2012 AACE INTERNATIONAL TRANSACTIONS

PS.841

The Law of Schedules

John C. Livengood, Esq., AIA CFCC PSP

and
Patrick M. Kelly, PSP

ABSTRACT Construction managers, program managers, contractors, owners, and planning and
scheduling professionals in the construction industry work with schedules every day. Yet what do
they know about the legal import of a schedules creation, approval, acceptance, management,
modification and updating? Further questions include: Do you need to have a schedule? Will a
PDF barchart of your P6 schedule meet the CPM schedule requirement? Do more detailed
schedules change the legal landscape? Do approvals/acceptances make a difference? Is having a
baseline important? If you want to finish early, what are the requirements? Do contractors have
to coordinate with their subcontractors in order to have a legally sufficient schedule? What role do
schedules play in the legal determination of negligent management? This paper reviews historic
and recent case law on these issues as well as proposes resolutions for topics not yet addressed by
the courts.

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Table of Contents

Abstract ............................................................................................................................... 1

Introduction ........................................................................................................................ 3

The Problem ........................................................................................................................ 3

Is a CPM Schedule Required? ............................................................................................. 3

Who develops the CPM schedule? ..................................................................................... 4

What constitutes a reasonable baseline schedule? ........................................................... 5

Do baseline schedules have to plan for weather?.............................................................. 6

Do baseline or update schedule submissions have to be Approved?............................. 6

Are updates required? ........................................................................................................ 7

What constitutes a reasonable update schedule? ............................................................. 7

What does timely submission mean? ............................................................................. 8

Are Preliminary Schedules a good idea? ......................................................................... 8

Who owns the float? .......................................................................................................... 8

What about float Ownership clauses? ............................................................................... 9

What if the specification prohibits float sequestration? .............................................. 10

Do Contractors have to follow the specification methodology for Time Extensions? ..... 10

What is necessary to establish early planned completion? ............................................. 10

Conclusion ......................................................................................................................... 11

Bibliography ...................................................................................................................... 12

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Introduction
Construction managers, program managers, contractors, owners, and planning and scheduling
professionals in the construction industry work with schedules every day. Yet what do they
know about the legal import of a schedules creation, approval, acceptance, management,
modification and updating? Further questions include: Do you need to have a schedule? Will a
PDF barchart of your P6 schedule meet the CPM schedule requirement? Do more detailed
schedules change the legal landscape? Do approvals/acceptances make a difference? Is having
a baseline important? If you want to finish early, what are the requirements? Do contractors
have to coordinate with their subcontractors in order to have a legally sufficient schedule?
What role do schedules play in the legal determination of negligent management?

These are but a few of the more intriguing questions revolving around CPM scheduling and its
real-world application in the practical art of project controls. Unfortunately, courts and
contract appeals boards at both the state and federal level have left huge areas of schedule law
unresolved. CPM scheduling, developed in the 1950s, only became reasonably common in the
1970s and 1980s it simply has not been around long enough to develop a detailed body of
legal decisions. Most of the legal decisions have been rendered in the very narrow venues of
the US Federal Courts and Boards of Contract Appeals. These decisions have resulted in a small
cadre of judges who are expert in construction issues. While there are decisions in state courts,
virtually all technical/legal issues facing a trier of fact in state court venues have no local
precedence to rely on [24]. Further, with the increasing cost of litigation and the greater use of
more cost-effective dispute resolution mechanisms, the volume and detail of published
decisions concerning schedule law is decreasing and likely to continue to do so in the
future[24]. With that caveat, we offer our best understanding of what the Law of Schedules is
today in the format of questions and responses.

The Problem
Question: The contract specification requires a schedule that depicts the orderly development
of optimized, time-phased, logically-related plans for project execution. The result of these
processes is a graphic depiction or listing, or both, of planned project events, their expected
start dates, duration, and relationships to other planned project events. Does this mean a CPM
schedule is required?

Answer: No. For an owner to require a contractor or a construction manager to provide a CPM
schedule, that requirement must be specifically identified in the contract. The reason is
manifest: projects, even complicated ones, were built before CPM schedules existed. Even in
the world of detailed construction contracts, which started in the mid-1800s , CPM scheduling
is a relatively new planning tool. The board concluded in H.I. Homa that even when the
specification stated that the submitted schedule must be acceptable to the contracting officer
(owner), unless the specification was explicit, there was no requirement for a CPM schedule
[12]. In this case, the contracting officer insisted upon a CPM schedule, and the contractor
provided one. The board ruled that contractor was entitled to additional compensation for this
change. However, the benefits of CPM scheduling to the contractor extend beyond answering

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a contractual need or providing owners with progress information. The contractors overall
performance is likely to be improved by the simple process of preparing and updating a CPM
schedule. Further, the contractor may need to demonstrate the impact that project events had
on either the completion date or the costs to achieve the completion date. The contractor
bears the responsibility of proving the extent of delays and of relating the delays to specific
actions by the government [42]. Furthermore, the contractor bears the burden of separating
and apportioning delays, and for determining the existence of concurrency [35, 43]. The
contractor, then, would be well advised to develop a CPM schedule that can provide the best
support in these tasks, irrespective of the contract provisions. Bar charts are often insufficient
to prove the existence of delays and to tie causes with effects [19].

Question: Who Develops the CPM Schedule?

There are three obvious candidates who could and often do develop schedules: designers,
owners, or contractors/CMs. Each candidate has separate issues.

If the designer develops the schedule, it is usually developed in the context of determining
overall duration feasibility and general sequence. For example, a major governmental entity on
the east coast of the US has traditionally required the designer to develop a CPM schedule, a
graphic representation of which is then included with the contract documents. This CPM
generally has no legal standing in the relationship between the owner and contractor. The
contractor is often specifically prohibited from relying on the feasibility and practicality of the
designers CPM schedule. Under this view, the schedule is developed only as an aid to the
contractor to establish that there was a reasonable basis for the contract duration. However,
unless the contract specifically states that the included schedule is for information purposes
only and cannot be relied upon, the Spearin Doctrine holds that there is an implied obligation
from the owner (acting in this case as principle for the designer) to the contractor, that the
project can be built in accordance with the construction documents, and that the project can be
completed within the time indicated [17, 33]. The designer has no liability to the contractor in
this case, although it is theoretically possible that liability could accrue as between the owner
and designer if the schedule had defects in it. This situation rarely occurs because courts and
boards of contract appeals usually find that since the contractor is not required to use the
designer-generated CPM, there is no liability against the designer for its defects. [10]

Much the same problem can arise if the owner independently develops a schedule. This occurs
rarely since it is uncommon for the owner to have the technical capability to develop a CPM
schedule. However, some owners are beginning to develop those skills, and are identifying
overall project durations and other schedule development functions. Additionally, the owner
does often develop contractual milestones that impose some schedule control and logic. These
milestones often carry liquidated damage charges and as such are almost always included in a
CPM schedule.

Contractor-generated CPMs are the responsibility of the contractor and generally do not create
any duty from the owner toward the contractor for performance. Since the contractor is
responsible for the means and methods of construction, the CPM is viewed as part of those

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means [15]. Owners should be aware, however, of contractors are representing owner activities
in the CPM schedule, and may assign original durations to those activities which are not
realistic. Given the fact that contractors will try to use these schedules to demonstrate delays,
owners will want to ensure that their responsibilities are reasonably represented in the
contractors schedules.

Subcontractors generally have no responsibility for the development of the initial project
schedule or its subsequent changes. Nevertheless, this is a bad policy and general Contractors
are well advised to not only involve subcontractors in the development of the schedules, but
also to advise them of progress and changes. If the general contractor fails to consider the
needs of the subcontractor and excludes the subcontractor from participating in the schedules
development, the prime contractor may have created a liability for its poor management [38].
Subcontractors that do participate in the development of the initial schedule may have even
greater rights than those who dont. Some courts have found that the prime contractor may
not alter the schedule in a manner so as to adversely affect the performance of the
subcontractor without incurring liability for the action [21]. This position is largely corrected by
the now typical clause that requires subcontractors to adhere to the contractors schedule.

Development of schedules by an agency construction manager (CMa) is a grey area in the law.
The CMa is an agent of the owner and has no responsibility for means and methods of
construction. However, an overreaching CMa can functionally assume the responsibility
normally of the general contractor. In a multi-prime situation typical of EPC contracts, the CMa
can assume overall CPM responsibility [5a].

Question: What Constitutes A Reasonable Baseline Schedule?

The obvious answer is that it is whatever the contract requires. Detailed specifications often
contain pages of very specific detail that are ignored with surprising frequency. Such
specification may discuss number of activities, the type of logic connection, the duration of
activities, and detailed submission requirements. They also often contain sentences similar to
the following:

The schedule for this contract shall be constructed to show the order in which the
general contractor proposes to carry out the work, and to indicate the
restrictions of access, availability of work areas, and the availability and use of
manpower, materials, and equipment. The contractor shall use the schedule in
planning, scheduling, coordinating, and performing the work under this contract
(including all activities of subcontractors, equipment vendors, and suppliers). The
schedule must reflect the complete scope of work, and must present a feasible
and reasonable plan for the sequence of work, the duration of individual
activities, and for the overall duration of phases and the project.

The requirement for a feasible and reasonable plan is supported by significant case law as
courts have often found that the absence of a feasible and reasonable plan makes the

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schedule useless as a tool to either manage the ongoing work, or to evaluate time extension
requests [7, 23, 27].

Specifications are unfortunately often silent on the exact submission requirements of the CPM
schedule. For example, in one project, the contractor interpreted the following specification
clause as only requiring the submission of a PDF of the baseline and monthly update schedules.
The owner interpreted the contract language to require the submission of a CPM in native
format:

4.1 Project Schedule

4.1.2 Within ninety (90) days after execution of this agreement, the
design/builder shall submit a detailed project schedule in CPM format, which
shall include the milestones, set forth in exhibit N-2 and which shall indicate a
commencement date for the work approved by the owner. At a minimum, the
project schedule shall include the necessary activities, relationships, and
durations of such components [25]

The requirement for cost loaded scheduling is still rare in most US contracts, either those based
on industry standards such as the AIA, or custom specifications such as quoted above.
Schedules that are resource loaded put a burden on both the Contractor and the owner
because the Owner may have to maintain independent records to check on the loading. In the
US, this seldom happens [22, 39].

Question: Do Baseline Schedules Have To Plan For Weather?

The baseline schedule must show a plan for accommodating weather events that can be
reasonably predicted [4]. The methods of determining what constitutes these planned adverse
weather days vary, but the most commonly accepted methods in scheduling involve
estimating an average number of non-work days that can be expected in each month because
of weather [18]. Again, beyond the fact that estimating the effects of weather on a project is
prudent planning, the courts have held that the Contractor will not be able to seek time
extensions for unusually severe weather without showing that their baseline plan reasonably
estimated the effects of likely adverse weather [2].The AACE will publish a Recommended
Practice on this subject in 2012.

Question: Do Baseline Or Update Schedule Submissions Have To Be Approved?

Most construction contracts include a requirement that the baseline schedule be submitted to
the owner for approval, acceptance or assent. Many of these contracts include time periods for
owner action of 14, 21, 28 or 30 days. If the contract permits rejection, the reasons for such
rejection must be provided. Practically, the owner can reject for any reason. The reasons for
requiring approval are manifest how can an owner enforce a feasible and reasonable
requirement if it does not have the power to reject a submitted schedule?

Owners correctly believe that accepting a schedule means they agree that the schedule
constitutes a reasonable plan for the execution of the work [9]. Failure to either approve or

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reject a schedule submission has also been ruled as to act as if it were approved [8]. As a result
some owners use the language that states they accept or assent to the schedule.
However, there is no legal difference in this situation between approval and acceptance or
assent. In these situations the owner has agreed that the plan presented by the contractor is a
feasible and reasonable approach to the construction.

If it appears during the execution of the project that the original schedule was not feasible and
reasonable, the owner can present evidence of the schedules inadequacies. Current law
seems to be that there is a rebuttable presumption of the baselines schedule reasonableness
a presumption that can be rebutted in subsequent litigation. Defect more recent U.S. cases say
that approval/acceptance of a schedule creates a rebuttable presumption that the schedule
was sufficient and in accordance with the contract. The owner is free to rebut that
presumption. This is clearly a better and more modern position [22, 31].

Question: Are Updates Required?

Virtually all contracts require the contractor to provide updates periodically. Court decisions
concerning periodic updates are similar to those related to baseline schedules. In addition,
courts in the US have found that schedules that are NOT updated are of little or no value, and
cannot be used either for managing the project or in subsequent delay actions [7].This applies
to Contractors that fail to update a schedule, and owners who fail to issue change order time
extensions in a manner so as to reflect ongoing work [3, 20].

Question: What Constitutes A Reasonable Update Schedule?

The contract specifications should clearly identify the submission requirements. Updates
should include:

Corrected logic that reflects actual and planned events in the field
Revised durations that reflect actual experience
Revised logic that corrects out-of-sequence work
Identification of logic tie changes
Accurate actual start and finish dates
Written narrative

In addition to the palpable benefits to project management that these good scheduling
practices will yield, providing fully developed updates in this way will document the changing
nature of the critical path of the project. It is widely held that the critical path is not static on
most projects, and that it shifts based on relative levels of progress within different areas,
resources, unexpected changes, or other issues [34]. Schedule updates that fail to meet these
criteria may be deemed useless in any subsequent proceedings under the theory that they fail
to accurately represent the project [15].

A related issue is the concept of re-baselining. This occurs when circumstances require a radical
revision to logic and to durations that reflect a significantly altered plan for the remainder of
construction after a major change or series of delays. If a project experiences significant delay

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or disruption, then it may be necessary for the contractor to completely revise the planned
sequence of work. Although the scale of the changes may differ from those implemented in a
typical update, the best way to handle this eventuality is through the existing updating process.

Question: What Does Timely Submission Mean?

Most contracts, both standard and custom, require that an initial schedule be submitted within
a certain time period. These submissions must meet the specific contract requirements, and if
they fail to do so, the owner must notify the contractor of the inadequacies of the submission.
The owner must act within a certain number of days in making its determination.
Unfortunately, there is seldom a suitable enforcement provision. Contracts with penalties or
non-payment provisions in the event on a failure to submit a schedule in a timely manner are a
useful way to assure compliance with the provision. Nevertheless, even in this situation it can
be unclear when the enforcement provision takes effect since the trigger is the failure to
submit a feasible and reasonable plan. Because the determination of this criterion is wholly
within the owners discretion, contractors often have legitimate complaints about
unreasonable rejection of the baseline schedule. There is no solution to this problem except
that the contractor follow the contract and provide the required materials within the required
time period, and the owner promptly and fairly evaluate the submission.

Question: Are Preliminary Schedules A Good Idea?

More complicated projects often require a preliminary schedule to cover an initial period of
project performance, usually 90 days. This requirement allows the contractor to develop its
plan for mobilization and early work within a relatively short time frame, and then to have
sufficient time to develop a more complete schedule for the entire project. The preliminary
schedule usually must be approved by the owner, just as the baseline schedule does. Such a
provision makes perfect sense for large complicated projects where the development of the
detailed baseline schedule will require the involvement of suppliers and subcontractors.

Question: Who Owns The Float?

For more than 30 years, the settled law in the US is that activity float is a shared resource,
available to whoever gets there first [36, 40]. This rule, applied largely through inertia, is
codified in most Federal contracts and is considered the default position for responsibility for
the consumption of activity float [5b, 6, 30, 41]. Project float - the time between the
Contractors planned completion and the contract completion date - is generally considered a
Contractor resource [5c]. However, there has always been an undertone concerning the proper
allocation of float as reflected in numerous academic articles and presentations [1, 28, 29].
More recently, the controversy between those espousing shared resource rule and the
contractor float rule reached the pages of Engineering News Record (ENR) [16]. While the
arguments are not new, the underlying arguments discussed in the ENR article are three
fold[13]:

The shared resource rule is contrary to US law as it concerns responsibility for

damage. If an owner delays an activity with 12 days of float by 10 days, and
then the contractor delays the same activity by 5 days, it appears that the

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proximate cause of the delays is at least partially the responsibility of the

owner and the owner should not be excused from that responsibility simply
because it delayed the activity first.

The shared resource rule does not allocate the risk for the delay to the party
best able to control responsibility. Since the schedule is virtually always created
by the contractor and a construction law fundamental is that the contractor is
responsible for means and methods of construction, and the party best able to
manage owner delays is the owner, the contractor has significantly more
potential risk under this rule.

The shared resource rule deprives the contractor with a contingency that is
part of its bid. No one seriously argues that when a contractor includes an
additional amount of money to cover unknown risks, the owner is entitled to
demand using that money for owner changes. Yet the shared resource rule
allocates contractor time-contingency to the party that gets there first.

The contrary view is that the shared resource rule reflects six different reasons for shared
float ownership [37]:

Float is not a resource created by the contractor. Rather it is a by-product of a

CPM schedule and changes almost continuously during the execution of a
project.

Float is often created by both the owner and contractor.

Float is less important now with the common use of precedence diagramming
method (PDM), than it was 20 years ago when arrow diagramming method
(ADM) was commonly used.

It can be difficult to impossible to properly identify damages resulting from float

consumption.

There is no advantage to the contractor to own the float as it controls the

schedule.

Float sharing provisions encourage resolution of delay issues as part of the

ongoing project management process.

The current law clearly supports the common understanding that float is a shared resource
available to the party that gets there first. However, the recent articles cited here are likely to
re-invigorate the discussion on this topic.

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Question: What About Float Ownership Clauses?

Courts have not addressed specifically the issue of float ownership clauses. Nevertheless, the
renewed interest in the issue has illuminated that any ownership clause has a significant down
side. At least one commentator has argued that float ownership clauses are a bad idea for
either party since the contractor still has the opportunity to control the schedule and could
sequester float. As such, the owner may actually hurt its position by inserting such a clause.
Further, there may be no float available when an owner legitimately takes more time on one of
its activities than planned.

Question: What If The Specification Prohibits Float Sequestration?

Anti-float sequestration clauses were popular in the 1980s and 1990s. They arose because of
the perceived practice of contractors to prepare schedules that effectively limited the owners
capability of adding work or otherwise adjusting performance without incurring a request for a
time extension. Below is an example of such a clause:

Contractor shall not sequester float through strategies including extending

activity duration estimates to consume available float, using preferential logic,
using extensive or insufficient crew/resource loading, use of float suppression
techniques like zero total float constraints, special lead/lag logic restraints or
imposed dates. Use of float time disclosed or implied by the use of alternate
float suppression techniques shall be shared to the benefit of both owner and
contractor.

Such clauses have generally fallen out of favor in the past decade as it has proven virtually
impossible to enforce such provisions and still allow the contractor to be responsible for the
development and maintenance of the schedule. However, there seems to be no decisions
prohibiting the inclusion of such provisions or even interpreting their meaning and application.

Question: Do Contractors Have To Follow The Specification Methodology For Time

Extensions?
Contractors must follow the methodology identified in the contract for the submission of
requests for time extension. Failure to do so generally results in an automatic rejection of the
request [7]. Such rejection is based both on the contractual mandate and on the practical
aspect that evaluating a potential delay during construction is essential for the owner to make a
prompt and considered decision on the request. A more difficult question is if a forensic
analysis done after the project is complete must use the delay methodology described in the
contract. Here, the law is less clear. As a general rule, if the methodology used forensically is
closely tied to the actual events on the project it will be acceptable, whether it is characterized
as a windows analysis or a time impact analysis [41].

Question: What Is Necessary To Establish Early Planned Completion?

Contractors are generally permitted to complete earlier than the date identified in the contract
[14]. Claims usually arise when a contractor alleges it planned to complete early, but owner
caused delays prevented that from happening, and the contractor is therefore entitled to delay

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damages even if the eventual completion date is timely. There are four requirements for
asserting an early completion claim in the US [14]:

Demonstrated intent to finish early prior to commencement of construction.

Advising the owner of intent to finish early.
Demonstrated capability of finishing early. And,
Proof that owner caused the failure to finish early.

Some contracts in the US now prohibit early completion. In this case, most contractors will
increase activity durations to absorb the float that might otherwise show as excess float at the
end of the project or as contractor retained float. Such contracts are intended to prevent early
completion claims. Some contracts do not prohibit early completion, but advise the contractor
that should they submit a schedule that indicates early completion, they will be issued a no-cost
change order adjusting the completion date to match the contractors schedule.

Risk adjusted schedules pose difficult and as-yet unresolved contractual problems. Some
contractors can choose to build in float to their schedule that accommodates the 90%
probability of finishing on time rather than the often 40% probability associated with typical
schedules. Again, the contractor must be careful how this information is treated in the
contract.

Conclusion
Although there are many manuals and guidebooks [11, 26, 32] on good scheduling practice,
schedulers must understand that little of the detailed work they perform in developing and
implementing CPM scheduling is supported by case law, or is ever likely to be so supported.
The primary guides to what is required for a CPM schedule flow from the contractual
requirements, which are often weak, to professional guides prepared by knowledgeable
experts.

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Bibliography
No. Description

1 Al-Gahtani, K., and B. Mohan S.

2005
CDR.16 - Total Float Management for Delay Analysis
2005 AACE International Annual Meeting Proceedings
AACE International, Morgantown, WV
2 All-State Construction, Inc., ASBCA No. 50513 (Sept. 22, 2004)
3 Ballenger Corp. DOTCAB Nos. 74-32,32A, 32H, 84-1 BCA 84,524.
4 Bigelow, Inc., ASBCA No. 24376, 81-2 BCA 15,300 (1981).
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2007
Section 6.7
Bruner & OConnor Construction Law
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(It should be noted that EPC contracts come in both multi-prime and single
prime varieties.)
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2007
Section 15.125
Bruner & OConnor Construction Law
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Section 15.9
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Construction Schedules
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9 Fullerton Construction Co., ASBCA No. 12275, 69-2 BCA 7876 (1969).

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10 Gassman Corporation ASBCA 44975 (Full Cite Needed)(1999).

11 Glavinich, T.
2004
Construction Planning and Scheduling
2nd Edition
Association of General Contractors
12 H.I. Homa Co., ENGBCA Nos. PCC-41 & 42, 82-1 BCA 15,651 (1982).
13 Hess, S.
2010
Who Should Own the Float
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Winter 2010
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Why Sharing the Float is No Utopia, but Should Be
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23 Nello L. Teer Co., ENGBCA No. 4376, 86-3 BCA 19,326 (1986);
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Whither Construction Law? How Can Construction Law Continue to Grow and
Evolve in the Era of "The Vanishing Trial?"
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28 Ponce de Leon, G.,
1986

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Float Ownership: Specs Treatment

Cost Engineering, Vol. 28, No. 10., October 1986;
AACE International, Morgantown, WV
29 Prateapusanond, A.
2003
A Comprehensive Practice of Total Float Pre-Allocation and Management for
the Application of a CPM-Based Construction Contract
Ph.D. Thesis
Virginia Polytechnic Institute and State University, 2003
30 Hoshino, Kenji P., et al.
Section 1.5.B.7 Delay Must Affect the Critical Path
RP 29R-03 Forensic Schedule Analysis
Page 17
AACE International, Morgantown, WV
31 Santa Fe, Inc. VABCA No. 2168, 87-3 BCA 2168 20,104 (1987).
32 See all the Recommended Practices prepared by the AACE.
AACE International, Morgantown, WV
33 Spearin v. U.S., 248 U.S. 132 (1918).
34 Sterling Millwrights, Inc. v. U.S., 26 Cl. Ct. 49, 75-76, 1992 WL 88368 (1992).
35 T. Brown Constructors, Inc. v. Pea, 132 F.3d 724, (Fed. Cir. 1997) (quoting
Coath & Goss, Inc. v. United States, 101 Ct. Cl. 702, (CITE).
36 Titan Pacific Const, Corp., ASBCA No. 24616, 87-1 BCA 19,626, 17 Cl.Ct. 630,
89 F.2d 1227 (Fed. Cir. 1990).
37 Trauner, T., Manginelli, W., and Furniss, B.
2011
Why Owners and Contractors Should Share the Float
Journal of the College of American Construction Lawyers, Vol. 5, No. 2,
Summer 2011.
38 U.S. v. F.D. Rich Co., 439 F.2d 895 (8th Cir. 1971).
39 Utley-James, Inc., GSBCA No. 5370, 85-1-BCA 17,816 (1984).
40 Weaver-Bailey Contractors, Inc. v. U.S., 19 Cl. Ct. 474, 36 Cont. Cas. Fed. (CCH)
P 75801, 1990 WL 10845 (1990).
41 Wickwire, J., Driscoll, T., Hurlbut, R., and Hillman, R.
2010
9.08[E] at 408
Construction Scheduling: Preparation, Liability and Claims
3rd edition
Aspen Publishers
42 Wilner v. United States, 24 F.3d 1397, 1401 (Fed. Cir. 1994) (en banc)
43 William F. Klingensmith, Inc. v. United States, 731 F.2d 805 (Fed. Cir. 1984).

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John C. Livengood
ARCADIS
john.livengood@arcadis-us.com

Patrick M. Kelly
ARCADIS
Patrick.Kelly@arcadis-us.com

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