3720 - Board of Claims

38. In late 1999, two years before construction work on the Project began, Mr. Pilosi
sent each of the Utilities a Utility Relocation Questionnaire and Permit Application
(“Questionnaire”) along with PennDOT’s preliminary design plans and drawings for the Project
on which he had identified the poles that were in conflict with the new road plan. (N.T. 41-42,
45, 58-59; Exs. P-3, P-4).
39. After the Utilities reviewed the preliminary plans and information that Mr. Pilosi
had sent them, each utility company identified what new facilities it needed to install in the
PennDOT right-of-way and the time estimate each company would need for doing its work.
(N.T. 44-45, 59; Exs. P-3, P-4).
40. Each utility company then sent its response to the Questionnaire to Mr. Pilosi, and
GTE and GPU applied for permits that specified each new pole location. (N.T. 42-55; Exs. P-3,
P-4).
41. Based upon the plans and information provided by Mr. Pilosi, GTE and GPU
identified in their permit applications each new pole to be installed by pole number. (N.T. 41-42,
44, 58-60; Exs. P-3, P-4).
42. In November 1999, G.T.E.’s application to PennDOT for a relocation permit
stated that G.T.E. would need 60 days to relocate 15 of its poles at the specified locations along
the roadway and relocate its wires. (N.T. 45-54, 87; Ex. P-3).
43. In December 1999, PennDOT’s Bureau of Design’s Right-of Way and Utilities
Section approved G.T.E.’s application and issued G.T.E. a permit to relocate its 15 identified
poles at the designated locations and to complete its work within 60 days. (N.T. 45, 57; Ex. P-3).
44. In December 1999, GPU’s application to PennDOT for a relocation permit stated
GPU would need 81 days to relocate 41 of its poles at the specified locations along the roadway
and relocate its wires. (N.T. 51, 70-71, 87; Ex. P-4).
45. In January 2000, PennDOT’s Bureau of Design’s Right-of Way and Utilities
Section approved GPU’s application and issued GPU a permit to relocate its 41 identified poles
at the designated locations and to complete its work within 81 days. (N.T. 57, 69-71; Ex. P-4).
46. Blue Ridge Communications had its cables strung on the G.T.E. and GPU poles
along the roadway, and it informed PennDOT it needed 60 days to relocate its cables in all
sections. (N.T. 50, 55; Ex. P-2B).
47. Also as part of his duties as District 4-0 Utilities Relocation Administrator,
Mr. Pilosi drafted a special provision entitled “Utilities” which was included in the bid and
Contract documents. This provision described to the bidding contractors the time period each
utility would occupy the Project site while it relocated its poles and/or wires. (N.T. 34, 47; Exs.
P-2B, P-8, P-34).
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