013110 Critical Path Method Scheduling.pdf

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HUD Granite Facade Replacement Federal contract opportunity
Solicitation number
47PM0120R0008
Issued by
General Services Administration Public Buildings Service

About this file

This solicitation requests proposals for a design-build contract to replace the granite facade of the Robert C. Weaver Federal Building located in Washington, DC. The selected contractor will be responsible for survey, removal, and reinstallation of existing granite panels; cleaning of panels; installation of a new anchoring system; repair of panels as needed; installation of roof davits; repair of metal roofs at stair towers; potential exterior hazardous materials abatement; and waterproofing of the existing wall facade. There is also a requirement for minor concrete patching. The work must be completed by a locally-based contractor within a 50-mile radius of Washington, DC. The estimated price range for this project is between $10-15 million. Proposals are due by August 14, 2020. A virtual pre-proposal conference will be held on July 8, 2020.

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Robert C Weaver Federal Building, Granite Façade Repairs, Phase 2 Washington, DC Project Number # VDC00213

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 1

SECTION 013110 - CRITICAL PATH METHOD (CPM) SCHEDULING

PART 1 - GENERAL

1.1 SUMMARY

A. The Contractor shall use a CPM Project Schedule to plan, coordinate, and perform the Work. The Project Schedule shall be a rational, reasonable and realistic plan for completing the Work, and conform to requirements specified in this specification section and elsewhere in this Contract. The Project Schedule shall depict all activities necessary to complete the Work, including, as applicable, all submittal and submittal review activities, all procurement activities, and all field activities, including mobilization, construction, start-up, testing, balancing, commissioning, and punch list. Activities shall be sufficiently detailed and limited in duration to enable proper planning and coordination of the Work and allow effective evaluation of the reasonableness and realism of the Project Schedule, accurate monitoring of progress, and reliable analysis of schedule impacts.

1.2 SCHEDULER REQUIREMENTS / QUALIFICATIONS

A. Within five (5) Working Days after the Contractor receives Notice to Proceed (NTP) from the Contracting Officer (CO), the Contractor shall provide written notice to the CO naming a scheduling representative in the Contractor’s organization who shall be responsible for coordinating with the GSA during the preparation and maintenance of the Project Schedule. The Contractor’s scheduling representative shall have authority to act on behalf of the Contractor in fulfilling the Project Schedule requirements of the Contract.

B. The Contractor's scheduler shall possess a minimum of 10 years’ experience in CPM scheduling on projects of similar size, scope, and complexity of the one specified in the Contract Documents.

C. The Contractor’s scheduler shall also have taken, and provide proof of, at least one CPM training class within the past 5 years. If the Contracting Officer rejects the proposed scheduling representative, the Contractor shall submit a different candidate, at no additional cost to the Government. The Contractor shall not change the scheduling representative without the prior written consent of the Contracting Officer.

D. The Contractor agrees that if the Contracting Officer provides written notice to the Contractor that the scheduling representative is not performing the duties to the satisfaction of the Government, the Contractor shall change such representative at no additional cost to the Government. Within ten Working Days of receipt such written notice, the Contractor shall propose a new scheduling representative for approval by the Contracting Officer. Until the Contracting Officer approves of any such replacement, the Government reserves the right to reject any Project Schedule.

1.3 DEFINITIONS

A. Activity - An element of the Work or task performed during the course of the project. Each schedule activity shall be a clearly defined, manageable and reviewable task depicting an estimated duration, an estimated cost. Each activity shall be limited to one trade unless approved by the Contracting Officer.

B. Baseline Schedule - The original work plan approved by the Contracting Officer depicting the Contractor’s plan to prosecute the work. The Baseline Schedule becomes the schedule upon which progress is monitored.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 2

C. Constraint - A scheduling restriction imposed on an activity to affect the start date, finish date or Float.

D. Critical Path - The sequence of activities that represents the longest path through a project, which determines the shortest possible duration.

E. Critical Path Method (CPM) - A scheduling technique using activities, durations, and interrelationships/dependencies (logic), such that all activities are interrelated with logic ties from the beginning of the project to the completion of the project. Estimates the minimum project duration and determines the amount of scheduling flexibility on the logical network paths within the schedule model.

F. Data Date - The date to which progress is updated. In most scheduling software, the data date represents the next day of work and all progress is updated through the day prior to the data date.

G. Float – The amount of time an activity can be delayed in a project network without causing delay to subsequent activities (Free Float) or the Substantial Completion date (Total Float).

H. Free Float - The amount of time that an activity can be delayed without delaying the early start date of successor activities.

I. Total Float - The amount of time an activity (or chain of activities) can be delayed without affecting the Substantial Completion date.

J. Float Suppression - The masking of available Float through the use of constraints, unreasonable logical relationships or unreasonable durations.

K. Fragnet – A subset group of interrelated activities representing only a portion of the CPM schedule.

L. Network Plan - The entire database of activities, logic, durations, and all items relating to any activity input into the scheduling software and is the complete representation of the Project Schedule prepared using the CPM and graphically shown in a time-scaled form. The network shows the sequence and interdependence of the activities, and planned and actual progress by activity, required for complete performance of the Work.

M. Preliminary Schedule - The first schedule submission provided by the Contractor that: (a) defines detailed planned procurement and construction operations for the first 120 calendar days after NTP; and (b) provides a higher level summary of planned operations beginning 120 days after NTP through completion of the project.

N. Project Schedule - Any schedule submitted by the Contractor to the Government, including but not limited to Preliminary Schedule, Baseline Schedule, and all subsequent Schedule Updates, Recovery Schedules, and As-Built Schedule.

O. Recovery Schedule – A schedule depicting the Contractor's plan for recovery of time lost on the project.

P. Retained Logic - The remaining duration of a progressed activity is not scheduled until the logical relationships of all predecessors are satisfied. With Progress Override, network logic is ignored and the activity can progress without delay.

Q. Schedule Update - A schedule in which the Contractor will reflect project progress on a monthly basis and updated from the prior data date to the current data date.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 3

R. Status – The progress of work which can be applied at any level of work breakdown structure.

Information on the progress of work or an action.

S. Time Impact Analysis - A schedule delay analysis procedure to demonstrate a revision or proposed revision to the Substantial Completion date against the current approved Project Schedule.

T. Work(ing) Day - A Work(ing) Day is a calendar day scheduled for active prosecution of the work.

PART 2 - PRODUCTS

2.1 The Project Schedule shall be produced using widely used, industry standard, commercially available computer software that is capable of generating and monitoring a CPM schedule.

Examples of widely used commercially available software include but not limited to Microsoft Project and Primavera P6.

PART 3 - EXECUTION

3.1 GENERAL REQUIREMENTS

The Project Schedule shall provide the proposed sequence to perform the work and dates contemplated for starting and completing all schedule activities. The Project Schedule is to include all work as identified within the scope of this contract. The Project Schedule should be a forward planning tool as well as a project monitoring tool.

3.2 PAYMENT TO CONTRACTOR

A. Basis of Payment to Contractor: Requests for payment shall be based upon the current approved Schedule Update. The Contractor's overall progress along with progress for discrete activities will be used to determine the amount to be approved for the monthly payment request.

B. Payment Rejection: The Contractor’s failure to meet the requirements of this specification justifies the Contracting Officer’s (1) withholding approval of any Project Schedule and (2) rejecting, in whole or in part, any payment request.

C. As-Built Schedule: Along with the final request for payment, the Contractor shall submit an As-Built Schedule documenting actual start and actual finish dates for all activities, and logic ties between all activities to show the actual sequence in which the work was performed.

3.3 PROJECT SCHEDULE DETAILED REQUIREMENTS

A. Level of Detail: The Project Schedule shall satisfy the minimum level of detail described below.

B. Activity Durations: Activity durations shall be in units of whole Working Days and scope of work shall be limited to one trade each. Except for submittal and procurement activities, durations shall not exceed 1 month.

C. Activity Cost Loading: With the exception of submittal activities, all activities shall be cost-loaded.

The assigned dollar value (cost-loading) shall cumulatively equal the total Contract price. General condition costs shall be shown as an activity with the exception of mobilization, insurance, and bonds costs, which shall be reflected as separate cost-loaded activities. Activity cost loading must be reasonable and avoid any front-end loading.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 4

To the extent that the Contractor anticipates requesting payments for stored materials, delivery activities shall be cost-loaded to reflect the cost of materials (excluding labor for installation) and shown separately from the related fabrication activity.

D. Design and Permit Activities: Include design and permit activities with the necessary conferences, follow-up actions, and design package submission dates. Include the design schedule to show the sequence of events involved in carrying out the design tasks within the specified contract period.

These activities shall be provided at a detailed level of scheduling that is sufficient to identify all major design tasks, including those that control the flow of work. Include review and correction periods associated with each item.

E. Procurement Activities: Include activities associated with critical submittals and their approvals, procurement, fabrication and delivery of long lead materials, equipment, fabricated assemblies and supplies. Long lead procurement activities are those with an anticipated procurement sequence of over 60 calendar days. Indicate intended submittal dates, and depict the review period as defined in this specification and elsewhere in the Contract Documents.

F. Construction Activities: The Project Schedule shall include all activities associated with construction including but not limited to permits, mobilizations, inspections, tenant move-in periods, close-out, start-up, testing and balancing, commissioning, and turnover.

G. Government Activities: Show government activities that could impact progress, including but not limited to: approvals, acceptances, design reviews, inspections, Government Furnished Equipment (GFE), move coordination, lease expirations and NTP for phasing requirements.

H. Activity Coding: All activities shall at a minimum shall be coded by Area, Responsibility (trade/ subcontractor), Construction Division, and Phase. Additional codes are allowed to identify sufficiently where work will occur. Codes shall be a maximum of six (6) characters and abbreviations shall be fully described in the Project Schedule. The work related to each activity shall be limited to one work trade and one area. All activity descriptions shall be unique. Include an activity code field Schedule of Values (SOV) for the coding of each schedule activity; this is for the tabulation and summarization of contractor assigned cost-loaded work activities fused for Progress Payment Request reporting. The Contractor’s self-performed work shall be clearly identifiable.

I. Contract Milestones and Constraints: Include milestone events as defined in the Contract Documents including, but not limited to, Award, Notice to Proceed, Substantial Completion, and Project Completion. Also include and identify any phased work, work restrictions/access/shift work, and work being performed by separate contractors. The Contractor is prohibited from assigning milestones that are not consistent with dates that are prescribed by the Contract Documents.

No Float constraint techniques shall be used without specific written approval from the Contracting Officer. The first activity in the project schedule must be a start milestone titled “NTP Issued,” which must have a “Start On” constraint date equal to the NTP date.

The last activity in the schedule must be a finish milestone titled “Project Completion”. Constrain the Project Schedule to the Contract Completion Date in such a way that if the schedule calculates an early finish, then the Float calculation for the “Project Completion” milestone reflects positive Float on the longest path. If the schedule calculates a late finish, then the Float calculation for the “Project Completion” milestone reflects negative Float on the longest path.

J. Calendars: Establish a schedule calendar as it relates to durations for activities. For example calendars should identify proposed number of working days per week, holidays to be observed, planned number of shifts per day, weather affected activities such as roofing or landscaping that normally cannot occur in the winter/fall months.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 5

Incorporate seasonal weather conditions in the project’s geographic area into the project planning and include an average number of days lost to weather per month using the NOAA historical data five (5) year averages.

K. Logic: The project schedule shall include interrelationships (logic) and sequencing for all activities.

Only two open ended activities are allowed; the first activity “NTP Issued” may have no predecessor logic, and the last activity “Project Completion” may have no successor logic. For each activity, at least one successor must be a finish relationship (Finish-to-Start or Finish-to- Finish).

L. Out-of-Sequence Progress: Out-of-sequence activities are those that have progressed before all preceding logic has been satisfied. Address out-of-sequence progress or logic changes in the Schedule Update and in the periodic schedule update meetings.

M. Added and Deleted Activities: Do not delete activities from the Project Schedule or add new activities without approval from the Contracting Officer. The Schedule Update shall identify all deleted or added activities.

N. Lags, Leads, and Relationships: The Contractor shall limit the use of Start-to-Start (SS) and Finish-to-Finish (FF) relationships to allow Project Schedule detail to be fully developed.

Lags must be reasonable, not used in place of realistic durations, and not be in place to artificially absorb Float or to replace proper schedule logic.

Leads (negative lags) and Start-to-Finish (SF) relationships are prohibited.

O. Retained Logic: Schedule calculations must retain the logic between predecessors and successors (“retained logic” mode) even when the successor activity(s) start(s) and the predecessor activity(s) has not finished (out-of-sequence progress). Software features that in effect sever the tie between predecessor and successor activities when the successor has started and the predecessor logic is not satisfied (“progress override”) are prohibited.

P. Percent Complete: Update the percent complete for each activity started, based on the assessment of work in place. Activities which are complete but for remaining minor punch list work and which do not restrain the initiation of successor activities may be declared 100 percent complete to allow for proper schedule management.

Q. Remaining Duration: Update the remaining duration for each activity based on the number of estimated Working Days it will take to complete the activity. Remaining duration may not mathematically correlate with percentage found under the paragraph entitled Percent Complete.

R. Ownership of Float: Float available in the schedule may not be considered for the exclusive use of either the GSA or the Contractor.

S. Early Substantial Completion Schedule: The Contractor shall have the right to submit a schedule for approval showing Substantial Completion earlier than the substantial completion date set forth in this Contract. The Government may approve such a schedule if it: (a) provides a realistic forecast for early completion; (b) otherwise satisfies all of the requirements set forth in the Contract Documents; and (c) is at no additional cost to the Government. In the event the Government opts to approve an early Substantial Completion schedule, the Contracting Officer is entitled, but is not required, to issue a unilateral, no-cost modification to the Contract to adjust the contractual Substantial Completion date.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 6

GSA is under no affirmative obligation or duty to aid, assist, or otherwise adjust its performance, including but not limited to accelerating work items, to ensure that the early Substantial Completion date (as adjusted) is met. The Contractor’s early Substantial Completion schedule shall include all indirect costs through the Contract Completion date.

If the Government approves the early Substantial Completion schedule and a unilateral modification is not issued, the time between the forecast early Substantial Completion date and the date required by this Contract for Substantial Completion will be considered Float (see Section 3.3.S).

3.4 PROJECT SCHEDULE SUBMISSIONS AND REVIEWS

GSA's comments, reviews, or approvals of a Project Schedule do not relieve the Contractor of responsibility for the accuracy or feasibility of the Project Schedule, or for meeting any of the completion dates set forth therein. In addition, any such comment, review, or approval does not create a warranty on the part of the Government, whether expressed or implied, or constitute a Government acknowledgement of or admission of the reasonableness of the activities, logic, durations, manpower, or cost-loading as set forth by the Contractor in the Project Schedule.

The Contractor shall meet with GSA within 14 calendar days after NTP to conduct a joint review of the Project Schedule requirements in this Section.

A. Preliminary Schedule Submission and Review: Within twenty (20) Working Days after NTP, the Contractor shall submit a Preliminary Schedule in an electronic format.

The Contractor shall meet with GSA to discuss the results of GSA's schedule review. In the event that GSA provides comments or otherwise rejects the Preliminary Schedule, the Contractor shall, within five (5) Working Days of receipt of the comments or rejection, revise the Preliminary Schedule and resubmit the Preliminary Schedule for review and approval.

B. Baseline Schedule Submission and Review: Upon approval of the Preliminary Schedule, the Contractor shall submit a fully detailed, cost-loaded schedule as the proposed Baseline Schedule.

The proposed Baseline Schedule shall have a data date no later than NTP.

The GSA will review the proposed Baseline Schedule and provide comments to the Contractor within fifteen calendar days of the receipt of this submittal and, if needed, will arrange for a Baseline Schedule review meeting with the Contractor for discussion of the schedule. The Baseline Schedule, when approved, shall become the basis for the next monthly Schedule Update submitted by the Contractor.

In the event that GSA provides comments or otherwise rejects the Baseline Schedule, the Contractor shall, within five Working Days of receipt of the comments or rejection, revise the Baseline Schedule and resubmit the Baseline Schedule for review and approval.

Upon approval of the Baseline Schedule, the cost-loaded values shown in the Baseline Schedule and progress of activities will be used as a basis for assessing the timeliness of the Contractor’s performance, and for determining progress payments. The computer generated cost report will be used by the GSA to verify the payment application submitted by the Contractor.

Until the Contracting Officer approves the Baseline Schedule, the Contracting Officer may withhold approval of any payments.

C. Schedule Update Submission and Review: Unless a shorter period for updates is specified by the Contracting Officer, the Contractor shall attend monthly schedule update meetings with GSA to review the Schedule Update, including any reports or submissions thereto. At a minimum, the

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 7

Contractor’s project manager, project superintendent, and the scheduling representative shall attend.

Unless a shorter period for updates is specified by the Contracting Officer, the Contractor shall provide monthly Schedule Updates at a date mutually agreed upon between the Contracting Officer and the Contractor until Contract Completion is achieved.

3.5 SUBMISSION REQUIREMENTS

The Baseline Schedule and every Schedule Update shall include:

A. Electronic Version of Project Schedule: With each submission, the Contractor shall provide an electronic copy of the submission in ePM in PDF as well as in its native format (that is, the format generated from scheduling software).

B. Narrative Report: The Narrative Report shall communicate the thorough analysis of the schedule output and the plans to compensate for any problems, either current or potential, which are revealed through that analysis. The Narrative Report shall include the following:

1. Critical path in the previous schedule at the beginning of the period.

2. Progress achieved on the critical path.

3. Variance between the progress planned on the critical path and the actual progress achieved on the critical path.

4. Deviations from lookahead schedules.

5. Near-critical paths in the previous schedule at the beginning of the period.

6. Progress achieved on each of the near critical paths.

7. Variance between the progress planned on the near critical paths and the actual progress achieved on each of them. Provide explanations for the variances.

8. General description of the work on the forecasted critical path for the remainder of the project.

9. Work on the critical path planned to be performed during the next reporting period.

10. Work on the near critical paths planned to be performed during the next reporting period.

11. Other Work (as requested by the Contracting Officer or that the Contractor deems necessary for communication purposes) anticipated to be performed during the next reporting period.

12. Changes to the critical path since the prior month’s approved schedule.

13. Problem areas

14. Current and anticipated delays including cause of delay, corrective actions taken, and impact of the delay on other activities, milestones, and completion dates

15. Pending items (change orders, requests for time-extensions, etc.), and status thereof.

16. Identification and explanation of items or information required from the GSA or third parties to avoid schedule impacts.

17. All schedule changes by activity ID and activity name including what was specifically changed and why the change was needed. Include at a minimum new and deleted activities, logic changes, duration changes, calendar changes, lag changes, and actual start and finish date changes.

18. Out-of-sequence work.

C. Schedule Reports: In addition to the electronic version and narrative report, the Contractor shall include an electronic copy of each of the reports listed below with each submission for the Government’s review:

Logic Report: List of detailed predecessor and successor activities for every activity in ascending order by activity number.

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 8

Total Float Report: A list of all incomplete activities sorted in ascending order of Total Float. List activities which have the same amount of Total Float in ascending order of Early Start Dates. Do not show completed activities on this report.

Pay Application Report: The Contractor shall provide an itemized report of all cost loaded items from the Schedule Update. The Contractor shall prepare a detailed pay application report based on the prior month's progress payment request to include the prior month's percent complete, costs incurred during the period, costs incurred to date, and costs anticipated to completion. For each task, the costs shall be linked to and generated from the percent complete.

Earned Value Report: To assist in evaluation of project performance, an earned value report shall include standard schedule categories, as well as categories such as cost performance index, schedule performance index, budget at completion, variance at completion, schedule percent complete, performance percent complete, earned value cost, planned value cost, actual cost, schedule variance, cost variance, estimate to complete and estimated completion cost.

Schedule Calculation Summary Report: Shall include listings of constraints, open-ends, out-of-sequence work, and scheduling statistics. This report is computer-generated when the schedule is calculated.

D. Schedule Charts and Diagrams: In addition to the electronic version and narrative report, the Contractor shall include an electronic copy of each of the charts listed below with each submission for the Government’s review:

Gantt Chart: A graphical representation of incomplete schedule activities.

Critical Path: Show all activities on the critical path.

Cost Loaded Chart: Cost loaded graphic chart (i.e., S-Curve and monthly histogram) generated from the data contained in the Project Schedule. The graphic shall show the actual and forecasted monthly cash flow in a histogram format, and the actual and forecasted cost over the planned project execution period shown on a cumulative cost curve using actual dates, early dates, and late dates.

Schedule Software Settings: The Contractor shall provide (screenshots of) the schedule software settings used under each tab of User Preferences, Admin Preferences, and Schedule Options with the Baseline Schedule and each Schedule Update.

3.6 REQUESTS FOR TIME EXTENSIONS

The Contractor shall provide a Time Impact Analysis (TIA) in accordance with this section to justify any request for a time extension to extend the Substantial Completion date. The Government will not consider any requests without a TIA.

The cost necessary for the Contractor to develop TIAs as part of a schedule extension request tied to a Contract Modification shall be included with the total settled price of that modification. A modification TIA shall be submitted in tandem with the Contractor’s price proposal.

The cost necessary for the Contractor to develop TIAs as part of a Contractor-driven delay in the overall Contract Period of Performance shall not be borne by the Government.

A. Written Narrative: Provide a detailed, written narrative that clearly sets forth the cause(s) of the delay and conclusively establishes the Contractor’s entitlement to an extension of time. The narrative shall at a minimum: (1) evaluate each impact chronologically; (2) explain the reason for

CRITICAL PATH METHOD SCHEDULING – For Prospectus Projects Updated May 2018 013110 - 9 the schedule revision; (3) set forth the number of days of delay to Substantial Completion and impact to Contractual Completion; (4) discuss all impacted schedule activities; (5) assign responsibility for the delay (e.g., government, A/E, utility provider, etc.); (6) discuss concurrent delay; and (7) describe the change in the affected activities’ Total Float value.

B. Fragmentary Network (Fragnet): The TIA shall include the Contractor’s proposed schedule revisions illustrating the impact in fragnet form. Unless otherwise requested by the Contracting Officer, the status analysis shall compare the progress of work in the most recently GSA approved project schedule update against the approved Baseline Schedule.

Each fragnet shall be accompanied with a spreadsheet depicting the following:

1. Unique fragnet Number,

2. Date of the fragnet,

3. Schedule for the fragnet to be inserted into,

4. Data date of the schedule the fragnet is to be inserted into,

5. Predecessor activity ID and activity name the fragnet is proposed to be linked to,

6. Successor activity ID and activity name the fragnet is proposed to be linked to,

7. Total Float for the path prior to insertion of the fragnet,

8. Anticipated Total Float after the fragnet is inserted,

9. Anticipated impact to the forecasted substantial completion date.

C. Submission Timeframe: The Contractor shall not be entitled to an extension of time if the Contractor fails to submit a TIA to the Contracting Officer within ten (10) Working Days from the time the Contractor knew or should have known of the circumstances, causes, events, or similar actions giving rise to the delay(s).

D. Time Extension: If the Contracting Officer issues a contract modification extending the Substantial Completion date, the Contractor shall incorporate the extension into the Project Schedule with the next Schedule Update

3.7 CHANGE MODIFICATIONS

When the Contractor submits any change modifications to the Contracting Officer that it believes will require a schedule revision, the Contractor shall prepare and provide a TIA: (1) as part of the Contractor’s response to a request for a proposal from the Contracting Officer; and (2) as otherwise requested by the Contracting Officer. The TIA shall include: (1) a written narrative as set forth in 3.6.A; (2) a fragnet as set forth in 3.6.B; and (3) conform to the submission timeframe identified in 3.6.C.

3.8 FAILURE TO ACHIEVE PROGRESS

If the Schedule Update shows negative Float due to Contractor performance, the Contractor shall take any and all steps necessary to improve its progress at no additional cost to the Government.

The Contracting Officer may require the Contractor to provide a Recovery Schedule along with a detailed, written plan.

A. Recovery Schedule: If a Recovery Schedule is requested by the Contracting Officer, the Contractor’s submission shall be consistent with the reporting requirements as set forth in Section

3.5 “Submission Requirements”.

END OF SECTION

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