EDUCATION B.S., Civil Engineering, Massachusetts Institute of Technology (MIT), 1977

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1 JOY E. PECHET, PMP Ms. Pechet is a Senior Executive Consultant with Long International and has nearly 30 years of experience in cost and schedule analysis, project controls, and claims preparation and negotiation for large domestic and international construction projects. Her expertise includes schedule delay analysis, loss of productivity studies, budget and cost variance analysis, and cash flow studies. She has prepared damage and lost profits analyses for breach of contract, business interruption, and wrongful termination disputes. In addition, Ms. Pechet has successfully evaluated and negotiated extension of time, loss of productivity, and acceleration claims for petrochemical, oil refining, coal and gas-fired power plants, commercial, educational, medical and correctional facilities, and large infrastructure projects throughout the world ranging in size from US$100,000 to over US$1 billion. Ms. Pechet is an expert in delay claims, forensic planning, contract management, dispute resolution and avoidance, project controls, disruption and productivity analysis, Primavera software, and FIDIC contracts. She has prepared both assertive and defensive claims for owners, contractors and subcontractors, applying various delay claim techniques including Time Impact Analysis, Windows Analysis, Impacted-As-Planned, and Collapsed-As-Built to quantify delay. She has produced loss of productivity analyses to quantify the schedule impact. EDUCATION B.S., Civil Engineering, Massachusetts Institute of Technology (MIT), 1977 PROFESSIONAL REGISTRATIONS Project Management Professional (PMP) Member of Chartered Institute of Arbitrators, (MCIarb) PROJECT EXPERIENCE Ms. Pechet has prepared and negotiated delay and disruption claims for over 20 years, for projects ranging in size from US$100,000 to over US$1 billion. Much of this work has been performed on large industrial and infrastructure projects located throughout the world. She has managed and directed internal claims teams and supported external legal counsel. Ms. Pechet has evaluated project schedules, contract documents, and project records to determine the cause and effect of construction delays and cost overruns, attributing responsibility for cost and schedule impacts to the various contracting parties. She has prepared delay and quantum claims and successfully negotiated equitable adjustments with Owners, Contractors and Subcontractors. She has prepared both assertive and defensive claims for a wide variety of clients spanning a number of industries. Representative claims include the following: Petrochemical, Oil Refining and Power Plant Facilities Engaged by Contractor to evaluate cost and schedule delays and to prepare Requests for Equitable Adjustment for a US$1.3 billion petrochemical plant in UAE. The project consisted of two separate contracts, one for the EPC of a Cross-Linked Polyethylene plant (XLPE), and the other for the provision of utilities and offsite structures, including Marine Facilities and a Sea Water Intake/Outfall Structure, for Ethylene and Polypropylene plants being constructed at the same time by other contractors. Negotiations

2 Resume of Joy Pechet, PMP Page 2 with client on the REAs totaling over US$250 million have begun. Also responsible for responding to and negotiating $50 million of claims against the Contractor by subcontractors. Evaluated cost and schedule impacts to a US$460 million Lube oil process plant constructed in a 20-year old refinery in the UAE. The project consisted of the EPC of a Base Oil Unit using Unconverted Oil form a hydrocracker as a feedstock. Assisted with the preparation of assertive and defensive claims on a $1.2 billion coal-fired power plant project in the UAE. Responsibilities included forensic schedule analysis, loss of productivity calculations, and cost overrun analyses. Reviewed project correspondence, schedule updates, status reports and cost reports to evaluate the cause and effect of delays, disruption, loss of productivity and cost overruns. Analyzed contractual provisions to assess a Party s entitlement to additional costs and extension of time. Prepared and successfully negotiated a 4.75 month extension of time to the completion date of a gas fired power plant as a result of Owner s delay in providing access to site. Prepared disruption claim due to Owner s failure to finalize design requirements for a gas-fired power plant prior to Notice to Proceed. This had the effect of transforming a Lump-Sum Turnkey Project into a design-build project. Also argued that disruptions caused by a supplier are recoverable under German law. Demonstrated entitlement to a 5.75 month extension of time as a result of transportation delays, cladding delays (not within Contractor s control), and poor performance by Owner s contractors on a gas-fired power plant. Prepared claim for 8-month extension of time and $40 million in additional costs as a result of unforeseen ground conditions. Showed that total delay to the gas-fired power plant would have been 12 months but for mitigation and acceleration by Contractor. Successfully argued for a 9-month extension of time as a result of unforeseeable growth in lead times of key power plant components due to extraordinary market conditions. Justification was based on the fact that tender was made in 2006, but Notice to Proceed was not issued until Prepared 95-day extension of time for a power project in Brazil due to (1) Owner s civil works delays, (2) custom clearance delays, (3) shortages of sand for concreting, and (4) delays in Owner-supplied cladding. Developed a work-around plan, with full agreement by Owner, to mitigate the impact of a Contractor s delay for gas-fired power plant in Perth. Contract completion date was achieved. Demonstrated the impact of unforeseen soil conditions to justify request for 1.5 month extension of time and 1 month of acceleration costs to a power plant project in the UK. As a consequence of Poland s acceptance into the EU after contract award, analyzed the impact to boiler steel structure design due to the change in law. The requirement to harmonize the original contract with the EU standards resulted in engineering delays. A 9.5-month extension of time claim was prepared. Successfully argued entitlement to a 3-month extension of time as a result of the discovery of asbestos on underground pipes that had to be removed prior to start of construction of a power plant. Prepared a claim for 2-month extension of time for a power plant project in France. Successfully argued that Owner failed to inform Contractor that site was classified as protected species area, thereby resulting in a 2-month redesign effort. Demonstrated how delays to a coal-fired project were a result of events outside the control of Contractor, including extreme weather, slow submittal review by Owner, soil contamination, and labor shortages. Successful in receiving a 9-month extension of time and $35 million in prolongation costs.

3 Resume of Joy Pechet, PMP Page 3 Demonstrated how Owner s delays were concurrent with Contractor s delays, to offset full assessment of liquidated damages. Assessed impact of labor shortages and lower labor productivity on schedule for a power plant project in Texas. Responsible for preparation and negotiation of change orders and claims to recover $60 million in cost overruns and to obtain relief from assessment of liquidated damages. Project involved 8 Distributed Control Systems being designed, manufactured, and installed by Invensys to control 8 nuclear power plants under construction in China. Analyzed cost overruns and schedule delays that are attributable to the client. Industrial, Commercial, Educational, Medical and Correctional Facilities Responsible for negotiating $54 million in claims against US government. Developed negotiating strategies. Analyzed contractor s progress to defend Government against claims by contractor. Settled $54 million claims for $8 million. Prepared integrated schedule for IRS Headquarters Building. Coordinated works performed by several contractors and many governmental agencies. Prepared time impact analysis showing entitlement to 11 weeks of compensable delay on a new parking garage. Project Manager for the construction of the US Consulate in Cape Town, South Africa. Responsibilities include: day-to-day over site and interface with General Contractor; coordinating design and submittal reviews with government; negotiating Contractor Requests for Equitable Adjustment; coordinating, reviewing and monitoring contractor schedules and progress payments. Analyzed impact to academic building as a result of delays to (1) switchgear design, (2) elevator installation, (3) interior finishes, and (4) productivity loss. Demonstrated impact to critical path of delayed permitting, stop work orders, and redesign of the piling system. Determined compensable and non-compensable delays. Responsible for project integration, requirements analysis, risk management, and process re-engineering for major IT upgrade project for the US Air Force. Managed the preparation of an Integrated Network Schedule consisting of 150 Satellite Control Network development projects, launch activities, and network downtime schedules. Identified cross project impacts, resource conflicts, critical paths and project interdependencies. Prepared feasibility studies, cash flow analysis, budgets, and cost variance analyses for hotel and resort construction projects at Euro Disney totaling over $150 million. Developed project proformas and implemented financial reporting systems. Project Manager for the design, fabrication and installation of elaborate multi-million dollar water features in the US and internationally. Performed earned value analysis of $150 million Pentagon IT network upgrade project. Prepared Budget vs. Cost and cash flow analyses. Updated cost-loaded schedules. Transportation Projects Aided in the analysis, preparation and negotiation of a $90 million claim against the Massachusetts Department of Transportation for additional costs to the client (Honeywell) for traffic control systems for the Central Artery Tunnel project. Responsibilities included identification of cost and schedule impacts due to scope changes.

4 Resume of Joy Pechet, PMP Page 4 Assisted with the development of an integrated project schedule for the Dulles Airport Expansion Project. PROFESSIONAL EXPERIENCE Long International, Inc. Orlando, Florida (September 2014 to Present) As a Senior Executive Consultant with Long International, Ms. Pechet provides construction claims analyses related to schedule delays, acceleration issues, requests for time extension, assessment of liquidated damages, productivity losses, and the quantification of damages. Ms. Pechet is currently assisting in the preparation of an Expert Witness Report for an arbitration case involving a process plant. Other duties include forensic schedule analysis, cost overrun calculations, and preparation of assertive and defensive claims. Hyundai Engineering and Construction Abu Dhabi, UAE (July 2013 to September 2014) As a Claims Consultant, Ms. Pechet was responsible for developing and implementing strategies for resolution of claims and disputes. Tasks include the analysis, preparation, and negotiation of assertive and defensive claims. Managed and directed internal claims teams and external legal counsel. Evaluated project schedules, contract documents, and project records to determine the cause and effect of construction delays and cost overruns; attributed responsibility for cost and schedule impacts to various Parties in accordance with contractual requirements. Evaluated and quantified concurrent delays. Applied various delay claims techniques including Time Impact Analysis, Windows Analysis, Impacted- As-Planned, and Collapsed-As-Built to quantify delay. Produced productivity analyses and identified construction inefficiencies. Responsible for redefining Contract Management processes and procedures and for developing a Claims Manual to serve as the standard guide to claims and disputes for the Company. Hill International Doha, Qatar (March 2013 to July 2013) As an Associate Director, Ms. Pechet was responsible for producing independent, expert delay and disruption analyses for settlement and arbitration purposes. Clients included Siemens, Metka, and Punj Lloyd, and involved offshore platforms, power plants, and airport projects. Managed and directed internal and external claims teams. Presented delay and disruption claims training seminars to clients. Invensys Operations Management Foxborough, Massachusetts (April 2012 to March 2013) As a Commercial Contract Management Specialist, Ms. Pechet was responsible for preparation and negotiation of change orders and claims to recover $60 million in cost overruns and to obtain relief from the assessment of liquidated damages. Project involved 8 DCS systems being designed, manufactured, and assembled by Invensys to control 8 nuclear power plants under construction in China. Analyzed cost overruns and schedule delays attributable to delays by the client in finalizing plant engineering and design inputs to the DCS. Compared design input delays with contractual requirements to determine schedule impacts to Invensys by system; produced change order proposals to recover revenue; revised the internal change management process; aided in formulating a commercial strategy for recovery of additional costs;

5 Resume of Joy Pechet, PMP Page 5 coordinated with Project Directors, Legal, Engineering and Project Controls to determine cause and effect of client s design input delays. Siemens Energy Third-Party Contractor Orlando, Florida (September 2010 to April 2012) Engaged as an external consultant by Siemens to aid in the preparation of assertive and defensive claims on a $1.2 billion coal-fired power plant project. Responsibilities included forensic schedule analysis, loss of productivity calculations, and cost overrun analyses. Scope of services included: (1) review of project correspondence, status reports, schedule updates, and cost reports to evaluate the cause and effect of delays, disruptions, loss of productivity, and cost overruns, (2) preparation of assertive and defensive claims, (3) analysis of contractual provisions to assess a Party s entitlement to additional costs and extension of time, and (4) presentations to Owner, Partners, project team, lawyers, etc. to defend and assert positions regarding the party responsible for cost/schedule impacts. ALSTOM Power Systems Plant Business Baden, Switzerland (January 2007 to July 2010) Director Forensic Planning, responsible for schedule delay, disruption, and loss of productivity analysis. Performed cause-and-effect and time impact analyses. Prepared negotiation strategies for cost and schedule claims. Interpreted contract and law to identify strategies for claiming Extension of Time (EOT) and cost entitlement opportunities. Negotiated EOT and loss of productivity claims for projects around the world. Responsible for identifying future schedule concerns and for proposing alternative mitigation plans to prevent further schedule deterioration; evaluated the cost/benefits of various schedule recovery options. Identified concurrent delay situations. Ensured that client interfaces and change orders are explicitly identified in the project schedule. Successful in recovering several months of liquidated damages assessment as well as prolongation and disruption costs as a result of forensic schedule analysis, contract interpretation, and client negotiation. Authored and presented training seminars on schedule delay, loss of productivity, and acceleration claims to project teams worldwide. US Government General Services Administration (GSA) Contractor Washington, DC (September 2005 to January 2007) As a Project Manager/Claims Consultant, Ms. Pechet was responsible for resolving $54 million in Requests for Equitable Adjustments and claims against GSA by a General Contractor on a $300 million project. Successful in getting parties to agree to settle these claims for $8 million. In addition, evaluated schedule delays; performed resource allocation studies; calculated economic losses as result of schedule delays; assessed impact of design/construction changes on schedule; determined negotiation strategies; and analyzed progress, resource requirements and cost performance on several GSA projects, including an IRS Renovation Project. Interfaced with project managers, clients, attorneys, and contractors to resolve schedule and cost disputes. ASRC Constructors Inc. Beltsville, Maryland (December 2004 to August 2005) As Project Controls Engineer, developed and monitored resource and cost-loaded schedules, performed cash flow analysis, analyzed earned value, and developed what-if scenarios for a classified $150 million Pentagon IT network upgrade project. Additionally, responsible for preparation and maintenance of multiple,

6 Resume of Joy Pechet, PMP Page 6 concurrent construction schedules for $20 million Dept of State FPSP Embassy Maintenance & Repair Program. Utilizing Primavera P3.1, prepared and monitored cost and resource-loaded schedules in a multiproject environment; negotiated change orders; managed field staff in remote locations; and prepared cost proposals for additional task order work. US Department of State OBO Washington, DC (August 2003 to December 2004) As a Project Controls Engineer, Ms. Pechet was responsible for the analysis of budgetary and cost information from multiple government sources; preparation of monthly reports on project budget status; preparation of Project Change Request and Amendments; tracking and analysis of allotments and obligations of project funds; resolving budget disparities; establishing internal budgetary controls; and managing project funding authorization changes. As a Construction Manager, Ms. Pechet was responsible for managing the construction of a $35 million in consulate in Cape Town, South Africa. Responsibilities included: day-to-day oversight and interface with General Contractor; monitoring and analysis of cost and schedule data; coordinating design and submittal reviews with government entities; critiquing and negotiating Contractor s Requests for Equitable Adjustment; coordinating multiple, integrated schedules; reviewing and monitoring General Contractor s schedule for critical path, logic errors, and inconsistencies with government schedules; developing risk mitigation plans; determining impact of contract mods on schedule in anticipation of construction claims. Utilized P3 and P5. GS-14 Step 10. Hill International Washington, DC (February 2002 to August 2003) As Managing Consultant in the Construction Claims Division, responsible for the analysis, preparation, and submittal of a $90 million claim by a subcontractor against the Massachusetts Central Artery. Responsibilities included: identifying cost impacts of scope changes; developing a methodology for segregating base costs from impacted and changed work costs; coordinating the financial analysis effort; identifying key issues responsible for cost overruns; providing analysis of project metrics; coordinating expert witness work; and preparing supporting documentation for use in negotiation. In addition, responsible for developing an Earned Value Management System for client. Bechtel Energy Corporation Frederick, Maryland (January 2001 to February 2002) As Claims Analyst, responsible for evaluating change order disputes and establishing claim strategies, including those affecting prime contracts, subcontracts, vendors, and partners. Effort included both the direct preparation and critiquing of offensive and defensive claims and disputes, and the direction of external resources to perform such tasks. Specifically involved in the assessment of the commercial aspects of claims, including interpreting cost and schedule data and preparing impact analyses. Aided in the preparation for negotiation, mediation, arbitration, and litigation. Assisted Project Management in its efforts to minimize risks and avoid claims situations.

7 Resume of Joy Pechet, PMP Page 7 Lockheed Martin Technical Operations El Segundo, California (June 1997 to June 2000) As Systems Engineer, responsible for project integration, requirements analysis, risk management, and process re-engineering of a major IT upgrade project for the Air Force. Managed the preparation of an Integrated Network Schedule consisting of 150 Air Force Satellite Control Network development/sustainment projects, Satellite Program launch activities, and network downtime schedules. Identified cross project impacts, resource conflicts, critical paths, and project interdependencies. Recommended risk mitigation options and resource reallocation plans. Performed sensitivity analysis on schedules. Documented technical, cost, and schedule risks. Led quarterly Risk Review Forums, with participation from contractors, AFSPC operations, and AF customer. WET Design Los Angeles, California (January 1995 to June 1997) As Project Manager, directed multi-disciplinary activities leading to the successful design, engineering, fabrication, and installation of elaborate, multi-million dollar water features within the US and abroad. As Director of WETCare, responded to client s field service requirements by directing field, engineering and programming staff to the site. Prepared and marketed project enhancement proposals. Resolved installation and warranty issues. Navigant Consulting, Inc. (formerly Peterson Consulting Limited Partnership) Boston, Massachusetts (July 1993 to January 1995) As Senior Consultant, provided litigation support consulting and contract disputes management. Performed damage and lost profits analyses for breach of contract, business interruption and wrongful termination disputes. Reviewed, analyzed, and prepared construction claims. Performed liability assessments, schedule/cost variance analysis, construction oversight, lost profits/productivity calculations, and delay and damage analysis. Walt Disney Company Euro Disney Paris, France (June 1987 to January 1992) As Project Controller, prepared feasibility studies, cash flow analyses, budgets, and cost variance analyses for hotel and resort construction projects totaling over $150 million; developed project proformas; designed and implemented financial reporting systems. PUBLICATIONS AND SPEAKING ENGAGEMENTS Contractual Recovery of Cost and Schedule Impacts Due to Errors, Inaccuracies, or Defects in the Employer s Invitation to Bid Documents, Long International, Inc., November 2014.