Does a Source Water Protection Plan Really Cost $100,000?

Charleston Gazette
29 November 2014
By David Gutman, Staff writer

Tanks at the Freedom Industries site on the Elk River are torn down in July. A leak from the site entered West Virginia American Water’s treatment plant on the Elk River in January, contaminating water for about 300,000 West Virginians. Afterward, state lawmakers told most public water systems in the state to come up with source water protection plans, but the costs of those plans may determine if they actually happen. How much does it cost for a water system to study the hazards around it and make a plan for what to do in case of disaster?

The answer could make a difference as to whether state lawmakers follow through with their mandate that most public water systems in West Virginia have to make such a plan. And different groups have very different ideas about how much such plans cost.

In the wake of this year’s Kanawha Valley water crisis, the bill passed by the Legislature last spring - unanimously, after weeks of contentious debate - requires every public water system (excluding those that are not influenced by surface water) in the state to conduct such a plan.

Those water systems will have to complete their plans - called source water protection plans - by July 2016, unless the Legislature changes its mind.

And the more those plans cost - money that would either be passed on to ratepayers or, if it came from the state budget, taxpayers - the more likely the Legislature is to change its mind.

The new law - SB373 - set up a commission to study, among other things, how much the plans will cost.

When that commission reports back to the Legislature on Dec. 15, it is very likely to ask for a total of $12.2 million, over the next three budget years, for water utilities to complete their plans.

One of the commission’s sub-groups estimated that it will cost an average of $100,000 for each of the state’s 125 affected water utilities to complete their plans.

Amy Swann, the director of the West Virginia Rural Water Association and a registered lobbyist, chairs the group that came up with the cost estimate.

“We have three registered professional engineers as members of our committee,” Swann said at the commission’s last meeting. “So I personally feel very comfortable with the estimate that we’ve come up with.”

Swann said last week that her group tried to estimate how many hours would be needed to make the plans - by people in positions like project manager, specialists, engineers and technical help.

“The cost is more driven by the pure engineering analysis that has to be done than anything else,” she said.

Swann said costs could vary widely between different utilities, but that they felt comfortable with $100,000 as an average. Other related estimates have come up with far different numbers.

In 2011, Tetra Tech, a multinational engineering firm with offices in Charleston, submitted a proposal to develop source water protection plans for West Virginia American Water Company, by far the largest water utility in the state.

Tetra Tech gave three price options, all of which would yield a source water protection plan.

All the price options were well below the $100,000 estimate.

For the company’s Elk River regional system - the one contaminated by January’s chemical leak - Tetra Tech projected costs between $13,000 and $33,000. For the company’s Huntington regional system, Tetra Tech estimated costs between $15,000 and $42,000.

(West Virginia American did not complete the plans for the two water systems.)

If the largest water utility in the state can complete source water protection plans for a fraction of $100,000, doesn’t that mean the commission’s cost estimate is overblown?

Not necessarily: Even though they’re both “source water protection plans” the 2011 Tetra Tech proposals and what is required by the Legislature are not exactly the same thing. The new plans must include much more contingency planning then the 2011 proposals. That includes studies on things like the feasibility of a second water intake, more raw water storage and the possibility of connecting with a neighboring water system.

“The original plans were focused on preventing contamination,” said Mindy Ramsey, Tetra Tech’s director of water resources in Charleston. “The changes to the plans now will be, OK, we want you to think about how to prevent, but if you do experience contamination what are you going to do about it?”

Ramsey said that with the new requirements she would expect their cost estimates to double - which would still leave the costs for West Virginia American’s individual systems well below the $100,000 mark.She said that Tetra Tech completed about 100 source water protection plans between 2009 and 2012 - costing between $6,000 and $14,000 - and that the utilities that did those would have a jump-start on the new plans.

The Region 1 Planning and Development Council is one of 11 such councils around the state that provide planning services (housing, health, infrastructure, etc.) to municipalities. Region 1 represents McDowell, Mercer, Monroe, Raleigh, Summers and Wyoming counties. It is the first region to begin working to solicit bids for the new plans and develop cost estimates.

“We’re running at right about $50,000 per plan,” said Cori Edwards, a project manager for Region 1. Edwards said that they had received three bids at around that price to do a plan for the McDowell County Public Service District.

The Morgantown Utility Board, the second-largest water utility in the state, is well ahead of other utilities, having already begun making its plan.

Timothy Ball, the board’s general manager, estimated the cost of making the plan at about $125,000, but said Morgantown’s plan goes well beyond the requirements of SB373.

The law requires utilities to catalog all possible sources of significant water contamination within a specified “zone of critical concern,” that basically includes contaminants that are directly upstream from a water source.

Morgantown is doing much more, cataloging all possible contaminants within the city’s watershed, an area that stretches to Elkins and includes eight to 10 counties.

Ball estimates that the law requires them to catalog about 2,500 possible contamination sources and they’re trying to catalog 25,000.

Swann noted that the driving factor behind costs wasn’t necessarily the size of a system, but the complexity of it. A system covering more varied terrain will have more pressure zones and will require a more complicated plan.

“A source water protection plan is not like an income tax form, it varies and, accordingly, costs vary,” she said. “You just be sure to tell the governor and the Legislature to print some money to make this happen.”

Reach David Gutman at, 304-348-5119 or follow @davidlgutman on Twitter.