3720 - Board of Claims

Mr. Pilosi to address these problems. Neither Mr. Sebastianelli, Mr. Pilosi nor anyone else from
PennDOT ever responded to these requests for assistance by telling Intercounty personnel that
they should be contacting the Utilities directly about pole relocation arrangements or problems
during the Project.
On June 18, 2001 (one week after the pre-job meeting), PennDOT issued its Notice to
Proceed. The contract completion date was therefore scheduled to be November 6, 2002.
True to its word, Intercounty adapted its work plan to the flipped sequence and started
work in Section Three promptly by doing the surveying and staking work necessary for the pole
relocations to commence. Intercounty completed the right-of-way stakeout work in Section
Three by July 1, 2001 (slightly more than two weeks from the pre-job meeting). Intercounty
then immediately proceeded to do the same surveying and staking work in Section Two and in
Section One, completing both of those sections by August 1, 2001. This provided the
opportunity to relocate poles through all three sections of the Project without stopping from
August 1, 2001 onward.
Intercounty reasonably expected pole relocation to begin on or about July 2, 2001 after
surveying and staking were completed in Section Three, and to continue relatively uninterrupted
through Section Two and Section One, taking approximately one month in each section and
concluding in early October 2001 based on the bid documents (including Construction Sequence
and “Utilities” section of the Contract). However, the actual pole relocation was vastly different.
Specifically, actual pole relocation did not begin on site until August 21, 2001 (seven weeks late)
and did not complete in Section Three until October 14, 2001 (several days after all pole
relocations for the Project were expected to be complete). At this point, the Utilities left the site
and did not return to proceed with utility pole relocation until late March of 2002, a hiatus of
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