Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 1 of 26 PageID #: 11296 Estimate of Economic Impact Resulting from Loss of Residential Potable Water Service Of West Virginia American Water System January 9 through 17, 2014 Vicinity of Charleston, West Virginia Prepared for: The Calwell Practice, LC 500 Randolph Street Charleston, WV 25302 Prepared by: 339 Sixth Avenue South Charleston, WV 25303 jerry@engineeringperfection.net March 27, 2015 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 2 of 26 PageID #: 11297 Estimate of Economic Impact Resulting from Loss of Residential Potable Water Service Of West Virginia American Water System January 9 through 17, 2014 Vicinity of Charleston, West Virginia Purpose Engineering Perfection was requested by The Calwell Practice, LC to estimate the economic impact to residential customers served by West Virginia American Water (WVAW) and affected by the Do Not Use Order commencing on January 9, 2014 and ending January 17, 2014. Qualifications of Expert This report and the supporting calculations were prepared by Seward G. Gilbert, P.E., DEE, CFM. Mr. Gilbert has more than 40 years of engineering experience. As a commissioned officer of the US Public Health Service, Mr. Gilbert was responsible for the design, construction, and startup of community water supply systems. Working for Union Carbide Corporation, his work included the preparation of cost estimates, economic studies, and assessment of public health risk. His work experience at Union Carbide included wastewater treatment, landfills, groundwater contamination, soil contamination, and regulatory compliance. In 2004, Mr. Gilbert started the company Engineering Perfection, PLLC, located in South Charleston. The company provides engineering services for oil and gas development, government, private citizens and serving as an expert for law firms. Since 2008, Mr. Gilbert has been performing benefit cost analyses for the Federal Emergency Management Agency (FEMA). The FEMA analyses are for potential projects that would lessen the damages from natural hazards. Since 2009, FEMA contracted with Mr. Gilbert to provide training to state and local governments on methods for determining the economic impacts of natural disasters. The training topics include the loss of potable water services to residents. Geographic Information Systems (GIS) is an emerging science, useful for the collection, processing and extracting of intelligence from data. Through training and experience, Mr. Gilbert has become proficient in GIS. In support of his work in West Virginia, he has compiled a substantial library of GIS data for the state, including aerial photography, political boundaries, census data, hydrology, and topography. Page 1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 3 of 26 PageID #: 11298 Affected Residents Approximately 224,180 persons reside in the affected WVAW service 1 area. This estimate is based upon mapping of the service area and determining the number of residents from the 2010 federal census. Customers served by the St. Albans municipal water system are excluded from this estimate. Details of the method and computations are provided in Appendix A. Affected Residential Person-Days The Do Not Use Order was in place for approximately 1,372,701 persondays. This is based on the estimated 224,180 residents in the service area. The Do Not Use Order was in effect for four to eight days, depending on the service area of each resident. The public was notified to not use WVAW product at a 5:45 pm press conference on January 9, 2014. WVAW published maps on their internet site to inform customers of their status. The Do Not Use Order was lifted for the first zone on January 13, 2014 and last zone on January 17, 2014. The average period of time that the Order was in place for residents is estimated to be 6.12 days. Details of the method and computations are provided in Appendix B. Residential Water Consumption The residential water consumption under normal circumstances is a factor in calculating the economic impact. Using data provided by WVAW for more than 50,000 customers, the average residential customer consumption is 148 gallons per day. The average consumption per resident is 70 gallons per day. Details of the calculation of the average number of residents per household are provided in Appendix B. Details of the calculation of the average consumption per household are provided in Appendix C. Residential Water Cost The residential water unit cost under normal circumstances affects the estimation of economic impact. Using data provided by West Virginia American Water for more than 50,000 customers, the unit rate for water is $0.012 per gallon. Details of this calculation are provided in Appendix D. Residential Economic Impact The Do Not Use Order stated “West Virginians in the affected service areas are urged NOT to use tap water for drinking, cooking, washing or bathing.”2 Residents were advised that water use for flushing toilets and for fire protection was acceptable. 1 2 Numbers are reported as computed; accuracy for most numbers is two significant figures. http://www.governor.wv.gov/Pages/State-of-Emergency.aspx, retrieved May 6, 2014 Page 2 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 4 of 26 PageID #: 11299 As the public became aware of the incident, they purchased virtually all of the bottled drinking water from retail stores in the region. Drinking water was soon provided by a cooperative effort of local, state, and federal governments. The drinking water was provided in bottles and in bulk. Distribution sites were established throughout the affected region. State and Federal government agencies provided an estimated 3.1 million gallons of water to residents during the emergency. The residential economic impact is estimated using a methodology developed by the Federal Emergency Management Agency (FEMA). References, assumptions, and details regarding the methodology are provided in Appendix D. Utilizing the FEMA methodology, an estimate of residential water consumption based on West Virginia American Water meter readings, and West Virginia American Water service rates, the estimated welfare loss for the January 2014 incident is $37.79 per resident per day. The total estimated welfare loss for the residents of the affected area is computed to be $51,876,921. Details of this calculation are provided in Appendix E. Page 3 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 5 of 26 PageID #: 11300 Conclusions The Do Not Use Order impacted an estimated 224,180 residents. The Do Not Use Order restricted residential water use for an estimated 1,372,701 resident-days. The estimated welfare loss from the Do Not Use Order is $37.79 per resident-day. The total estimated welfare loss for the residents of the affected area is $51,876,921. Limitations This estimate of welfare loss considers only the immediate impacts to residential customers. Not considered in the estimate are losses such as the continued purchase of bottled water by residents after the Do Not Use Order was lifted and the closure of public and private schools. Within the limitations of scope, schedule and information available, our services have been executed in accordance with generally accepted practices in the field of environmental engineering in this area at the time this report was prepared. No warranty or other condition, express or implied, should be understood. Engineering Perfection reserves the right to amend, modify, and/or revise this report as further analysis is conducted and as addition information is considered. Page 4 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 6 of 26 PageID #: 11301 Appendix A Determination of Affected Residents An estimated 224,180 persons reside in the West Virginia American Water affected area. This estimate is based upon mapping of the service area, excluding the St. Albans Municipal Utility Commission customers, and determining the number of residents from the 2010 federal census. Note that the State of Emergency by Governor Tomblin included a broader area and greater number of residents than indicated by the estimate above. The State of Emergency Declaration on January 9, 2014 states “Gov. Earl Ray Tomblin this evening issued a State of Emergency for Boone, Cabell, Clay, Jackson, Kanawha, Lincoln, Logan, Putnam, and Roane counties. This declaration follows a notice from West Virginia American Water Company that its water supply had become contaminated. Residents served by Lincoln PSD, Queen Shoals PSD, Reamer PSD, City of Culloden PSD, and City of Hurricane PSD are also affected.”3 The total number of affected residents is approximately 490,000 persons, if each of the above counties is considered affected in its entirety. Some residents outside the actual affected area but within the counties included in the initial declaration likely limited their use of water. Also, the residents on the St. Albans water system may have abstained from potable water use for a significant time if they relied on the Governor’s declaration, the WVAW maps, and press releases. Inclusion of these unaffected areas in official announcements would result in economic impacts; these impacts are not considered in this report. The affected area for this report was estimated based on the map displayed on the WVAW web site during the period of the Order. The map is displayed in Figure A-1 below. Also used to estimate the affected were a shapefile of the West Virginia American Water pressure zones and a shapefile of the West Virginia American Water distribution system.4 The estimated service area for the St. Albans city water distribution system, which obtains water from the Coal River, was not included in the affected area. An estimate of the perimeter of the City of St Albans water system was prepared, based on the corporate city limits and a narrative report of the system service area found on the city web site5. 3 http://www.governor.wv.gov/Pages/State-of-Emergency.aspx, retrieved May 6, 2014 Received from counsel for WVAW January 28 and February 6, 2015 5 http://www.stalbanswv.com/municipal.shtml, accessed May 13, 2014 4 Page A1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 7 of 26 PageID #: 11302 Figure A-1 West Virginia American Water Service Area Page A2 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 8 of 26 PageID #: 11303 The digitized perimeters of the affected area and the St Albans service area are displayed below in Figure A-2, with county borders as a background for the map. Figure A-2 Digitized Perimeter of the Affected Area The number of persons residing in the affected area was determined from the 2010 federal census data. Population data were determined by Census Block. The Census Blocks of the affected area were selected in Geographic Information System (GIS) computer program6, and their populations summed. Only Census Blocks that were wholly within the digitized perimeter representing the affected area were selected. Census Blocks partially within the affected area were not included in the summation; this is a conservative approach. A total of 14,003 Census Blocks are wholly within the affected area, not including the St. Albans estimated water service area. According to the 2010 federal census, there are 224,180 persons residing in the affected area. 6 ArcMAP version 10.3, a product of Environmental Systems Research Institute, Inc., Redlands CA. Page A3 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 9 of 26 PageID #: 11304 Appendix B Determination of Residential Customer Person-Days Affected by Do Not Use Order The Do Not Use Order was in effect for four to eight days, depending on the specific service zone. The public was notified to not use West Virginia American Water at a 5:45 pm press conference on January 9, 2014. The duration that residents were affected was dependent on their water service zone. West Virginia American Water published maps on the company internet site to inform residential customers of their status. The lifting of the order was announced by press releases from the Governor’s Office, by area. The areas were defined by neighborhoods and communities. The lifting of the order was also shown on the WVAW web site and in local newspapers. Using the above sources of information, the number of days that the Do Not Use Order was in effect was determined for each census block. In several instances, the terms used to define the areas with the “Do Not Use” order lifted in the press releases of the Governor’s Office were unclear (e.g., Cemetery, Jenkins Hollow) either in their location or their boundaries. The press releases referred to maps available on the internet; however these maps were not available in March 2015 when this analysis was performed. In these instances, specific service areas were estimated. If more accurate information about the Order duration and specific locations become available, reanalysis may be advised. The number of days that the Do Not Use Order was in place was assigned for each census block. Finally, the number of person days that the order was in place was determined. Page B1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 10 of 26 PageID #: 11305 The Do Not Use Order was lifted for the first zone on January 13, 2014. A total of 1,767 Census Blocks have centroids within the released area. According to the 2010 federal census, this released an estimated 25,168 residents from the water use Order. These residents experienced 100,672 resident-days under the Do Not Use Order. Figure B-1 Census Blocks with Centroids in Area Released on January 13, 2014 Page B2 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 11 of 26 PageID #: 11306 The Do Not Use Order was lifted for several zones on January 14, 2014. A total of 2,866 Census Blocks have centroids within the released area. According to the 2010 federal census, this released an estimated 50,558 residents from the water use Order. These residents experienced 252,790 resident-days under the Do Not Use Order. Figure B-2 Census Blocks with Centroids in Area Released on January 14, 2014 Page B3 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 12 of 26 PageID #: 11307 The Do Not Use Order was lifted for several zones on January 15, 2014. A total of 2,642 Census Blocks have centroids within the released area. According to the 2010 federal census, this released an estimated 58,042 residents from the water use Order. These residents experienced 348,252 resident-days under the Do Not Use Order. Figure B-3 Census Blocks with Centroids in Area Released on January 15, 2014 Page B4 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 13 of 26 PageID #: 11308 The Do Not Use Order was lifted for several zones on January 16, 2014. A total of 4,039 Census Blocks have centroids within the released area. According to the 2010 federal census, this released an estimated 52,309 residents from the water use Order. These residents experienced 366,163 resident-days under the Do Not Use Order. Figure B-4 Census Blocks with Centroids in Area Released on January 16, 2014 Page B5 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 14 of 26 PageID #: 11309 The Do Not Use Order was lifted for the final zones on January 17, 2014. A total of 2,689 Census Blocks have centroids within the released area. According to the 2010 federal census, this released an estimated 38,103 residents from the water use Order. These residents experienced 304,824 resident-days under the Do Not Use Order. Figure B-5 Census Blocks with Centroids in Area Released on January 17, 2014 Provided below is a summary table of the release data. Page B6 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 15 of 26 PageID #: 11310 Date Released Residents 1/13/2014 25,168 1/14/2014 50,558 1/15/2014 58,042 1/16/2014 52,309 1/17/2014 38,103 SUMS 224,180 Days Order 4 5 6 7 8 Number ResidentCensus Days Households Residents/Household Blocks 100,672 14,220 1.7699 1767 252,790 24,371 2.0745 2866 348,252 26,213 2.2142 2642 366,163 23,747 2.2028 4039 304,824 17,075 2.2315 2689 1,372,701 105,626 14,003 An average of 6.12 days is calculated for the duration of the Order, by number of residents. An average of 2.12 persons per household is calculated for the affected census blocks. Thus a calculated 1,372,701 resident-days experienced the Do Not Use Order. Page B7 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 16 of 26 PageID #: 11311 Appendix C: Residential Water Consumption in Normal Conditions A key variable in the determination of the economic impact of the loss of potable water is the water consumption quantity in normal conditions. Counsel for WVAW provided four data files with water meter equipment numbers, dates of readings, and reading values.7 The records are for both residential and non-residential customers. Each of the four files contains about 500,000 records, for a total of 2 million records. These data were reduced in the following steps, for each of the four data files: i. ii. iii. iv. v. Readings occurring prior to January 1, 2012 were deleted. The first reading date and corresponding meter reading were denoted for each customer in the files The last reading date and corresponding meter reading were denoted for each customer in the files The average daily consumption was computed by dividing the total number of metered gallons by the interval of time between the first and last reading dates, for each customer The records containing all of the above information were saved. A copy of this file was created, and the data were condensed to approximately 20,000 records. The above five step process was repeated for the remaining three data files.8 The four condensed files were then combined, with about 80,000 records.9 Non-residential customers were then removed from the records, using the customer code “WVRS” found in the WVAW records. The records of 54,297 WVAW residential customers were used to calculate the average daily use by household. The average water consumption by household is 148 gallons per day. The average daily use by household was then divided by the average number of persons per household. There are 2.12 residents per household, on average, as determined from the 2010 census data for the overall impacted area. Dividing the household consumption by the number of residents per household yields an average daily water consumption of 70 gallons per resident. 7 Usage Data_RPD 4\SAP\CGC0007991_0001 Meter Read History Part 1.csv.xlsx\'Meter Read History Part 1$', etc. 8 CGC0007991_0001 Meter Read History Part 1Gilbert Analysis.xlsx, etc. 9 File path Calwell Elk River Contamination 2014\Consolidated Summary Meter Read History Gilbert.xlsx Page C1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 17 of 26 PageID #: 11312 Appendix D: Residential Water Cost in Normal Conditions The residential water cost under normal conditions is a variable in the determination of the economic impact of the loss of potable water. WVAW has published their rate structure on the internet.10 The average water cost was computed based on the daily average residential water consumption determined above. Applying the published rate schedule, the average monthly cost for households in the WVAW service area is $53.50. Dividing the average monthly cost of water by the number of gallons consumed yields a unit rate of $0.012 per gallon. 10 http://www.amwater.com/wvaw/customer-service/rates-information.html Page D1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 18 of 26 PageID #: 11313 Appendix E Residential Customer Economic Impact The economic impact on residential customers is determined using 11 12 13 14 concepts found in scientific and economics literature. , , , A succinct summary of the literature and methodology is presented in the document “FEMA Benefit-Cost Analysis Re-engineering (BCAR) Development of Economic Values”15 The purpose of this report is to document the methodology employed in FEMA Benefit Cost Analyses for the mitigation of short-term losses of utilities.16 FEMA uses this methodology extensively for the review and approval of mitigation projects valued at more than one hundred million dollars per year.17 The mathematical expression for residential customer economic impact from the primary literature source (Brozovic, et. al.) for the FEMA methodology report is reproduced below: 1+𝜂 𝜂 𝜂 𝑄𝑟 (𝑧𝑖𝑡 ) 𝑊𝑖 (𝑧𝑖𝑡 ) = 𝑃𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 𝑄𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 [1 − ( ) 1+𝜂 𝑄𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 ] Where: 𝑊𝑖 (𝑧𝑖𝑡 ) = daily loss of welfare for a consumer 𝜂 = price elasticity of demand for water 𝑃𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 = water price when there are no shortages 𝑄𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 = quantity of water consumed when there are no shortages 𝑄𝑟 (𝑧𝑖𝑡 ) = quantity of water available during restriction 11 Espey, M., J., Espey and W. D. Shaw, “Price Elasticity of Residential Demand for Water: A Meta-Analysis,” Water Resources Research, Vol. 33, No. 6, Pages 1369-1374, June 1997. 12 Brozovic, Nicholas, David L. Sunding, and David Zilberman, “Estimating Business and Residential Water Supply Interruption Losses from Catastrophic Events,” Water Resources Research, Vol. 43, W08423, doi:10.1029/2005WR004782, August 2007. 13 Dalhuisen, Jasper M., Raymond J. G. M. Florax, Henri L. F. de Groot, and Peter Nijkamp, “Price and Income Elasticities of Residential Water Demand: A Meta-Analysis,” Land Economics, pages 292-308, May 2003. 14 Aubuchon, Craig P., Kevin M. Morley, PhD, “Lessons from Short-term Supply Disruption: Providing Confidence and Context to FEMA’s Methodology,” Prepared for Industrial Economics Incorporated under EPA Contract Number EO-W-10-002, Subcontract Number 8070-Aubuchon, undated report found at http://www.indecon.com/iecweb/documents/Aubchon%20&%20Morley%20-%20FEMA.pdf; accessed May 14, 2014. 15 “FEMA Benefit-Cost Analysis Re-engineering (BCAR) Development of Standard Economic Values”, initially prepared for FEMA by URS Corporation and updated by Ideation, Inc., December 2011. 16 See http://www.fema.gov/media-library/assets/documents/92923, accessed May 14, 2014. 17 See http://www.fema.gov/hazard-mitigation-assistance, accessed May 14, 2014 Page E1 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 19 of 26 PageID #: 11314 An important factor in the above equation is 𝑄𝑟 (𝑧𝑖𝑡 ), the quantity of potable water available during the restricted use event. The value used in this study for the potable water available is 3,103,057 gallons based on two letters from the governor of West Virginia.18 For the West Virginia Water residential customers experiencing the Do Not Use Order, the following values are appropriate: Total Number of affected Residents is 224,180 Residential Consumption per day without use restriction is 70 gallons Water use for toilet flushing is 26.7% Potable Water available from emergency services to residents is 3,103,057 gallons Potable Water available from emergency services is 2.26 gallons per resident per day Adjusting the residential consumption for the permissible use of flushing of toilets, the inputs for the Brozovic equation are:19 𝑄𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 = 70 * (1-0.267) = 51.31 gallons per person per day 𝑃𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 = $0.012 per gallon 𝑄𝑟 (𝑧𝑖𝑡 ) = 2.26 gallons per person per day 𝜂 = -.041 The computations in a stepwise manner are then: 1+−0.41 −0.41 −0.41 $0.012 𝑔𝑎𝑙𝑙𝑜𝑛𝑠 2.26 𝑊𝑖 (𝑧𝑖𝑡 ) = ∗ ∗ 51.31 [1 − ( ) 1 + −0.41 𝑔𝑎𝑙𝑙𝑜𝑛 𝑑𝑎𝑦 51.31 𝑊𝑖 (𝑧𝑖𝑡 ) = (−0.69) ∗ ] $0.012 𝑔𝑎𝑙𝑙𝑜𝑛𝑠 [1 − 89.40] ∗ 51.31 𝑔𝑎𝑙𝑙𝑜𝑛 𝑑𝑎𝑦 𝑊𝑖 (𝑧𝑖𝑡 ) = (−0.69) ∗ 𝑊𝑖 (𝑧𝑖𝑡 ) = 53.4 ∗ $0.62 [−88.40] 𝑑𝑎𝑦 $0.012 𝑔𝑎𝑙𝑙𝑜𝑛𝑠 ∗ 51.31 𝑔𝑎𝑙𝑙𝑜𝑛 𝑑𝑎𝑦 18 Letter from Governor Tomlin to Jeffry McIntire, President WVAW, January 30, 2014 and Letter from Governor Tomlin to Elizabeth A. Zimmerman, Deputy Associate Administrator, FEMA, March 11, 204 19 For purposes of illustration, a computation was performed to determine the economic impact had the WVAW water been not available for flushing of toilets during this event. If 𝑄𝑏𝑎𝑠𝑒𝑙𝑖𝑛𝑒 was not reduced by 26.6%, the calculated economic impact would be $81.03 per resident, per day. Page E2 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 20 of 26 PageID #: 11315 𝑊𝑖 (𝑧𝑖𝑡 ) = $37.79 𝑝𝑒𝑟 𝑑𝑎𝑦 The average estimated welfare loss for the event is computed by multiplying the average resident days (1,372,701 resident days) by the daily welfare loss ($37.79 per resident day). The average estimated loss for all residents is computed by multiplying the event average welfare loss per resident by the total number of residents. The collective loss for all residents is calculated by multiplying the loss per resident day by the resident-days. The above computations indicate an estimated welfare loss of $37.79 per resident-day, an average loss for the event of $231.29 per resident, and a collective loss for all residents of $51,876,921.20 20 Because of rounding of numbers, figures beyond two decimal places may not agree. Page E3 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 21 of 26 PageID #: 11316 Curriculum vitae S.G. (Jerry) Gilbert, PE, DEE, CFM jerry@engineeringperfection.net PROFESSIONAL EXPERIENCE ENGINEERING PERFECTION, PLLC South Charleston, WV 2004-Present Environmental and Civil Engineer, Business Owner  Performed investigations, documented findings, prepared technical reports and appeared as an expert in West Virginia courts.  Prepared and presented Webinars for community floodplain managers in West Virginia, under contract the West Virginia Division of Homeland Security and Emergency Management.  Provided technical analysis of flood considerations for numerous gas well development sites in West Virginia. Prepared technical reports and signed/sealed the reports as a Professional Engineer.  Evaluated natural hazard reduction projects for locations throughout the USA for FEMA, for benefit-cost and engineering feasibility.  Provided training to state and local officials on behalf of FEMA on the Benefit-Cost Analysis system used in national grants program.  Performed floodplain analyses for private property owners throughout West Virginia. Scope included land surveying, Geographic Information System analysis, regulatory interpretation, HEC-RAS analysis, and detailed report preparation.  Developed stormwater, erosion and sediment control permits for 700 acre residential development.  Determined flood prevention benefits for two stream restoration projects in West Virginia for FEMA. Prepared comprehensive report for publication by FEMA.  Analyzed methods of estimating flood heights on small West Virginia streams for the West Virginia Office of Emergency Services. Prepared concise report with documentation supporting findings.  Designed, developed and deployed myfloodalert.com, a web based real time flood warning system.  Evaluated civil and environmental engineering universities for accreditation by ABET, Inc. Evaluated program content, transcripts, and facilities for compliance with ABET requirements. Prepared comprehensive reports. THE DOW CHEMICAL COMPANY, South Charleston, WV 2001-2004 Remediation Leader  Completed remediation of metals reclamation site in Texas, located in a residential area (contaminants include lead and PCBs). Led litigation defense team.  Completed destruction of dioxin-contaminated groundwater in Canada  Defined numerous opportunities for cost reduction and improvements in efficiencies in the Dow environmental remediation program UNION CARBIDE CORPORATION, South Charleston, WV 1976-2001 Program Manager and Environmental Engineer (1976-2001)  Completed the site investigation, detailed design and construction for environmental remediation of numerous large manufacturing sites. Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 22 of 26 PageID #: 11317 Curriculum vitae – S. G. Gilbert Page 2      Negotiated administrative consent orders with state and federal governments. Manager for construction valued at >$15 million. Completed remediation of metals manufacturing facility with low level radioactive contamination. Obtained Removal by the Nuclear Regulatory Commission from the Site Decommissioning Management program. Led design teams for industrial wastewater treatment, groundwater remediation, soil remediation, and landfill closure. Prepared project justifications that included detailed cost estimates, evaluation of time value of money, depreciation, tax consequences, and alternative analyses. PURDUE UNIVERSITY, West Lafayette, IN 1974-1976 Graduate Student Performed physical and chemical analyses of West Lafayette public wastewater system. US PUBLIC HEALTH SERVICE, Escondido, CA 1971-1974 Commissioned Officer, Field Engineer for US Indian Health Service  Designed, constructed, and started up sanitation facilities for rural Indians, responsible for $1 million in construction (community water supplies, wastewater collection, anaerobic lagoon, leach field systems).  Negotiated legal agreements with Indian tribes on behalf of the federal government. EDUCATION   B.S. in Civil Engineering, Clarkson College (now Clarkson University) M.S. in Civil Engineering, Purdue University PROFESSIONAL REGISTRATIONS  Registered Civil Engineer in West Virginia PROFESSIONAL ORGANIZATIONS   Member of American Society of Civil Engineers and American Water Works Association Evaluator of civil and environmental engineering programs for accreditation, representing ABET, Inc., the American Society of Civil Engineers, and the American Academy of Environmental Engineers CERTIFICATIONS AND TRAINING     1 Six Sigma Black Belt1 Certified Floodplain Manager by the Association of State Floodplain Managers Benefit Cost Analyst and Trainer for FEMA Board Certified by the American Academy of Environmental Engineers “Six Sigma” is a disciplined, data-driven methodology for eliminating defects in any process. “Black Belt” indicates the level of Six Sigma proficiency – fully capable of independent work. Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 23 of 26 PageID #: 11318 History of Court Testimony S.G. (Jerry) Gilbert, PE, DEE, CFM Deposition on November 28, 2012 re Civil Action No. 12-C-17 in the Circuit Court of Doddridge County, West Virginia Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 24 of 26 PageID #: 11319 Citations and Materials Relied On Preparation of Report “Estimate of Economic Impact Resulting from Loss of Residential Potable Water Service Of West Virginia American Water System January 9 through 17, 2014 Vicinity of Charleston, West Virginia” Prepared by S.G. (Jerry) Gilbert, PE, DEE, CFM Report Dated March 27, 2015 Provided by Counsel for West Virginia American Water Usage Data_RPD 4\SAP\CGC0007991_0001 Meter Read History Part 1.csv.xlsx\'Meter Read History Part 1$', etc. (EXCEL Spreadsheets) 2015-02-05_MainLine (shapefile) Gradient_Zones (shapefile) Master Kanawha Valley Premise BClass (C3048053) (EXCEL Spreadsheet) Premises_perZone_withXY (Confidential) (C3041191) (EXCEL Spreadsheet) CGC0007990_0001 Master_20141014.csv Metering Data (V.2) from SAP for Production (EXCEL Spreadsheet) Obtained from the Internet http://www.governor.wv.gov/Pages/State-of-Emergency.aspx, retrieved May 6, 2014 http://www.stalbanswv.com/municipal.shtml, retrieved May 13, 2014 http://www.amwater.com/wvaw/customer-service/rates-information.html Letter from Governor Tomlin to Jeffry McIntire, President WVAW, January 30, 2014 Letter from Governor Tomlin to Elizabeth A. Zimmerman, Deputy Associate Administrator, FEMA, March 11, 2014 West Virginia American Water press releases from January 13 to 17, 2014 (21 documents in total) US Census Data (file tabblock2010_54_pophu found at https://www.census.gov/geo/maps-data/data/tiger-line.html Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 25 of 26 PageID #: 11320 Technical References Espey, M., J., Espey and W. D. Shaw, “Price Elasticity of Residential Demand for Water: A Meta-Analysis,” Water Resources Research, Vol. 33, No. 6, Pages 1369-1374, June 1997. Brozovic, Nicholas, David L. Sunding, and David Zilberman, “Estimating Business and Residential Water Supply Interruption Losses from Catastrophic Events,” Water Resources Research, Vol. 43, W08423, doi:10.1029/2005WR004782, August 2007. Dalhuisen, Jasper M., Raymond J. G. M. Florax, Henri L. F. de Groot, and Peter Nijkamp, “Price and Income Elasticities of Residential Water Demand: A MetaAnalysis,” Land Economics, pages 292-308, May 2003. Aubuchon, Craig P., Kevin M. Morley, PhD, “Lessons from Short-term Supply Disruption: Providing Confidence and Context to FEMA’s Methodology,” Prepared for Industrial Economics Incorporated under EPA Contract Number EO-W-10-002, Subcontract Number 8070-Aubuchon, undated report found at http://www.indecon.com/iecweb/documents/Aubchon%20&%20Morley%20%20FEMA.pdf; accessed May 14, 2014. “FEMA Benefit-Cost Analysis Re-engineering (BCAR) Development of Standard Economic Values”, initially prepared for FEMA by URS Corporation and updated by Ideation, Inc., December 2011. Mayer, Peter W. and William B. DeOreo …[et. al.], “Residential End Uses of Water,” AWWA Research Foundation and American Water Works Administration, 1999 Case 2:14-cv-01374 Document 679-4 Filed 04/01/16 Page 26 of 26 PageID #: 11321 339 Sixth Avenue P.O. Box 8596 South Charleston, WV 25303 March 30, 2015 Mr. Alex McLaughlin, Esq. The Calwell Practice 500 Randolph Street Charleston, WV 25302 Re: Fee Schedule for Engineering Services, Depositions, and Court Appearances Dear Mr. McLaughlin, You requested that I provide a fee schedule for my engineering services. The rate for engineering services, excluding preparation and appearance for depositions and court testimony, is $160 per hour. The rate for preparation and appearance for depositions and court testimony is $320 per hour. The above rates include document reproduction and delivery for our usual engineering reports. Should the work require the printing of an unusually large number of pages, then actual printing costs will be billed to the customer. Very truly yours, S. G. (Jerry) Gilbert, P.E., DEE, CFM West Virginia Professional Engineer License 12143