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The well test that wouldn’t die:

Testing of wells 380 and 381, 1996-2004


In October 2003, controversy arose in Owens Valley over the pumping of wells 380 and 381 under the guise of an operational test.Objections to the testing were based on the facts that the wells were in Off status status and that vegetation in a large meadow southwest of the wells had already been impacted due to sustained, pumping-induced drawdowns for the past 16 years. A close reading of documents associated with the testing shows that relevant history goes back at least to 1996, and that there are several other issues involved which equal or surpass in seriousness that of pumping Off status wells in the guise of a test.


Persons mentioned in this document are:

Under On/Off management, wells 380 & 381 (in the Thibaut-Sawmill wellfield) are linked to permanent monitoring site TS4.This means that conditions at monitoring site TS4 determinewhen the wells may be pumped and when they must be turned off. Wells 380 and 381 are screened only in the deep (confined) aquifer and are sealed through the shallow (unconfined) aquifer.  With this design, wells 380 and 381 draw water from deep aquifers which are separated, in places, by relatively impermeable layers of clay (i.e. confining layers) from the shallow aquifer upon which groundwater-dependent ecosystems rely. The intent of this well design was to minimize pumping impacts on the shallow aquifer (Harrington 2001).The Conceptual Diagram of the Owens Valley Aquifer from the EIR to the LTWA is useful for visualizing and understanding the concepts of free and confined aquifers.  

The tests in 1996-1998

DWP’s annual operations plan for 1996 included a rough outline for an evaluation of the linkage between wells 380 and 381 and monitoring site TS4 (Jackson 1997a). The rationale for the evaluation was given in the introduction to a July 29, 1996 memorandum to the Technical Group:

“Casual inspection of pumping hydrographs for these wells and the shallow test hole hydrograph for TS4 (804T) reveals no obvious correlation between pumping and shutoff of E/M wells 380 and 381 and the decline or recovery in shallow water levels in shallow test hole 804T [i.e. at the monitoring site to which the wells are linked].”  (Jackson and Coufal 1996).

The memorandum also included a test protocol which called for pumping wells 380 and 381 for approximately 100 days starting October 1, 1996 (Table 1). The pumps were to be shut off in time to allow for water table recovery before the start of the 1997 growing season.  Twenty-six shallow monitoring wells and twelve deep ones within about a two-mile radius of the wells were to be read on a complicated schedule ranging from twice weekly, to weekly, to biweekly  (Jackson and Coufal 1996).

On January 10, 1997, ICWD Hydrologist Randy Jackson sent a memo to the Technical Group in which he proposed continuation of the evaluation until at least April 1, 1997 because, in his opinion, measured changes in shallow aquifer water table depths could not be attributed to pumping. His opinion was based on a qualitative analysis: he looked for differences in monitoring well hydrographs between the period before wells 380 and 381 were turned on and the period afterwards. The memo also noted that two of the monitoring wells had been dry throughout the test period, and that Jackson had determined eleven others to be influenced by bodies of surface water such as the LA Aqueduct (i.e. rendering them of little value in detecting pumping impacts).Jackson did not discuss the possibility that water table variation in the remaining 13 shallow monitoring wells might also represent uncontrolled variance masking pumping impacts (Jackson 1997).  Despite Jackson’s recommendation, the wells were turned off on January 29, 1997 (Harrington 2001).

Wells 380 and 381 were turned on again on April 6, 1997, by which time they were in On status.  On October 15, 1997 the Technical Group decided that the test would be continued until pumping-induced drawdowns in the shallow aquifer had been detected or until March 31, 1998.  In his memo to the Technical Group documenting this decision, Jackson also noted that equilibrium had been reached for several months and that it may take “many months of pumping in the deep aquifer to affect the shallow groundwater levels” (Jackson 1997a).

Concerns about these tests were raised by ICWD plant ecologist Dr. Sara Manning at the time the tests were conducted.  Manning pointed out that water tables had already been lowered beneath the rooting zone of meadow vegetation in the area since 1988, and vegetation cover had declined.  She also argued that the testing protocol did not adequately control sources of water table variance, making conclusive attribution of water table fluctuations to test pumping unlikely (S. Manning, personal communication 1997).

The proposal in 2000

In April, 2000 DWP released its proposed annual operations plan for the 2000 — 2001 runoff year.  The plan proposed pumping about 7000 AF from wells 380, 381 and  three others wells (which had also been tested in 1996-1998), notwithstanding the fact that all were in Off status.  DWP's Gene Coufal justified the proposal in a letter to ICWD in which he asserted that these wells had "no impact on [the] shallow aquifer during 1997-1998 pump test."  ICWD responded by pointing out that the wells were in Off status (Harrington 2001).  The matter, however, did not die.

At an Inyo County Water Commission meeting in June 2000, a summary was released of a closed Technical Group meeting regarding DWP's proposed 2000 operations plan.  The summary reported that ICWD had "offered" that it was willing to work with DWP to conduct additional cooperative studies and that if the cooperative studies were approved by the Standing Committee, and if the cooperative studies required operation of the Off status wells, ICWD would recommend that the Standing Committee allow pumping of the Off status wells (Inyo-Los Angeles Technical Group 2000).   In other words, ICWD had suggested the wells could be pumped despite their Off status as long as the parties treated the pumping as a test and agreed upon a protocol.

In response to ICWD's suggestion, DWP submitted a protocol for a pump test on August 17, 2000 (Table 1).  The protocol would have required pumping about 7000 AF of water from the same 5 wells noted above. Seventeen shallow and four deep test wells were proposed for monitoring associated with testing of wells 380 and 381.  The wells to be monitored were all wells which had been monitored in the 1996-1998 tests, though wells 628 – 631, which had been treated as deep wells in the previous test, were listed as shallow wells in this protocol (Erb 2000).

In commenting upon this proposed protocol, ICWD hydrologist Dr. Robert Harrington questioned the purpose of the study as well as its methods, and noted risks to the environment as well as critical problems in the methodology (Harrington 2000).  Several of his comments are excerpted below at length because they address fundamental questions in groundwater management and are relevant to subsequent incarnations of the protocol.

“Comment #1: I believe the focus of this study should be the estimation of aquifer and confining layer properties, not simply observation of shallow aquifer water levels.  Since the design of these production wells retards the vertical propagation of pumping effects, the effects propagate laterally and the impact at the surface is spatially diffuse and time-lagged with respect to drawdown in the confined aquifer… In my opinion, a better strategy would be to design pump tests with the goal of estimating aquifer properties, particularly the confining layer, and use these data as prior information in the groundwater model.  These activities are already contemplated under the confining layer characterization cooperative study and groundwater modeling cooperative study. It is unclear to me why a separate study is required here, unless it is designed to complement the studies already in place”

“Comment #3:…Because of its limited [six month] duration, a test such as proposed here does not adequately assess the cumulative impact of pumping over many years.  Yet, simply expanding the duration of the test is inadequate, because that may provoke time-delayed impacts that are irreversible even before they are detectable at the surface.  The best strategy would be to design the test to derive hydrologic parameters and use the groundwater model to assess various pumping strategies.”

“Comment #6: The greatest challenge in analyzing the results from previous similar tests has been to separate the “signal” due to test pumping from the “noise” due to other factors that affect shallow water levels.  How will pumping impacts be discriminated from effects due to seasonal variations in ET and recharge, fluctuations in surface water levels, interference from other wells, and infiltration from irrigated land?  This is a critical problem with this proposal, and without a credible method of discriminating pumping effects from other factors, I highly doubt that this study will result in an unambiguous conclusion regarding the impacts of these wells…”

Meanwhile, the Bristlecone Chapter of the California Native Plant Society (CNPS) publicly denounced the proposed test as a "fraudulent" pretext to pump Off status wells for production  (Pritchett 2000).  In addition to the "coincidence" that the test would have provided the same volume of water originally planned to be pumped without a test, CNPS pointed out that DWP had made no mention of any need for a study in its original annual operations plan, nor in any of the lengthy discussions of needed studies which had been held at recent Technical Group meetings.  Furthermore, CNPS asserted that the results of the 1996-1998 tests had yet to be thoroughly analyzed.

DWP didn't modify the protocol to ICWD's satisfaction (Harrington 2001) and dropped the proposed test from its annual operations plan at the Standing Committee meeting of September 14, 2000.  At the same meeting, however, Inyo County made a commitment to provide DWP with a more detailed presentation of its views and concerns regarding operational testing of the wells. 

This commitment was realized in June 2001, with the release of a report by Harrington (2001) entitled "Operational test of wells 375W, 380W, 381W, and 382W: results from previous tests and recommendations for future tests and management.”   Harrington conducted a qualitative analysis of hydrographs of test wells monitored in the 1996-1998 testing.  He concluded that hydrographs could be organized into 3 groups: 1) those influenced by bodies of surface water such as the LA Aqueduct; 2) those apparently influenced by seasonality of plant evapotranspiration; and 3) those which showed little change.  He concluded that Pumping effects could not be detected in any shallow wells, either because effects were buffered by surface water, masked by other variations, or no pumping effects propagated to the shallow aquifer.”[emphasis added] (p. 29)

Regarding the need for further operational tests, Harrington concluded:

"1) the problem of separating the effects of test pumping from effects of other factors severely hampers observation of pumping affects in the shallow aquifer, and  2) operational testing as conducted in these [i.e. the 1996-1998] tests to assess the effects of these wells is unlikely to provide a useful assessment of the long-term operation of these wells.  In all but a few wells monitored during these tests, the assessment of pumping effects was inconclusive due to the large amount of external noise in the hydrographs compared to the modest signal due to pumping.  Danskin (1998) states that, though confining pumping to the deep aquifer may reduce impacts to the shallow aquifer, sustained pumping of such wells will eventually affect groundwater dependent vegetation by propagation of drawdown around the margins of confining clay layers.  Were this to occur, impacts would be far progressed before they were detectable in the shallow aquifer.” [emphasis added] (p.31)

“Further operational testing of 380W and 381W is unlikely to yield any additional information unless aimed at supporting a modeling effort e.g. aquifer testing to determine confining layer characteristics.  An observation well was drilled in 2000 into the confining layer near wells 380W and 381W for the purpose of evaluating confining layer properties.  An aquifer test should be designed and conducted using this well as part of the confining layer cooperative study” (p.32)

The proposal in 2002

In April 2002, DWP released its proposed annual operations plan for the 2002 - 2003 water year.  The plan noted that a proposal was being prepared for testing an "interim alternative management plan" for wells 380 and 381.  In ICWD's comments on the operations plan, ICWD director Greg James wrote, "As a result of previous test pumping of these wells, which did not reveal any adverse impacts on the shallow aquifer, the Water Department concluded that these wells could be operated once the Technical Group has agreed to a monitoring/management plan for these wells that augments and/or replaces the current ON/OFF management of the wells" [emphasis added] (James 2002).  Noting that the previous tests hadn’t revealed any adverse impacts without also noting Harrington’s conclusion that the tests had produced no conclusive results regarding impacts in the shallow aquifer (due to the problem of uncontrolled external variance) was de facto a reinterpretation of test results.  James' reinterpretation suggested results of the tests were conclusive while Harrington had concluded they were not.   No explanation was given for this reinterpretation.

On July 12, 2002, DWP sent ICWD a protocol for the proposed test drafted by its consultant Montgomery Watson Harza (Table 1).  Although the 2003 operations plan referred to testing of an "interim alternative management plan," the protocol is entitled "Task 1.3.4 Deep Well Operational Testing Draft Operational Plan."  It called for pumping wells 380 and 381 for 10 to 18 months or until drawdowns in any of six key “trigger” wells in the shallow aquifer exceeded pre-established limits and this change could be attributed to the test pumping.  A qualitative method (just as Jackson had used in 1996-1998) was proposed for attributing water table variation to test pumping, i.e. comparison of test well hydrographs before and after initiation of test pumping. The protocol did not note that two of the six key wells (wells #674 and #380) had previosuly been determined by Jackson to be influenced by bodies of surface water and so were of little value for determining shallow aquifer pumping impacts.  About 7200 AF of water would be pumped if the test were conducted for the entire 18 months. Thirty shallow test wells were proposed for monitoring, of which nineteen had been monitored in the 1996 study and six were to be constructed.  Thirteen deep wells were proposed for monitoring of which seven had been monitored in the 1996 study.  Wells 629 and 631 were treated as shallow wells in this protocol, though they had been treated as deep wells in the 1996-1998 test.  Test wells were to be read on a complicated schedule which ranged from thrice daily, to daily, to weekly, to bi-weekly.  Nine production wells in the area were required to be turned off one month before the initiation of the test in order to minimize uncontrolled variance in shallow water tables (Coufal 2002a).

On September 19, 2002, Inyo County submitted its comments on the draft protocol.  Although Harrington had noted the “critical problem” of separating pumping impacts from other sources of water table variance and questioned the need for further operational tests (as quoted above) (Harrington 2001 and 2002), his concerns were not raised in the comments.  ICWD did comment, however, that the protocol should state that, "In the event of a disagreement at the Technical Group over whether the operation of the wells has caused a decrease in shallow water tables, or may cause a decrease in flow from a spring or seep, the test will be discontinued" (James 2002a).  This comment is important because it would have required the test be ended even if the Technical Group failed to agree on attribution of drawdowns to the test pumping.  In effect, it would have allowed either ICWD or DWP to terminate the test.

Initiation of the 2003 test

In April 2003, DWP released its proposed annual operations plan for the 2003 - 2004 runoff year.  The plan noted, "In order to develop an appropriate management approach for pumping wells screened exclusively to the deep aquifer, LADWP will operate Wells W380 and W381 in the Thibaut-Sawmill Wellfield.  LADWP encourages the County to participate in cooperatively developing a protocol for this deep aquifer pumping that considers the needs of both the County and LADWP" (Coufal 2003).  DWP subsequently sent a revised protocol to ICWD, and ICWD returned comments on the revised version but no agreement was reached on a final protocol (S. Manning, pers. com.).

In summer 2003 wells 380 and 381 went into On status and shortly thereafter DWP initiated an operational test of the wells.  While the Technical Group had not approved the test protocol, with the wells in On status no Technical Group approval was required.

On October 1, 2003, wells 380 and 381 went into Off status.  DWP, however, did not turn off the pumps.   On October 6, 2003, ICWD director Greg James wrote DWP and asked that the wells be turned off immediately unless a Technical Group meeting were held by October 15 and the Technical Group approved a test protocol (James 2003).  No Technical Group meeting was held and the Technical Group did not approve a test protocol. 

Meanwhile, the issue of pumping Off status wells was publicized by KDAY radio, which had obtained a copy of James' letter of October 6, 2003.  The pumping was criticized in letters to the editor of the Inyo Register (Pritchett 2003, Bradburn 2003), while DWP’s Gene Coufal defended the testing.  In a letter to the Editor of the Inyo Register of October 28, 200 Coufal wrote that the test was necessary to “better understand the relationship between pumping the deep wells and the shallow aquifer…” and that the volume of water to be pumped was accounted for in the 2003-2003 Pumping Plan (in other words, pumping elsewhere in Owens Valley would not have to be reduced to make up for the water pumped in the test) .  He also asserted that "LADWP and Inyo County staff agreed to allow pumping to continue to allow time for staff to reach agreement on the final details of the test protocol and to allow the Technical Group time to consider approval of the plan"  (Coufal 2003a).  He did not mention the fact that DWP had ignored ICWD's request for a Technical Group meeting by October 15, 2003 (noted above), nor did he specify which ICWD staff member(s) had made the alleged agreement to allow pumping to continue. 

The agenda for the Inyo County Supervisors meeting of October 28, 2003, contained an item regarding DWP's ongoing pumping of Off status wells.  ICWD Director Greg James explained to the Board that pumping Off status wells was not allowed under the LTWA even for testing purposes.  He therefore needed the Supervisors to determine if Inyo County's position was that the Technical Group had authority to grant a temporary exemption of certain wells from On/Off management for testing purposes. Furthermore, if the Board determined that the Technical Group did have such authority, James asked Supervisors to determine if Inyo County's representatives to the Technical Group were at liberty to exercise their own discretion in deciding whether to approve the "proposed"1 test of wells 380 and 381, or if the Board wished to direct Inyo County Technical Group representatives to approve or not approve the test (James 2003a). 

At the discussion of this agenda item, Mike Prather, representing the Owens Valley Committee, spoke against the test as did Daniel Pritchett (i.e. author of this website) representing the Bristlecone Chapter of CNPS.  The basis for the objections was the likelihood that the testing would delay recovery of the water table under meadow vegetation which had already been impacted by sustained, pumping-induced drawdowns for the past 16 years.  Speakers suggested the test be delayed until after water tables and vegetation had recovered.

Inyo County Water Commissioner Paul Lamos and ICWD Director Greg James spoke in favor of the test2, ICWD hydrologist Dr. Robert Harrington, and DWP's Gene Coufal answered questions in support of James' arguments, while ICWD ecologist Dr. Sally Manning presented data documenting impacted vegetation and water tables below the grass (meadow) rooting zone in the area for the past 16 years.  James explained that the county thought the test was important because the knowledge gained would allow pumping management to be improved, though he did not specify exactly what improvement he expected to take place.  He pointed out that DWP was providing “high-tech” equipment for the test and that the 1996-1998 tests had already shown that the proposed test would be safe.  He also stated that pumping elsewhere in Owens Valley would be decremented by the amount pumped in the test and that no one had expected wells 380 and 381 to go into "off status" on October 1.  He pointed out that if the test were discontinued the pumping already done for the would be wasted and it was not clear when the well would return to On status so the test might be reinitiated.

James did not mention that ICWD staff had, up to this point, not found the test protocol, acceptable.  Nor did he mention Harrington's conclusion that most of the results of the 1996-1998 test were inconclusive (quoted above) , nor did he mention Harrington's arguments against further operational tests (also quoted above).  In fact, he did not disclose the existence of Harrington's 2000 memo and 2001 report at all, nor did he address the issue of the likelihood of the test delaying water table recovery as raised by Pritchett.

After several hours of discussion discussion, Inyo County Supervisors asked that the number of "trigger" wells be increased, then unanimously ordered Inyo County Technical Group representatives to support the test (Mendez 2003).  In doing this the Supervisors retroactively legitimized a month of pumping in violation of the On/Off management protocol, and effectively took for themselves the role of Inyo County representatives to the Technical Group.  This was only the second occasion I know of in which the Board had chosen to act as Inyo County representative to the Technical Group. Neither James nor the Board offered any explanation as to why this was done.

The Technical Group met and approved the protocol (Table 1) on either October 30, 2003 (James 2004) or October 31, 2003 (Coufal 2004).  The approved protocol called for wells to be pumped continuously for 18 months or until water tables in any of 10 trigger wells were drawn down by specified amounts and drawdown was attributable to test pumping.  For five of the trigger wells, the specified drawdowns were derived by estimating the typical seasonal variation and doubling it.  No basis for determination of the specified drawdown for the other five trigger wells was given in the protocol.  A qualitative method (just as Jackson had used in 1996-1998) was proposed for attributing water table variation to test pumping, i.e. comparison of test well hydrographs before and after initiation of test pumping.

ICWD's comment of September 19, 2002 noted above (to the effect that the test should end immediately if the Technical Group disagreed about attributability of drawdowns to the test) was not included in the approved protocol.  Instead, the protocol specified that a Dispute Resolution procedure would be initiated if the Technical Group could not agree on attribution of drawdowns to the pump test.  The cost of Dispute Resolution was to be shared equally by DWP and Inyo County. Monitoring wells were to be read on a complicated schedule which ranged from thrice daily, to daily, to weekly, to bi-weekly. The protocol also required that DWP notify ICWD within 24 hours of the time one of the specified drawdown amounts had been reached in any of the 10 “trigger” wells, and that a meeting of DWP and ICWD staff be held within 48 hours of the notification.  Unless there were agreement at this meeting to continue the test, the test must be discontinued within 24 hours (Montgomery Watson Harza 2003).

Controversy over the test continued in the Inyo Register from November 2003 through January 2004. It was asserted that the tests would “almost certainly lead to delay in recovery of the shallow aquifer under parcel Blackrock 94, arguably the finest remaining wellfield meadow in the valley “ (Pritchett 2003a) and that James had incorrectly stated the total amount of pumping for the 2003 pumping program while speaking in support of the test to Inyo County Supervisors (Bradburn 2003a, Pritchett 2003b)  It was also asserted that James had been incorrect in his assertion at the same Supervisors meeting that pumping elsewhere in the valley would be decremented by a volume equal to the amount pumped for the test (Pritchett 2003b). James defended the safety of the testing, writing that previous testing had not shown any impact to the shallow aquifer.  He also wrote that the test would allow development of "tools to manage future pumping" (James 2003c).

Attempts to continue and discontinue the test in 2004

On March 1, 2004, ICWD director Greg James wrote DWP’s Gene Coufal and asked that the test be discontinued immediately on the grounds that the shallow aquifer was being impacted in that seasonal water table recovery was being delayed.  The letter also noted that on January 23, 2004, water levels trigger well 674 had dropped below the threshold for ending the test.  ICWD, however, thought this was due to influence from flows in the LA Aqueduct and so believed the well should be deleted as a trigger for ending the test.  No mention was made of the fact that it had been known since 1997 that well 674 was influenced by flows in the LA Aqueduct.  The letter concluded with a request for a Technical Group meeting by March 8, 2004 to consider ICWD’s request (James 2004).

On March 3, 2004, Coufal replied to James’ letter of March 1, 2004.  Mr. Coufal cited the following passage from the protocol of October 31, 2003:

“if County contends that there is credible evidence that the test has resulted in, or will result in, an impact of consequence that justifies ending the test, the County may request a meeting of LADWP and County staff to discuss the matter.   Such a meeting shall occur within two working days of a request from the County for such a meeting.  At the meeting it will be determined whether the test should be discontinued.”

He pointed out that, if ICWD wished to discontinue the test, ICWD should have requested a staff meeting within two days to discuss the matter.  Instead, James had requested a Technical Group meeting [eight days later] and Coufal wrote that LADWP was “confused” by James’ request (Copufal 2004).

James responded on March 4, 2004 with another letter.  In this letter he pointed out that LADWP had failed to notify ICWD within 24 hours that the drawdown trigger in well 674T had been exceeded i.e. in violation of the protocol, and that, instead, ICWD had notified DWP that a drawdown threshold had been crossed.   Under these circumstances, if LADWP didn’t discontinue the test, LADWP should have requested a staff meeting take place within two days of receipt of ICWD’s letter of March 1, 2004 (James 2004a). 

In James’ letter of March 1 he had not invoked the drawdown in well 674 as the grounds for requesting the test be discontinued.  To the contrary, he had stated that ICWD believed that well 674 should be deleted as a trigger well. The relevance of his subsequent invocation (in his letter of March 4) of the procedure DWP should have followed when the drawdown in trigger well #674 was noted is unclear.

Although this exchange of letters is confusing, it can be inferred that the drawdown threshold had been reached on January 23, 2004, which means ICWD should have received notice on January 24, and a staff meeting should have been held no later than January 26.  January 23 was a Friday, however, so if allowances are made for the weekend, the meeting should have been held by January 28 at the latest.  Because the notice was never given and the meeting never held, agreement was never reached to continue the test, which, therefore should have ended within 24 hours of January 28, the date when the meeting should have been held, but wasn’t.  Testing subsequent to January 28 was in violation of the protocol.

On March 16, 2004, a Technical Group meeting was held.  Agenda item 3a was a motion to modify the test protocol to delete well #674 as a "trigger" capable of ending the test.  Daniel Pritchett, representing the Bristlecone Chapter of CNPS, made lengthy objections to this on the grounds that passage of this item would assure that the test continued even though ICWD had already asked the test be discontinued.  He also argued that if the designation of well 674 as a trigger was an error (because it is influenced by flows from the aqueduct) of commission, failing to define any trigger mechanisms sensitive to the delay in water table recovery was certainly an error of omission and that the errors offset each other.  He noted that in oral comments to the Inyo County Supervisors and written comments to the Inyo Register he had stated that the test would almost certainly bring about a delay in water table recovery and if any change were made to the protocol it should be the addition of a new trigger sensitive to this phenomenon.  Finally, he pointed out that since Inyo County Supervisors had directed ICWD members of the Technical Group to pass the protocol, permission from Inyo County Supervisors was needed to change it.  Neither ICWD nor DWP Technical Group members responded to these comments and item 3a passed with no discussion.

Agenda item 3b was a motion to modify the test protocol to allow DWP more time before it delivered test well data to ICWD.  Mr. James stated that there was an "internal inconsistency" in the monitoring requirements of the test protocol due to the fact that it required DWP to give 24 hours notice when the specified drawdown in a trigger well had been crossed, but didn’t require the trigger wells to be read on a daily basis.  Further discussion led to the realization that no one in the Technical Group knew exactly how often test wells were actually being read.  It was impossible, therefore, to determine which (if any) of the protocol’s monitoring requirements were actually being implemented and, therefore, impossible to determine how they might best be modified.  DWP promised to provide information to the county after the meeting and no action was taken.

Agenda item 3c was a discussion of ICWD's request that the test be discontinued.  ICWD hydrologist Robert Harrington stated that 10 test wells showed impacts to the shallow aquifer even though the specified drawdown amounts had not been reached in trigger wells, (with the exception of well 674, which had just been stripped of its trigger status in agenda item 3a ), and he showed hydrographs from two of them.  DWP's Gene Coufal stated that he would have to consult with DWP's hydrologist, who was not present, before he could make any decision about ending the test.  In the discussion, it was disclosed that ICWD had already discussed these data with DWP and already knew DWP would not agree to end the test

Although this was not discussed at the Technical Group meeting, one of the wells James (2004) cited (in his March 1 letter requesting discontinuation of the test) as showing a pumping-induced impact was well 804T.  This is the monitoring well associated with permanent monitoring site TS4, which controls management of wells 380 and 381 under On/Off management.  The hypothesis that this well was not impacted by pumping from wells 380 and 381 led to the initiation of testing in 1996 (Jackson and Coufal 1996).  James’ reinterpretation of results of the 1996 tests as “not showing a detectable decline in the On/Off monitoring site [i.e. TS4 - 804T]” associated with the wells (James 2003c) had figured prominently in his justification of  the 2003 testing.

After the Technical Group meeting of March 16, 2004, DWP’s Coufal was quoted in the Inyo Register as saying that  “there could be any number of other factors… combining with the pumping [of wells 380 and 381] to create the changes in groundwater level” (Klusmire 2004).  There is no indication of whether Coufal was aware of the irony in his statement.  Coufal was noting the same difficulty in separating “signal” from “noise” that ICWD hydrologist Harrington had observed in his analysis of the 1996-1998 test results and described as a “critical problem” which “severely hampers observation of pumping affects in the shallow aquifer” (quoted above).  Coufal, however, used the observation to justify continuing the ongoing operational test, while Harrington had used the observation in support of arguments that operational tests be replaced with testing directed toward supporting hydrological modeling efforts (Harrington 200 and 2001).

In a subsequent letter to the editor of the Inyo Register Coufal “clarified” the discussion of the testing of wells 380 and 381 at the Technical Group meeting of March 16, 2004 (Coufal 2004a).  Mr. Coufal wrote that ICWD and DWP were “cooperatively conducting a test…” and that “ICWD staff said that they plan to continue evaluating the test results for evidence of an impact or consequence that justifies terminating the test” (Coufal 2004a). He didn’t mention that ICWD had already found data that justify terminating the test and had, in fact, made two requests to DWP to discontinue the test.  Neither did he mention how DWP’s decision to ignore ICWD’s request to end the test could be understood as “cooperatively conducting a test.” 

On April 6, 2004, ICWD released information DWP had provided regarding the frequency of its reading of test wells associated with the well test.  These data were promised during the discussion of agenda item 3b in the Technical Group meeting of March 16, 2004 (as noted above).  The data showed two of the nine trigger wells were being read every two weeks, in conformance with requirements of the protocol. No data were provided regarding the reading of the remaining seven trigger wells.  Of the remaining non-trigger test wells associated with the well test, 15 were reported to be read in compliance with the protocol, two were reported to be read monthly instead of bi-weekly, i.e., in violation of the protocol, while frequency of reading of at least 14 shallow non-trigger wells was not provided.  DWP stated that it lacked the personnel to read test wells with greater frequency (Inyo County Water Department 2004).  Neither DWP nor ICWD pointed out that DWP’s own consultant had determined the frequency at which the test wells should be read and that the protocol had been under consideration for over a year before it was finally adopted.

Status as of April, 2004

DWP has refused to discontinue the test so the pumping continues. Because Inyo County Supervisors instructed ICWD Technical Group representatives in October, 2003 to support a version of the protocol which did not incorporate ICWD's 2002 comment that the test should be discontinued if the Technical Group couldn't agree on attribution of drawdowns to the testing, Inyo County must initiate Dispute Resolution proceedings if it wishes to end testing. Neither ICWD nor DWP has made any public references to any "tools to manage future pumping" that are being developed from test results.

Literature cited

1 Although DWP's testing had been going for several months, the adjective "proposed" is consistently used to describe the test in documents for the Inyo County Supervisors meeting of October 28, 2003. 

2 The official minutes of the meeting state only that James “provided additional information and explanation on the request for direction” (Mendez 2003) rather than advocating support of the test.  Having attended the meeting, however, I can attest that he was de facto in the role of an advocate for the test.  Margaret Bradburn described James as having “strongly urged the supervisors” to support the testing (Bradburn 2004)


I am solely responsible for the contents of this document.  While I have attempted to accurately and fairly summarize the documents and proceedings of meetings cited above, mistakes may be present.  I apologize for any errors and welcome corrections.  Please sent them to

--- Daniel Pritchett, April 2004


Table 1. Test Protocols

Protocol Date

Duration of test

Volume pumped

Criteria for ending test

Test wells to be monitored

Surface water monitoring sites

Frequency of reading test wells

Protocol Date

Duration of test

Volume pumped

Criteria for ending test

Test wells to be monitored

Surface water monitoring sites

Frequency of reading test wells

October 1996

100 days

1300 AF

Fixed length

26 shallow, 12 deep

6 sites

Twice-weekly, weekly, bi-weekly

January 1997

Three months requested, One month actual (extension of October 1996 test)

400 AF

Fixed length

Same as above

Same as above

Same as above

October 1997

Up to six months (resumption of October 1996 test)

2400 AF

Until shallow aquifer impacts noted or March 31, 1998 (Actual termination April 24, 1998)

Same as above

Same as above

Same as above

August 2000 (proposed)

Six months: October 1 2000 - March 31, 2001

2400 AF

Fixed length

17 shallow, 4 deep

2 sites

Twice-weekly, weekly, bi-weekly

July 2002 (proposed)

Minimum of 10 months, Maximum of 18 months

Up to 7200 AF

Specified drawdowns in any of six key monitoring wells or 18 months

30 shallow, 13 deep

28 sites

Thrice daily, daily, weekly, bi-weekly

October 2003

Minimum of 10 months,  Maximum of 18 months

Up to 7200 AF

Specified drawdowns in any of ten key monitoring wells or 18 months

32 shallow, 13 deep

28 sites

Thrice daily, daily, weekly, bi-weekly