Ronald E. Downing

BACKGROUND SUMMARY
Mr. Downing is a Principal with Long International and has over 30 years of experience in the management of power, process industrial and environmental construction projects, and in the analysis and preparation of construction claims. His direct project management experience includes estimating, contract administration, and the development and implementation of project control systems (cost, schedule and quality) for ongoing projects. His construction claims experience includes claims evaluation, analysis, and expert testimony related to construction means and methods, technical issues, schedule delays, productivity losses, and the quantification of damages.

Mr. Downing has significant experience in the role of project manager in the construction of various systems at heavy industrial and power generation plants throughout the U.S.

EDUCATION
B.S., Education, Florida State University, 1972
A.S., St. Johns Community College, 1969

PROJECT EXPERIENCE

Mr. Downing has served in various capacities on more than 80 construction claims ranging in size from $250,000 to over $500 million. Representative projects have included:

• University Co-Generation Plant

• Resource Recovery Power Plant

• Waste Coal Power Plant (2)

• 300 MW Combined Cycle Power Plant

• University Stadium Construction

• Boiler Fuel Conversion - 200MW Power Plant

• Paper Mill Recovery Boiler Rebuild

• 250 MW Combined Cycle Power Plant

• 40,000 BPD Offshore Drilling/Production Rig

• Soy Sauce Manufacturing Plant

• Poultry Processing Plant

• Railway Electrification Project

• Polyester Chip Manufacturing Plant

• Prototype Gold Ore Processing (ROTP) Facility

• Prototype Gorilla Class Offshore Drilling Rig

• 150 Unit Luxury Apartment Complex

• Renovation of 96 Unit Apartment Complex

• Manufacture of Spent Nuclear Fuel Storage Containers

• Cement Manufacturing Plant Expansion

• Cement Manufacturing Plant (2)

• 550 MW Combined Cycle Power Plant

• 100 Unit – Nursing Home/Assisted Living Facility

• 2 – 30 Cell Air Cooled Condensers

• Corrections Facility (Administration/Jail/Detention Center)

TESTIMONY EXPERIENCE

Mr. Downing has testified as an expert witness on numerous schedule delay, loss of productivity, extra work, and damage claims. His testimony experience includes the following:

• Provided schedule delay, loss of productivity and damages deposition testimony regarding a $60 million claim on a Combined Cycle Power Plant. The case was settled successfully in arbitration. (Project Value - $300M)

• Provided testimony with respect to the owner’s withholding of payments to a contractor under a reimbursable contract due to contractor-caused delays, inefficiencies, and defective work, based on contractual language that placed the responsibility for these costs with the contractor. The project involved a fiber glass insulation manufacturing facility in Canada. (Project Value - $28 M)

• Provided schedule delay, loss of productivity and damages deposition testimony regarding a $7.5 million claim on a Co-Generation Power Plant. The case was settled prior to the start of the trial in U.S. District Court, Eastern District of Kentucky. (Project Value $100M)

• Provided schedule delay, loss of productivity, extra work, and damages testimony in State Court of West Virginia regarding a $3.0 million claim on a Waste Coal Power Plant. The testimony resulted in a jury award slightly greater than clients settlement offer. (Project Value - $100M)

• Provided deposition testimony on schedule delay, loss of productivity, extra work, and damage claims of $2.0 million on an FGD installation for a Resource Recovery Facility. The case was settled in mediation prior to a trial in U.S. District Court District of Maryland, Southern Division. (Project Value - $10M)

• Provided deposition testimony on schedule delay, loss of productivity, project management, extra work, and damage claims of $8.0 million on a boiler installation for a Resource Recovery Facility. The case was settled in mediation prior to a trial in U.S. District Court District of Maryland, Southern Division. (Project Value – $40M)

• In the construction of a maintenance facility at an international airport, Mr. Downing provided deposition testimony on schedule delay, loss of productivity and damages claims of $1.5 million. The case was settled prior to arbitration. (Project Value - $30M)

• Provided deposition testimony on inappropriate assessment of $2.5 million of liquidated damages on the erection of a Boiler for a Resource Recovery Facility. The case was settled in mediation prior to a trial in U.S. District Court District of Maryland, Southern Division. (Project Value - $40M)

• Provided deposition testimony on loss of productivity, extra work, and damages claims of $6.5 million on the erection of a Floating Offshore Oil Production Platform. The case was settled in mediation prior to a trial in U.S. District Court Southern District of Texas, Houston Division. Project Value – $40M)

• In International Chamber of Commerce, International Court of Arbitration, Mr. Downing provided deposition testimony on schedule delay, loss of productivity, cost reporting, extra work, and damages claims of $50 million on the construction of a Refractory Ore Treatment Plant. The case was settled in arbitration with the defendant client paying no damages. (Project Value - $150M)

• In arbitration for a Housing Finance Agency, Mr. Downing provided standards of practice regarding project management and subcontractor management, and schedule delay analysis testimony. The client was awarded over 50% of the liquidated damages claimed. (Project Value – $30M)

• Provided testimony on a $6 million loss of productivity claim prepared for client contractor on a 500 MW combined cycle power plant in Massachusetts.

• Representing a Casualty Insurance Carrier, provided deposition testimony on a $15 million delay and loss of productivity claim on a 500 MW combined cycle power plant in Connecticut. The case was settled during trial.

• Represented a general contractor in defending against a $1 million delay, acceleration and loss of productivity claim on a poultry processing plant. Case was settled during trial with defendant client paying $150K.
   

PROFESSIONAL EXPERIENCE

Long International, Inc.
Atlanta, Georgia (2006 to Present)

As a Principal with Long International, Mr. Downing provides construction claims evaluation, analysis, and expert testimony related to construction means and methods, technical issues, schedule delays, productivity losses, and the quantification of damages.

Revay & Associates USA Ltd.
Atlanta, Georgia (2001 to 2006)

As Vice President and Principal, Mr. Downing was responsible for all facets of the consulting practice specializing in claims and litigation support. Specific responsibilities included business development, client liaison, strategy formation, issue definition, performance of required analyses, coordination of staff technical tasks and assignments, development of extensive written reports, design/preparation of demonstrative exhibits and offering expert testimony.

Hanscomb
Atlanta, Georgia (1999 to 2000)

Resolution Management Consultant
Atlanta, Georgia (1995 to 1998)

A.W. Hutchison
Atlanta, Georgia (1991 to 1994)

Cleveland Consolidated, Inc.
Atlanta, Georgia (1988 to 1991)

Vice President for the Mechanical Division of a $60 million specialty contractor. Specific responsibilities included development of new markets, maintaining business with existing customers, oversight of all division operating and administrative functions including estimating, contract review and negotiation, quality control, purchasing, scheduling, cost and progress monitoring and reporting. In addition to the specific division related duties, also responsible as company officer to work with other executives in reviewing, developing and implementing company policies and procedures.

Representative construction projects included:

• 350 TPD & 600 TPD Air Separation Plants - Erection of structural steel, equipment, ducting, code vessels and code piping

• Six (6) Train FGD System - Erection of structural steel, vessels, ducting and piping at a Resource Recovery Power Plant

• Electrified Monorail System - erection of all supports, rails, transfers, and maintenance stations and installation of automated trolleys at an automobile manufacturing facility

• Underground Piping System - Installation of all stainless steel underground product piping at a new brewery.

• Four (4) Train FGD System - Erection of structural steel, vessels, ducting and piping at a Resource Recovery Power Plant

Comstock Mechanical
Atlanta, Georgia (1987 to 1988)

As Vice President of Pre-Contract Services, Mr. Downing was responsible for developing major design/build projects, in excess of $20 million, for this newly formed subsidiary of the Comstock Group. Specific duties involved creating and managing a professional sales force, and managing the estimating department (all disciplines), developing alliances with industrial design/engineering firms, establishing operating budgets, short and long term objectives and creating and implementing strategic marketing plans.

Representative construction projects included:

• Compressed Air Storage Facility - Development of Design/Build Proposal for 100 MW CAES plant utilizing salt cavern air storage

• Paper Mills Lime Kiln - Mechanical installation of 300 foot lime kiln

• Power Plant Code Piping Modifications - Turbine water injection prevention

Brock and Blevins
Denver, Colorado (1980 to 1987)

As Western Region Vice President and Project Manager, Mr. Downing was responsible for all operating and administrative functions. Representative construction projects included:

• 1200 FPM Continuous Annealing Line - Complete rebuild from pay-off reel to take-up reel

• Repair/Renovation of Coke Oven gas Supply and Distribution - Remove and replace main supply headers and distribution lines to burners.

• Two (2) 65 MW Geothermal Steam Turbines - Erection of base plates, rotating equipment, housings, lube oil and steam piping.

• Major Boiler Repairs, 750 MW Power Boilers - Remove and replace superheaters, sootblowers, wall boxes and slope wall sections. All boiler code work.

• FFDC Systems - Erection of all Structural and Mechanical work for three (3) different projects: 24 compartment - 1.4 million ACFM-DG&T, 14 compartment - 1.2 million ACFM-PSCC, 12 compartment - 900K ACFM-PSCC.

• Repair/Renovation of 4 Heating Boilers - Upgrade fire safety system and replacement of boiler side walls and burner fronts.

Inseco, Inc.
Denver, Colorado (1975 to 1980)

Employed in 1975 as Field Office Manager on a Recovery Boiler Project and subsequently to a precipitator installation, specific duties and responsibilities included all field administrative functions such as payroll, union reporting, progress reporting, earned value reporting, cost monitoring, maintenance of project drawings and drawing logs, weld procedures and certifications, etc.

Promoted in 1977 to Project Manager based in the home office in Denver, CO. Responsibilities included handling all aspects of project management. In companies such as Inseco, Inc. those duties typically include estimating, contract review and negotiation, contract administration, customer relations, project scheduling, progress monitoring, cost monitoring and controls, and overall project oversight.

Representative construction projects included:

• Covered Quench Car System - Erection of foundations, rails, water quenching system and modification to coke oven door removal system.

• 1200 TPH Coal Handling System - Erect all building structures, conveyor supports, gallery sections, tables and idlers, pulleys and drive systems.

• Stacker/Reclaimer System - Structural and Mechanical erection of a mobile rail coal stacker and drum reclaim equipment.

• Electrostatic Precipitators - Erection of structural support steel and equipment for numerous customers.

• 1200 TPD Recovery Boiler - Erection of all Pressure Parts.

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Revised: December 31, 2007