s Demonstration Project Report Response to Cone of Depression Test Comments (“May 2017 Report”), included here as Attachment 2.
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wells. Some of these factors, such as time, cost, and the burden on the well owners, were
discussed in Sections III and V of ADWR’s Original Objections.5
“The addition of multiple image wells increases the complexity of the model and
the amount of time needed to analyze each well.” Special Master’s Final Report at
7.
ADWR has consulted with the designer of AquiferWin32 and determined that a
pre-processor could readily be created that would take the distances to the model
boundaries determined and exported from GIS and convert them to the necessary
coordinates for the recommended 24 image wells, and then input those coordinates into
AquiferWin32. The pre-processor could be made available in a matter of weeks at a
reasonable cost. With this pre-processor, ADWR can add multiple image wells without
expending any additional time.
“AquiferWin32 also depends upon the modeler properly determining a reference
head for each well at a location where drawdown will always be zero. Mr. Ford
and Dr. Cross agreed that the AquiferWin32 model’s reliance on the use of a
reference head set by the modeler created uncertainty. It also inserted subjectivity
into the process because no physical basis exists for the selection of the correct
location of the reference head.” Special Master’s Final Report at 8-9.
ADWR agrees that the selection of the reference head creates uncertainty but notes
that this same uncertainty is present in MODFLOW. MODFLOW models are not unique.
Different modelers may use different boundary conditions to produce models that behave
5 See Arizona Department of Water Resources’ Objections to the Special Master’s Draft Report on ADWR’s Demonstration Project Report: Cone of Depression Test Methodology, filed May 31, 2018 at 4-7 and 8-9, included as Attachment 1.
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similarly overall but could easily produce different steady-state drawdown values for
individual wells, including differences in whether drawdown is greater than or equal to
0.1 foot6. ADWR disagrees that there is no physical basis for the correct location of the
reference head. The appropriate location of the reference head is related to the boundary
conditions. If the reference head is located too close or too distant, the effects of the
image wells emulating the boundary conditions are overwhelmed. The close agreement of
the results between AquiferWin32 and MODFLOW shown in Attachment 2 for small
volume and large volume wells demonstrates that ADWR has selected an appropriate
reference head location.
“Depending upon the number of image wells and the location of the reference
head, AquiferWin32 could forecast drawdown results for the same well as less than
0.10 or greater than 0.10 foot.” Special Master’s Final Report at 10.
As described in the response above, this same concern applies to MODFLOW
models.
“Finding of Fact No. 1. AquiferWin32 requires a reference head to be set at a
location which requires subjective judgment and lacks objective physical
standards. This feature contributes additional uncertainty into the groundwater
model and can introduce significant error given the 0.10 foot criterion.” Special
Master’s Final Report at 10.
The reference head that was ultimately selected for use with AquiferWin32 was
empirically derived from an iterative process in which ADWR initially assumed a test
6 The ADWR Groundwater Modeling Unit typically creates multiple Alternative Conceptual Models with varying boundary conditions for each new groundwater model it creates.
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location for the reference head and subsequently ran the model with the combination of
real and imaginary wells to determine if the desired boundary conditions emulated by the
image wells were reasonably achieved. Through a trial and error process, similar to
numerical model calibration, an appropriate location for the reference head was eventually
obtained.
The reference head must be physically related to the boundary conditions used on
AquiferWin32. As shown in Section 3.2 and Table 2 of its May 2017 Report, ADWR
conducted sensitivity testing and demonstrated that reasonable variations of the reference
head location only significantly impacted the results for medium volume wells.
“Finding of Fact No. 6. The use of a single transmissivity value based on the
lithology surrounding the well does not adequately reflect the transmissivity
affecting the formation of a cone of depression where there are longer distances
between the wells and the relevant boundaries in the San Pedro River Basin.”
Special Master’s Final Report at 18.
Because of the simplifying nature of steady-state modeling, the use of a single
transmissivity value is adequate for small and large volume wells as demonstrated by the
close agreement between the AquiferWin32 and MODFLOW results for these wells
displayed in Attachment 2.
“As shown in Table 1 below, MODFLOW reports only about 10% of the drawdown
for Wells 1, 2, and 3 that the analytical methods calculate. As to Well 40 on the
opposite of the river, MODFLOW calculates a drawdown that exceeds the
analytical results by more than 60%. Admittedly, the absolute differences in
drawdown are small, but the consequences of an increase or decrease in the
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drawdown by a fraction of an inch are material.” Special Master’s Final Report at
19.
The Special Master’s Table 1 is in error because it displays the AquiferWin32
results from Column 5 of Table 1 of ADWR’s May 2017 Report, rather than Column 4
(see Attachment 2). A corrected Table 1 is shown below.
Table 1 Well No. MODFLOW
Drawdown AquiferWin32
Drawdown Jacob Equation
Drawdown Difference between AquiferWin32 and
MODFLOW drawdowns
1 0.020 0.099 0.29 0.079
2 0.052 0.111 0.32 0.059
3 0.033 0.110 0.32 0.077
40 0.112 0.115 0.07 0.003
The actual differences in calculated drawdown between AquiferWin32 and MODFLOW
for these four wells are remarkably small, with the average difference being 0.055 foot, a
mere two-thirds of an inch. That said, the two methods differ on which of these medium
volume wells have calculated steady-state drawdowns that equal or exceed 0.1 foot. As
previously stated, due to the uncertainties in estimating such things as pumping rate and
transmissivity, and the nature of steady-state, there is no way to demonstrate which
model’s results are more accurate.
“Finding of Fact No. 7. MODFLOW is the standard in the industry for modeling
groundwater flow in aquifers.” Special Master’s Final Report at 21.
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ADWR agrees and notes that it has demonstrated that its proposed method provides
essentially the same results as MODFLOW for small and large volume wells while being
significantly faster and therefore cheaper (see the table in Section III of Attachment 1).
“Finding of Fact No. 8. A properly designed and populated MODFLOW model is a
highly reliable test to determine and measure the drawdown of a well’s maximum
cone of depression at the boundary of the subflow zone.” Special Master’s Final
Report at 21.
ADWR agrees and notes that it has demonstrated that its proposed method provides
essentially the same results as MODFLOW for small and large volume wells while being
significantly faster and therefore cheaper in areas where no acceptable MODFLOW
model exists at the time of testing (see the table in Section III of Attachment 1).
“Conclusion of Law. The results generated by the Cone of Depression Test do not
cause the evidentiary burden to shift to the well owner to show that owner’s well
will not pump subflow due to the well’s cone of depression determined at a steady
state condition.” Special Master’s Final Report at 24.
ADWR disagrees with this conclusion. In Gila IV, the Arizona Supreme Court
addressed two principal subjects: the subflow zone and cones of depression. In discussing
the burden of proof for wells within the subflow zone and wells outside the subflow zone,
the court stated: When DWR determines and establishes that a well is in the subflow zone by using the pertinent criteria or that it is pumping subflow by reason of its cone of depression, DWR provides clear and convincing evidence of that fact. See Gila River II, 179 Ariz. at 392, 857 P.2d at 1246. The burden then shifts to the well
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owner to show that a well is either outside the subflow zone or is not pumping subflow. Id.7
ADWR believes that the phrase “pumping subflow by reason of its cone of
depression” refers to the results of the cone of depression test and is not the introduction
of a “depletion” test in order to shift the burden of proof.
“An examination of the clear language of Gila IV establishes that not all wells must
be subjected to the Cone of Depression Test. A well will be subject to this court’s
jurisdiction when ADWR shows that “the well’s cone of depression extends into the
subflow zone and is depleting the stream.” Gila IV at 342, 9 P .3d at 1082
(emphasis added).” Special Master’s Final Report at 24.
ADWR agrees that if a well were demonstrated to be measurably depleting the
subflow zone, then it would clearly be subject to the adjudication whether a cone of
depression test was conducted on that well, or not.
“When circumstances warrant the use of both a Cone of Depression and a subflow
depletion test, instead of the testing procedures proceeding seriatim, the tests could
be conducted simultaneously, which would reduce delay in the continued
adjudication of water rights that could occur if no subflow depletion test could be
formulated and applied until the completion and application of a highly reliable
groundwater model for the Cone of Depression test.” Special Master’s Final Report
at 26.
7 Gila IV, supra note 1, 198 Ariz. 330 at 343, 9 P.3d 1069 at 1082.
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It is ADWR’s position that the calculation of subflow depletion, however that is
defined, is not necessary until the enforcement phase of the decree. Judge Goodfarb
found that, “any well located outside the ‘subflow’ zone that now pumps any percentage
of water from the stream itself or its ‘subflow zone,’ should be included in the
adjudication and the total amount of water withdrawn subjected to this proceeding”
(emphasis added).8 ADWR believes that it is the “total amount of water withdrawn” that
should be in the decree, not the amount of subflow zone depletion that everyone agrees
will change over time. That said, ADWR believes that subflow zone depletion can be
calculated using actual pumping data in a transient simulation and that if a well were
shown to be measurably depleting the subflow zone, then that well could be assumed to be
subject to the adjudication. However, ADWR believes that the volume of subflow
depletion calculated using actual pumping data should not be used to derive quantities of
subflow zone appropriable water to be assigned in a decree (assuming the Court decides
that subflow zone depletion is indeed what belongs in the decree). Any decree-related
calculations should use the quantities established in the HSR for each Potential Water
Right (PWR) after the objections to the quantification methods have been resolved.
“Finding of Fact No. 9. The high degree of reliability of a properly designed and
populated MODFLOW model is not outweighed by potential delay or differences of
cost and time necessary to implement an analytical method or analytical element
model.” Special Master’s Final Report at 26.
ADWR disagrees. Because of the nature of steady-state modeling in the alluvial
materials of the San Pedro River watershed, the vast majority of small volume wells will
8 See Judge Goodfarb Order filed June 30, 1994 at 62, affirmed “in all respects” by the Arizona Supreme Court in Gila IV, supra note 1, 198 Ariz. 330 at 344, 9 P.3d 1069 at 1083.
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not be subject to the adjudication and the vast majority of large volume wells will be.
This will be true regardless of which model is utilized, or even if no model is utilized at
all.
Rather than spending time and resources to build a MODFLOW model that will
likely just confirm what we already know about small and large volume wells, and
perhaps not shed any additional light on the uncertainties associated with medium volume
wells, ADWR would rather dedicate its efforts to collecting the best information available,
including field work if necessary, on the medium volume wells9. This effort would make
the cone of depression calculations for medium volume wells using AquiferWin32 as
reliable as can be made.
III. Requested Action
ADWR has exercised its technical expertise and concluded that both AquiferWin32
and MODFLOW are suitable means of conducting cone of depression testing. Therefore,
ADWR respectfully requests that the Court not adopt the Special Master’s
recommendation that the MODFLOW program should be used to create the groundwater
model for all cone of depression testing. ADWR further requests that the Court allow
ADWR to use the AquiferWin32 analytical model for cone of depression testing when
ADWR makes the technical determination that the use of AquiferWin32 is realistically
adaptable to the field, the least expensive and delay-causing, and provides a high degree
of reliability in the results.
These objections and all attachments will be posted to ADWR’s website at
https://new.azwater.gov/adjudications.
9 As described in Section 6.6 of ADWR’s August 2018 Small Wells Analysis Report (“Small Wells Report”), there are fewer than 138 wells that were mapped in the 1991 San Pedro I HSR whose calculated steady-state drawdown at the subflow zone boundary could potentially approach 0.1 foot. The locations of those wells are shown on Figure 6-7 of the Small Wells Report, included here as Attachment 3.
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DATED this 13th day of May, 2019. ARIZONA DEPARTMENT OF WATER RESOURCES _________________________________ Kimberly R. Parks, Deputy Counsel Janet L. Miller, Deputy Counsel ORIGINAL of the foregoing sent by first-class mail on May 13, 2019, to: Clerk of the Maricopa Superior Court Attn: Water Case 601 W. Jackson Street Phoenix, Arizona 85003 COPIES of the foregoing sent by first-class mail on May 13, 2019, to: Special Master Susan Ward-Harris Maricopa County Superior Court Central Court Building 201 West Jefferson Street, Suite 3A Phoenix, AZ 85003-2205 COPIES of the foregoing sent by first-class mail on May 13, 2019 to all parties on the court-approved mailing list for Contested Case No. W1-103.
ATTACHMENT 1
FIGURES ATTACHMENT 2
Table 1 - Changes in Calculated Drawdown Resulting from Variations in Models and Methodology
ADWR Demonstration Project ReportResponse to Cone of Depression Test Comments
May 2017
Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9
Well Map No. Well Name
Original MODFLOW
Drawdown (ft) at SFZ*
ADWR's Original Muliple Image Wells
(AquiferWin32© Method) Drawdown (ft)
at SFZ
Recharge at Mtn Frnt (AquiferWin32©
Method) Drawdown (ft) at SFZ
Recharge at Center of Subflow Zone
(AquiferWin32© Method) Drawdown
(ft) at SFZ
Recharge at Mountain Front (Jacob Steady State Method)
Drawdown (ft) at SFZ
Recharge at Center of Subflow Zone
(Jacob Steady State Method)
Drawdown (ft) at SFZ
Steady State Pumping Rate - Q
(gpm)
31 111-24-086-W1 0.007 0.009 0.024 0.004 0.02 0.03 0.514 111-23-041-W1 0.023 0.004 0.001 0.002 0.00 0.03 3.119 111-23-025-W2 0.016 0.006 0.010 0.002 0.01 0.02 4.022 111-23-028-W1 0.030 0.006 0.006 0.002 0.01 0.02 4.016 111-20-062-W22N 0.020 0.059 0.013 0.015 0.01 0.18 4.217 111-23-066-W1 0.020 0.211 0.536 0.083 0.53 0.65 5.024 111-23-029-W1 0.039 0.020 0.007 0.006 0.01 0.07 5.71 111-23-ADC-031-W1 0.020 0.099 0.272 0.047 0.29 0.25 6.8
20 111-23-030-W14 0.049 0.084 0.076 0.019 0.08 0.30 7.221 111-23-030-W13 0.049 0.062 0.054 0.019 0.05 0.22 7.223 111-23-030-W3 0.049 0.007 0.004 0.002 0.00 0.03 7.23 111-23-ADC-060-W1 0.033 0.110 0.322 0.048 0.32 0.31 7.3
26 111-20-062-W18 0.046 5.870 1.168 2.070 1.16 12.96 7.511 111-24-CBC-063-W1 0.958 0.089 0.192 0.073 0.19 0.09 7.712 111-24-CBC-072-W1 0.872 0.120 0.313 0.092 0.32 0.14 8.46 111-23-DDA-016-W1 0.115 0.105 0.282 0.054 0.28 0.16 11.0
36 111-24-060-W6N 0.112 0.027 0.079 0.013 0.08 0.14 11.237 111-24-060-W2 0.112 0.072 0.204 0.036 0.20 0.38 11.240 111-24-060-W8N 0.112 0.115 0.069 0.047 0.07 0.67 11.241 111-24-060-W7N 0.112 0.033 0.094 0.016 0.09 0.17 11.22 111-23-ADC-059-W1 0.052 0.111 0.322 0.049 0.32 0.32 12.1
18 111-23-025-W1 0.052 0.010 0.017 0.003 0.02 0.03 12.310 111-24-CBC-022-W1 2.591 2.300 3.407 2.104 3.80 2.56 13.415 111-23-BDCA-009-W1 0.098 0.516 0.090 0.169 0.09 2.44 14.125 111-20-062-W17 0.118 0.287 0.106 0.106 0.07 0.45 18.28 111-23-DDA-023-W1 0.174 0.109 0.271 0.055 0.27 0.16 19.8
30 111-24-BDC-008-W1 0.499 11.310 3.674 3.109 3.62 19.06 22.727 111-23-027-W2 0.522 1.060 2.789 0.442 2.78 1.92 35.413 111-24-CBC-078-W1 3.510 0.690 1.732 0.506 1.37 0.66 47.529 111-24-CBC-005-W1 1.797 1.550 3.596 1.076 3.56 1.74 70.09 111-24-CBB-001-W1 11.270 1.620 3.690 1.333 3.58 1.62 70.65 111-23-DDA-006-W1 0.797 1.710 4.196 0.792 4.15 2.68 71.3
28 111-24-CCB-002-W1 1.817 0.220 0.533 0.165 0.53 0.27 129.432 111-24-075-(59)-W1 1.748 0.468 1.337 0.231 1.33 2.25 176.433 111-24-075-(59)-W3 1.748 0.478 1.333 0.234 1.33 2.28 176.434 111-24-075-(59)-W2 1.748 0.639 1.798 0.313 1.79 3.09 176.435 111-24-075-(59)-W4N 1.748 0.107 0.308 0.053 0.31 0.53 176.438 111-24-DCD-012-W1 1.886 0.654 1.776 0.318 1.76 3.44 190.54 111-23-DAD-006-W6 36.752 5.620 13.491 3.950 13.07 6.49 390.77 111-23-DDA-022-W1 1.519 8.220 20.166 4.883 18.81 9.27 395.8
39 111-24-DCD-010-W4 3.979 1.990 4.057 0.905 3.99 10.86 399.9
Concurs with MODFLOWAlternative Model Subject to the Adjudication / MODFLOW Not Subject to the AdjudicationMODFLOW Subject to the Adjudication / Alternative Model Not Subject to the Adjudication
* SFZ - ADWR Proposed subflow zone
ATTACHMENT 3
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Redington
Benson
Sierra Vista
Aravaipa
Winkelman
Mexico
5
8
4
9
17
12
23
20
24
21
15
19
3
6
13
18
10
14
11
2
22
1
7
16
0
Sources: Esri, USGS, NOAA
±
0 10 205Miles
Legend!( HSR Mapped Wells
San Pedro RiverSubflow Zone5,000 ft Buffer15,000 ft BufferDemonstration AreaSan Pedro WatershedHSR Regions
Currrent OwnershipBLMUS ForestServiceNationalPark ServiceMilitaryState TrustPrivate
Count %
Total 1010 100
Beyond the 15,000 ft Buffer 138 14
*Wells associated with irrigation, municipal, and other significant uses that were individually field checked and mapped in Volume 9 of the 1991 San Pedro HSR
Within the Subflow Zone 443 44
Between the Subflow Zone & 5,000 ft Buffer 395 39
Between the 5,000 ft & 15,000 ft Buffers 34 3
Wells Mapped in the 1991 San Pedro HSR
Small Well Analysis Report
Wells Mapped in the 1991 San Pedro HSR
Relative to Buffers located 5,000 ft & 15,000 ft from the Subflow Zone
Figure 6-7
ADWR August 2018
*