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Summary Carroll et al. (2009) state that the United States Geological Survey (USGS) Death Valley Regional Flow System (DVRFS) model, which is based on MODFLOW, is “conceptually inaccurate in that it models an unconfined aquifer as a confined system and does not simulate unconfined drawdown in transient pumping simulations.” Carroll et al. (2009) claim that “more realistic estimates of water availability” can be produced by a SURFACT-based model of the DVRFS that simulates unconfined groundwater flow and limits withdrawals from wells to avoid excessive drawdown. Differences in results from the original MODFLOW-based model and the SURFACT-based model stem primarily from application by Carroll et al. (2009) of head...