Professional Documents
Culture Documents
Methodology Problems
Failure to use or rely on the original schedule: See Pathman Constr. Co., ASBCA No. 23392, 85-2 BCA 18, 096 (1985). Two opposing experts produce after-the-facts schedules (both unreliable).
Methodology Problems
Failure to use or rely on the original schedule: See Pathman Constr. Co., ASBCA No. 23392, 85-2 BCA 18, 096 (1985). Cs expert labeled the original bar chart as meaningless and chose to prepared an after-thefact CPM; because of changes made to original plan by expert, the CPM found unreliable.
Methodology Problems
Failure to use or rely on the original schedule: See Pathman Constr. Co., ASBCA No. 23392, 85-2 BCA 18, 096 (1985). Gs expert created his own schedule, also relied on Cs schedule and at times referred to the original bar chart and at times applied his own knowledge and beliefs with regard to construction.
Methodology Problems
Failure to consider actual performance. Ealahan Elec. Co., DOT BCA No. 1959, 90-3 BCA 23, 177 (1990). Opposing experts failed to consider actual performance. Cs expert converted a bar chart contract requirement into a CPM schedule; however, in doing so, failed to account for Cs actual performance.
Methodology Problems
Failure to consider actual performance. Ealahan Elec. Co., DOT BCA No. 1959, 90-3 BCA 23, 177 (1990). A G expert failed to take into consideration reasons why particular activities were delayed and used approximation techniques for quantifying actual durations (ultimately failed to demonstrate causation).
Methodology Problems
Unacceptability of an analysis of as-planned plus impacts. See Titan Pacific Constr. Corp., ASBCA Nos. 24148, 24616, 26692, 87-1BCA 19, 626 (1987), summary judgment granted, 17 Cl.Ct. 630 (1989), Affd 899 F.2d 1227 (Fed. Cir. 1990). C expert prepared A/P schedule plus impacts but ignored actual performance.
Methodology Problems
Unacceptability of an analysis of as-planned plus impacts (contd). Cs like-time analysis included a revised A/P schedule (adjusted for seasonal considerations), which produced a different critical path and completion date and then added Owner-caused and weather-related delays to obtain a projected (theoretical) completion date.
Methodology Problems
Unacceptability of an analysis of as- planned plus impacts (contd). BD rejected analysis as purely theoretical. See also, Freeman-Darling, Inc., GSBCA No. 7112, 89-2 BCA 21, 882 (1989).
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Methodology Problems
Failure to establish correlation between plan, changes, actual performance and contemporaneous records. See Titan Mountain States Constr. Corp., ASBCA No. 23095, 85-1 BCA 17, 931 (1985). Cs expert failed to establish causal relationship between mods and alleged delays attributable to them.
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Methodology Problems
Failure to establish correlation . . . (contd) Expert prepared an A/P vs. A/B analysis with a comparison of various updates to show delays. BD found that such comparison disclosed only differences between them and not causes of those differences. CPM updates alone insufficient to establish that COs caused delay.
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Methodology Problems
Failure to establish correlation . . . (contd) Expert did not personally examine CPM printouts, quality control and quality assurance reports or payrolls (only cursorily reviewed project correspondence and other documents and had no contact with any of the subs).
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Methodology Problems
Failure to consider ones own delays. See Gulf Constr., Inc., ASBCA Nos. 30195, 32839, 33867, 89-2 BCA 21, 812, Affd on Recon., 90-1 BCA 22, 393 (1989), Affd 23 Cl.Ct. 525, Affd, 972 F.2d 1353 (Fed. Cir.), Cert. denied, 113 S.Ct. 598 (1992). Expert failed to consider delays for which C was responsible.
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Methodology Problems
Failure to consider ones own delays (contd). Expert took approved CPM schedule and revised it to correct certain logic errors and incorporate crew restraints. Created a revised CPM for use as a benchmark schedule and then prepared analysis of G-caused delays and made a comparison of A/P vs. A/B s.
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Methodology Problems
Failure to consider ones own delays (contd). Expert performed in-depth review of all project correspondence and data pertinent to progress of project but was instructed to exclude all disruptions except those caused by G.
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Methodology Problems
Failure to consider ones own delays (contd). G expert presented revised A/P. and an analysis of 5 Contractor-caused delays that impacted projects critical path. Cs analysis unreliable and inherently biased.
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Methodology Problems
Failure to keep schedules up to date and reflecting delays as they occur. See Fortec Constr. v. U.S., 8 Cl.Ct. 490 (1985).
Failure to account for delays as they occurred can call into question ones analysis. See e.g., Ballenger Corp., DOTBCA No. 74-32, 74-32A, 72-32H, 84-1 BCA 16, 973 at 84, 524 (1983); Preston-Brady Co., VABCA Nos. 1892, 1991, 2555, 87-1 BCA 19, 649 (1987).
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Methodology Problems
Failure to involve the right people in the delay analysis. See Turner Constr. Co., ASBCA Nos. 25447, 29472, 29591, 29592, 29830, 29851, 29852, 90-2 BCA 22, 649 (1990). Gs experts analysis rejected because limited and cursory review of project DOCS (that were selected by G, not expert).
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Methodology Problems
Failure to involve the right people . . . (contd) Information compiled by individuals who had nothing to do with actual performance. Substantial portion of analysis was delegated by expert to associates whose qualifications were questionable.
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Methodology Problems
Need to avoid adversarial interests. See Nello L. Teer Co., ENGBCA No. 4376, 83-3 BCA 19, 326 (1986). CPM schedule becomes suspect when C and G have developed adversarial interests. Too many variables in schedule subject to manipulation to permit acceptance of conclusions by CPM consultants in such circumstances.
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Common Problems
Modified total time simply throwing in some selfcaused delays without analysis ad hoc Ignoring concurrent delays Failure to account for pacing Ignoring your own delays
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TIA Requirements
As-Planned Schedule
Contract Dates (Milestones) Logical Relationships (Work Sequence) Reasonable Durations
As-Built Schedule
Actual activity start dates Actual activity completion dates Change Orders inserted
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* The Systems Thinker Volume 13 Number 2 (Dancing with Systems by Donella Meadows)
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Project Examples
Refinery Renovation 120 million dollar Refinery Utilities UpGrade and expansion project in the middle east Submarine Pipeline Five Foot Diameter, 12,000 meter Cement Encased Pipeline
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BS&T Issues
Owner delayed start of construction due to drainage issues U/G obstructions Owners inaccurate as-built drawings Changes in Owners OMSB philosophy HAZOP Review Black Oil sump foundation delay (TEL contamination)
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Schedule Summary
As-Planned Schedule As-Built Schedule Change Orders Comparison of 90% Engineering IFC Drawing Analysis
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As-Planned Schedule
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As-Built Schedule
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Change Orders
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1999
Oct 1997
Jan 1999
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BS&T Summary
Engineering delayed 24 Months 90% Engineering delayed 9 Months IFC Drawings delayed 24 Months Mechanical Completion delayed 16 Months Impacted by 53 Change Orders
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Schedule Analysis
TIAs would be meaningless As-Planned schedule was fundamentally defective Re-Planned schedules were rigged COs not incorporated into the schedules Constrained milestone dates Fixed inter-system and inter-package dates
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Activity Status
Physical Units Schedule Data Reporting Daily Records
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Analysis Schedules
Submarine Pipeline As-Planned Schedule Submarine Pipeline TIA Summary Submarine Pipeline Work During Exclusion Periods
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