Final Combined Book v.4.0 test
PO Box 575 Fort Montgomery, NY 10922 time, however we can collectively discuss this further when timing permits." Three (3) months passed before Spearhead was allowed to add a 2 nd shift. Trade stacking due to the limited areas for work required intense coordination. Spearhead does not understand why the SWJV PM/APM refused to provide 2-week or 6-week look-ahead schedules to alleviate the difficulty of coordinating trades working on top of each other. Additionally, SWJV PM/APM had the opportunity to resolve further congestion at the moving walkway by installing scaffold to allow all trades to work above the moving walkway without restriction, on any shift. Instead, SWJV PM/APM rented 2 “spider” lifts for all trades to share during the 2 nd and 3 rd shifts, only. These lifts proved so unreliable that SWJV ultimately had to add a 3 rd spider for trades to share. With proper scaffold above the moving walkway, trades could have worked with limited restriction throughout three (3) shifts with stepped up manpower. Instead, trades were limited to three (3) crews per 2 nd and 3 rd shifts. 4. On site SWJV Project Management (SWJV PM/APM) We agree to have some of the change order work rescinded, under pressure, not because we could not perform, but because the SWJV PM/APM, has • failed to provide a detailed comprehensive schedule, • failed to provide near-term updates or milestone objectives, • failed to provide updated changes to the schedule or a 2-week or 6-week look-ahead, • failed to properly manage the work of preceding contractors, • failed to have MEPS work installed in a timely manner without interference of our work, • failed to respond accurately or expeditiously to questions arising from the structural issues with the bridge steel being out of plumb or bolts installed backwards, • thwarted our attempts to recover project delays by denying our request to work 2 nd shift to overcome the inefficiencies of working among stacked trades during the day and to avoid delays for materials being loaded to the job by the Magni lull, • failed to provide advance notice of work stoppages, such as the Live Load Test that impacted 3 shifts of work, • delayed delivery of critical materials (GFRG/C) by a full month, further putting Spearhead in the hole for completion, • at the last minute, blocked Spearhead from beginning its work at the moving walkway prior to the walkway installation, contrary to the submitted and agreed upon “heat map” from day one, which resulted in substantial reduction of productivity, • consistently failed to timely approve change orders to move the project along causing Spearhead to “carry” change order work for more than 2 months on average, most recently to the tune of more than $100k, • blaming Spearhead for “missed dates” that were discussed in Spearhead’s shanty, then co-mingling those unofficial dates with contract language and threatened recourse, while introducing a new end date of January 26 th , • failed to allow Spearhead to perform in an efficient and cost-effective manner as originally anticipated with a single shift in a standard work week, • directed Spearhead to complete work in support of Other trades’ inspections, once again, interrupting work tasks with only 2 days advance notice, • failed to allow Spearhead to have free and clear work areas, directing Spearhead to run hither and yon based on the SWJV’s PM’s lack of leadership, pre-planning and management by crisis project management methodology, and • now threatening to hold Spearhead accountable for costs and delays not of its, but rather SWJV and those under its control’s making.
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