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© Turner & Townsend plc December 11 making the difference

FIDIC, extension to Time for Completion and liquidated damages in the Middle East

April 2014

2

FIDIC, extension to Time for Completion and liquidated damages in the Middle East Timetable

Timetable

Time Topic

5 mins Timetable

8 mins FIDIC Range of Contracts

3 mins Contractual Roles

8 mins The Contractor and Clause 8

4 mins The Contractor and Sub Clause 20.1

2 mins Clause 8 and relevant Sub Clauses

5 mins The Engineer

10 mins Engineer’s calculation and determination

5 mins Employer’s Claims & Delay Damages

10 mins Demonstration and illustration of unliquidated and liquidated damages

5 mins Conclusion

Questions & Answers

Richard Chamberlain


FIDIC Range of Contracts

4

GREEN BOOK

4

Short Form of Contract

Recommended for building or engineering works of a relatively small capital value, for relatively simple work, or work of a short duration.

5

RED BOOK

5

Conditions of Contract for Construction for Building and Engineering Works Designed by the Employer

6

PINK BOOK

Construction Contract MDB Harmonised Ed (Version 3: June 2010)

Pink Book project is MDB financed and a development of the Red Book

(Multilateral Development Banks who provide finance for projects in developing countries)

6

7

YELLOW BOOK

7

Conditions of Contract for Plant and Design-Build for Electrical and Mechanical Plant and for Building and Engineering Works designed by the Contractor

8

SILVER BOOK

8

Conditions of Contract for EPC/Turnkey Projects

.

9

GOLD BOOK

9

Design, Build and Operate Projects (2008)

10

WHITE BOOK

10

Client/Consultant Model Services Agreement (4th Ed 2006)


Contractual Roles

13

FIDIC & Contractual Roles

• Complete design

• Progress the works in a regular and diligent manner

• Safe manner of work

• Workmanship

• Consultancy Agreement

• Responsible for Design

• Supervision of Contractor

• Provide possession of the Site

• Provide information

• permits and consents

• Appoint the Engineer

• Payment

• Instructions

• Variations

• Certifier of extensions to Time for Completion

• Certifier of Payments

• Determinations

Engineer

Obligations

Employer

Obligations

Contractor

Obligations

Engineer

Administers Contract

making the difference

The Contractor & Clause 8

15

The Contractor

■ The Contractor in FIDIC is :

■ the master of the programme

■ revises the programme when necessary

■ notifies the Engineer of the causes of delay to the programme (Clause 8 and 20)

■ consults with the Engineer to assist in the determination of extension to the Time for Completion

15

16

Clause 8

■ 8.1 Commencement of Work

■ 8.2 Time for Completion

■ 8.3 Programme

■ 8.4 Extension of Time for Completion

■ 8.5 Delays Caused by Authorities

■ 8.6 Rate of Progress

■ 8.7 Delay Damages

■ 8.8 Suspension of Work

■ 8.9 Consequences of Suspension

■ 8.10 Payment for Plant and Materials in Event of Suspension

■ 8.11 Prolonged Suspension

■ 8.12 Resumption of Work

16

17

Sub Clause 8.3 Programme

■ Summary:

■ The Contractor shall submit a programme to the Engineer as required in the Contract.

■ The Employer's Personnel shall be entitled to rely upon the programme when planning their activities.

■ The Contractor shall promptly give notice to the Engineer of specific probable future events or circumstances which may delay the execution of the Works.

■ If the Engineer gives notice to the Contractor that a programme fails the Contractor shall submit a revised programme to the Engineer in accordance with this Sub-Clause.

17

18

Clause 8.4: Extension of Time for Completion

18

■ Summary

■ The Contractor shall be entitled to an extension to Time for Completion, if delayed by any of the following causes:

■ (a) a Variation

■ (b) a cause of delay under a Sub-Clause of these Conditions

■ (c) exceptionally adverse climatic conditions

■ (d) any Unforeseeable delay, impediment or prevention caused by Employer

■ ….”the Contractor shall give notice to the Engineer in accordance with Sub-Clause 20.1 [Contractor's Claims]”

■ ….”the Engineer shall review previous determinations and may increase, with the Employer's written approval, but shall not decrease, the total extension of time”


The Contractor and Sub Clause 20.1

20

Tension between Clause 8.3 and 20.1 Does probable = aware ?

Cl 8.3: The Contractor shall promptly give notice to the Engineer of specific probable future events…

Clause 20.1: The notice shall be given as soon as practicable, and not later than 28 days after the Contractor became aware or should have become aware, of the event or circumstance

21

Avoiding “probable and aware”

Tension between 8.3 and 20.1

• Notices are in a state of flux • Engineer can time bar • Engineer’s Determination can only be overturned in arbitration

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Cl 8.3 & 20.1"Probable "and "Aware" are

merged

Cl 20.1Fully Detailed Claim

(Interim)

Cl 20.1Fully Detailed Claim

(Interim)

Update or final after end of effects


Clause 8 Matrix

23

Clause 8 Matrix of potential causes of delay


The Engineer

25

The Engineer - Generally

■ The Engineer is a quasi arbitrator and has two functions, namely:

■ Agency function, where s/he administers the Contract on behalf of the Employer

■ Decision making function, where s/he certifies time and money

■ When in the agency function, the Engineer must not misapply or misunderstand the Contract

■ When in the decision making function the Engineer must be independent and fair to both the Employer and the Contractor

■ Over certification by the Engineer is negligence

■ The Engineer has no duty of care to the Contractor

25

26

The Engineer - Certification

■ The Engineer

■ acts as the Employer’s agent

■ must consult with the Contractor and Employer when differences arise

■ must carry out fair determinations

■ must calculate all certificates in a logical and methodical manner


Engineer’s calculation and determination

28

Logical and methodical process

Step 1 -

Investigation

Records

Step 2 -

Summary

Data basing

Analysis

Graphing

Step 3 -

Verification

Method selection

Step 4 -

Analysis

Application of method

Step 5 -

Graphical

Finalisation of Report

Investigation Conclude

Step 6 -

Award

Engineer determines entitlement

Analysis Review

29

Step 1 - Investigation

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Information Gathering

- Meetings interviews with project team - Orientation meetings with client - Document review (schedule of likely document types included below)

Action Output

No external deliverables

Aims and considerations

Internally: - Chronology - Document mapping - Sequence sketches - General overview notes

Analysis route to be matched to information available and issues identified. Initial aim is to develop robust overview as-planned v as-built.

Investigation

Comment

30

Step 1 - Typical record types

Programme

•Basel ine Programme

•Revised Basel ine programmes

•Progress Programme Updates

Progress Records

•Progress Reports

•Marked up progress drawings

•Progress Photos

•Site diaries

•Minutes of Site Meetings

Contract Documents

•Drawings

•Specif icat ion

•Condit ions of Contract

Drawings and production Records

•Iso / spool dwg tracking schedules

•Iso / spool fab /del ivery records

•Drawing registers

•Inspection and test records

• Reactor vessel / plant i tem design, manufacture and del ivery records

•FEED design detai ls

Payment records

•EPC contractor appl icat ions

•Suppl ier / sub-contractor appl icat ions

Project Admin Records

•Client instructions

•Site Instructions

•Change notices

•Delay Notices

•Correspondence

•Any claims submissions to date by Tecnicas Reunidas

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

31

Step 2 - Summary

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Establish baseline and actuals

- Identifying Baseline programme from candidates. - Compilation / verification of as-built records to generate robust As-built programme. -Sense checking / cross referencing as-built records for resilience

Action Output

As-planned v As-built

Aims and considerations

-Reasoned selection of baseline -Verifiable as-built - Notes on verification and sources of data.

As-built programme element potentially as summary level in order to deliver early overview. Extent to which summary required depending upon availability and quality of records, time available and consideration of issues.

Summary

Comment

32

Step 3 - Verification

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Interrogation of T&T output

-Review of Step 2 outputs (predominantly As-planned v As-built). -Identification of significant programme variance (delay / sequence change). -Identify key events. - Develop analysis windows.

Action Output

Key Decision point Aims and considerations

-Definition of key events. - Definition of Analysis windows/time slices.

Step presents opportunity to review delays identified and to consider potential causation/ liability positions. Option to substantially modify approach based on findings to date.

Verification

Comment

33

Step 4 - Analysis

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Detailed investigation

-Review progress by sub dividing the project into a series of windows and examining each window in detail -Analysis will deliver extent and causes of delays in each window. - development of view of actual critical path in each window.

Action Output

No external outputs Aims and considerations

Internally: -Windows analysis and graphics. - Initial report outline. - Notes on causation. - Notes on critical path and critical delays.

Detailed analysis stage. This stage is likely to be time consuming. Initial approach of investigation of most significant areas of delay may be appropriate. NOTE - A selective approach cannot deliver certainty and often increases time and cost to prepare opinion in the long term.

Analysis

Comment

34

Step 5 - Causation

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Finalising Report

- Finalising delay in each window and cumulative critical delay. - Causation findings set out. - Drafting Preliminary Expert opinion.

Action Output

Opinion Aims and considerations

- Summary table of delay events, extent, whether critical, dates during which delay occurred, etc – to enable quantum assessment to be established.

In order to comply with initial phase timescale significant short cuts in analysis and causation phases are likely to be necessary – hence the preliminary nature of the report. Causation opinion should enable issues behind critical delays to be identified and settled.

Causation

Comment

35

Step 6 - Liability

Step 1

Investigation

Step 2

Summary

Step 3

Verification

Step 4

Analysis

Step 5

Causation

Step 6

Liability

Legal views

- Preliminary report

should enable legal assessment of liability issues. - Quantum (loss & expense, liquidated damages) assessment should be available

Action Output

Output Engineer’s Determination

- Output likely to be award or non award of the extension to Time for Completion.

Preliminary opinion should be suitable for use in dispute resolution.

Liability

Comment


FIDIC & Delay Damages

37

Unliquidated or general damages

Employer breaches: • interference and prevention • late supply of information • failure to give possession

Result of Employer breaches is Contractor’s claims for:

•delay • disruption • prolongation • extension to the Time for Completion • additional payment

In summary, the Contractor’s remedy for an Employer’s breach is recovery of general or unliquidated damages. (Note: Unliquidated damages are assessed after the breach)

38

Liquidated damages

Liquidated is a word recognised in the Shorter Oxford Dictionary and from as early as 1574 and is defined as ‘ascertained and fixed’ Questions that arise with respect to liquidated damages:

• Are they an exclusive remedy for a breach? • an agreed price to be paid for a breach or non performance

• Is an agreed price for a breach a penalty? • is the liquidated damage disproportionate to the loss?

• Can the parties agree any price they wish? • freedom of contract –v- penalty

• What is a genuine pre-estimate of loss? • is a genuine precise pre estimate impossible to determine?

•What is the purpose of liquidated damages?

• from Contractor’s perspective it takes away uncertainty and provides an incentive to perform • for Employer, the burden of proving actual loss

39

Middle East (FIDIC delay damages –v- Liquidated damages)

Qatar

• Arabic term for liquidated is fines • principle of ‘freedom of contract is endorsed • principle of ‘good faith’ and bound by terms agreed • pre estimates of liquidated damages are permitted • no distinction between penalties and liquidated damages • FIDIC delay damages replaces liquidated damages • a genuine pre estimate is an important concept • exhaustive remedy depends on drafting • adjustment if no loss is incurred • superseding or contributory fault reduces compensation • liquidated damages provide certainty in contract • liquidated damages are uncertain in law due to exceptions and circumstances A guide to liquidated and ascertained damages for the Qatar construction sector, Warren L, Hall A (2013), Clyde & Co

40


United Arab Emirates Construction contracts provide for: • pre determined amount of damages to be paid by Contractor for late completion of a project • liquidated damages are an incentive for the contractor to perform • liquidated damages removes the burden of ascertaining loss The Courts have determined: • liquidated damages is a secondary obligation • delay fines in contracts are a penalty clause and a secondary obligation • termination is fatal to liquidated damages • liquidated damages are an estimate and actual loss is preferred • no loss then liquidated damages should be repudiated • the application of liquidated damages is subjective and prone to the application of exceptions

Liquidated damages under UAE and UK law, a comparison (2014), Ibrahim A, Mullen J, Fenwick Elliot

41


Sultanate of Oman Royal Decree No. 29/2013 enacting the Civil Code issues such as liquidated damages relating to building contracts (Muqawala) is codified as follows: • if the subject matter of obligation is not a sum of money, the contracting parties may determine the amount of compensation in advance by making provision of same in the contract or in a subsequent agreement • In all cases, the court may, upon application of either of the parties amend such agreement to make the compensation equal to the damage , and any agreement to the contrary shall be null and void Result : • courts may award liquidated damages • liquidated damages must be a reasonable assessment of the loss • Court may reopen liquidated damages and award general damages

Construction Disputes in Oman – Here and Now (2013), Curtis, Mallet – Prevost, Colt & Mosie LLP

42

Summary (FIDIC delay damages –v- Liquidated damages)

Principles surrounding liquidated damages : • freedom of contract is acceptable practice • parties free to agree liquidated damages • liquidated damages must be reasonable estimate • liquidated damages can be reopened by the courts • liquidated damages may fall away and be substituted by general damages Conclusion: In respect of the application of liquidated damages in the Middle East there is no such thing as certainty


Presenting extensions to Time for

Completion


Visualising the Critical Path

45

DN65 Contract 206

DOLJ County Limit to Slatina

21+200 to 49+000 Km

DN65 Contract 207

Slatina to Pitesti County Limit 54+000 to

90+000 Km

DN65 Contract 208

Pitesti County Limit to Pitesti = 90+000 to

115+000Km NR65B

Pitesti County Limit to Pitesti

46

Km 21+200

Km 115+000

Km 0+000

Km 7+400

Contract 206

Contract 207

Contract 208

A1

A2

A3

A4

A5

A6

A7

A8

A7

A6

A5

A4

A3

A2A1

A1 A2 A3

A4

A5

A6

A7

A8

Saru Forest

Negreni Lane

B1 - km 28+179

B2 - km 33+180

B3 - km 43+550

B4 - km 44+850

B5 - km 48+250

B6 - km 48+570

B7 - km 59+050

B6 - km 70+265

B5 - km 70+650

B4 - km 71+863

B1 - km 75+634

B2 - km 82+191

B3 - km 86+476

B2 - km 1+440

B1 - km 3+365

B3 - km 109+137

B4 - km 109+067

B5 - km 107+170

B6 - km 96+300

B7 - km 96+088

B9 - km 92+500

B8 - km 94+700

km 21+200

km 24+650

km 29+690

km 41+650

km 42+180

km 47+360

km 49+000

km 7+400

km 3+400

km 115+000km

109+000

km 106+400

km 100+500

km 94+500

km 54+000

km 58+000

km 60+500

km 69+500

km 72+600

km 75+500

km 81+000

km 83+200

km 90+000

km 32+600

km 37+200

Key

= Bridge:- Number & Chainage

B1 - km 75+634

= Programme Window \ Timeslice

A7

= Tree Felling

47

Construction Methods

Stage 1 : Original Road Profile and Structure Exhibit C-2 : Typical Cross Section Nr. 1

Exhibit C-2 : Typical Cross Section Nr. 1 shows the proposed

rehabilitated road profile in black lines. Original road profile shown in

broken green line

48

Stage 2 : Topsoil Removed Working Drawings Non-Critical

A 1km stretch of carriageway is closed and the topsoil removed from the banks and stored for

future use


49

Stage 3 : Excavation Working Drawings Non-Critical

The existing bank is excavated to enable the new profile of the

rehabilitated road to be formed and the foundation layers placed


50

Stage 4 : Fill to Form Bank Profile Working Drawings Non-Critical

A portion of the excavated area is filled with earth to form the new

road bank profile and enable work to begin on the foundation layers of

the road


51

Stage 5 : 4% Lime Sub-Base Working Drawings Non-Critical

A 15cm deep sub-base layer made up of soil treated with 4% lime is

laid


52

Stage 6 : Granular Sub-Base Working Drawings Non-Critical

A 35cm deep granular sub-base layer is laid and

compacted


53

Stage 7 : Stabilised Ballast 6% Cement Working Drawings Non-Critical

A 25cm layer of natural aggregates stabilised with 6% cement is laid using shuttering to the outer edge


54

Stage 8 : Regulating/Base Course Working Drawings Critical

A 4cm base course is laid across the carriageway together with a

regulating course where necessary to achieve the proposed road profile


55

Stage 9 : Binder Course Working Drawings Critical

A 4cm binder course is laid on top of the base course


56

Stage 10 : Fill up to Base Course Level Working Drawings Non-Critical

The new bank is filled to underside of the stabilised ballast layer


57

Stage 11 : Identical Works to Opposite Carriageway

The same 1km stretch of the opposite carriageway is closed and stages 1 to 10 inclusive are carried out to that side (construction up to

binder course)


58

Stage 12 : Wearing Course to First Carriageway Working Drawings Critical

A 4cm wearing course (MASF16) is laid to the first carriageway


59

Stage 13 : Wearing Course to Opposite Carriageway Working Drawings Critical

A 4cm wearing course (MASF16) is laid to the opposite carriageway


60

Stage 14 : Fill to Shoulders Working Drawings Non-Critical

The remaining section of the new bank is filled. During this process a

small length of one side of the carriageway is closed to carry out

the work


61

Stage 15 : Topsoil to Banks Working Drawings Non-Critical

Exhibit C-2 : Typical Cross Section Nr. 1 Constructed

The new banks are covered with topsoil using the material removed

in stage 2

Completed Road



Photographs to illustrate the critical path

63

South Central Depot Improvement Contract Littlehampton Depot

Delay Event 1: Bellmouth:

(Entrance to the site and car park and work which has encountered a critical path delay of 34 days)

Volume 1:

7.0 EXTENSION OF TIMEPARTICULARS

DELAY EVENT 1

64


Delay Event 2: Upsidings:

(An area of work located between the cleaning shed and train washer and adjacent the car park and that has encountered a critical path delay of 42 days)

Volume 1:


DELAY EVENT 2

65


Delay Event 3: Path 6

(An elevated reinforced concrete pathway and canopy located between siding 3 and 4 in the “Backsidings” and that has encountered a critical path delay of 20 days)

Volume 1:


DELAY EVENT 3

66


Delay Event 4: PSU

(The upgrade of the power supply that is located adjacent the car park and which has caused a critical path delay of 81 days)

Volume 1:


DELAY EVENT 4

67


Delay Event 5: ETE

(The late installation of electrical traction engineering, which has resulted in a critical path delay of 17 days)

Volume 1:


DELAY EVENT 5

68


Delay Event 6: Car Park Works

(The late construction of the car park, which has resulted in a critical path delay of 41 days)

Volume 1:


DELAY EVENT 6


Modelling the critical path

70

Dalston Junction Station

70

71

71

72

Construction Sequence

72

73

Piles

73

Piles

74

Pile Caps

74

Pile Caps

Piles

75

Walls & Columns

75

Pile Caps

Walls Columns

Piles

76

Podium Steel

76

Pile Caps

Walls Columns

Podium Steel

Piles

77

Pile Caps

Walls Columns

Podium Steel

Piles

Trackslab

Trackslab and Platforms

77

Trackslab Trackslab Platforms

78

Temporary Supports

78

Pile Caps

Walls Columns

Podium Steel

Piles

Temporary Supports

Trackslab Trackslab Trackslab Platforms

79

Podium Slab

79

Pile Caps

Walls Columns

Podium Steel

Piles

Podium Slab

Trackslab Trackslab Trackslab Platforms

80

Platform Finishes

Pile Caps

Walls Columns

Podium Steel

Piles

Podium Slab

Trackslab Platforms

80

Platform

Finishes

Trackslab Trackslab


Flow charting the critical path

82

Flowcharts to assess the impact of variations

Off Site design of software / graphics & development of DOP’s

Revised Minimum Air Volumes

Perforated Plates

Modify Volumes to perimeter zones

Remove Perforated Plate and blank 1 No Bell Mouth

Disable CV Box

Acoustically line 4No Bell Mouths

83

Analysis of commissioning plans

Off Site design of software / graphics & development DOP’s

Note: Off Site Operations should be complete.

• Engineer located at the Head End. • Engineer located at the Controller. • Engineers communicate via radio. • Certain conditions require simulation by the Engineer at the Controller i.e. Boilers and Chillers need not be available. • All points would be checked in this way. • The Specification set out that Systems 33 & 35 should be commissioned separately. • In our opinion, 1 - 2 days would have been allowed to commission System 33. • After all points are checked and both Engineers satisfied, the System is ready for witnessing.

84

SPECIFIED WITNESSING PROCEDURE


Stage 1 - Point to Point Checks. • Carried out in the field with the Witness Authority located with Engineer at IQ Controller. • Another Engineer in the Plant Room. • Communication via radio. • Engineer at Controller would force values and start fans etc. • Plant Room Engineer confirming actions have taken place. • 10% of points agreed between OAP, Skanska and Axima.

85


System 33 and 35 should have been witnessed individually as the specification dictated.


Stage 2 • Engineer located at Controller. • Engineer at Head End along with the Witnessing Authority. • Communication via radio. • Proving the functionality of the plant in automatic mode using graphics. • This witness would take place on a System by System basis again with simulation being generated to prove Global Interfaces.

86


Site design of software / graphics & development DOP’s

Stage 3 • The final stage is termed as The Global Witness. • This can only be carried out when ALL relevant items of plant are online and functioning correctly. • In the instance of Systems 33 & 35, the Boilers and Chillers are required to be operational and functioning in automatic mode. • This witness would take place during a 2 week period at the end of the project, which would include the 7 day Continuous Run, immediately prior to Practical Completion. • The building should be empty of other trades, sub-contractors & free of dust & debris etc.


Bar charts & network analysis

88

Factual Analysis Dealing with Scenario 3 – Impact on Level 3

89


Contractor theoretical critical path

90

2 Month Delay


91

7.5 Month Delay


92

9.5 Month Delay


93

12 Month Delay


94

12 Month Delay


95

15 Month Delay


Engineer critical path after factual analysis

96

15 Month Delay

12 Month Delay

12 Month Delay

9.5 Month Delay

7.5 Month Delay

2 Month Delay



Charts in general

98

98

Anticipated output = green line

Actual output = Blue Line

Delay Effect = Red Bars

Factual Analysis Dealing with Scenario 2 – Late Detail Design

99

■ The example of the Level 3 programme shows the effect of

design delay in blue background facilities that make up the

project

■ The construction in each facility is being driven out and delayed

by red delay bars that represent late detail design

■ Each red delay bar in each facility has a different effect and

length of delay, this is called causative potency

■ The longest red bar in a facility = the primary critical path and

the others that follow behind are the secondary critical paths

99

PROCUREMENT DELAY EVENT 1: ROOF FANS

PROCUREMENT DELAY EVENT 2: MOLY SCREW DRYER

PROCUREMENT DELAY EVENT 3: AGITATORS

PROCUREMENT DELAY EVENT 4: ROCK BREAKER

PROCUREMENT DELAY EVENT 5: HIGH ANGLE CONVEYORS

PROCUREMENT DELAY EVENT 6: IN PLANT CONVEYORS

PROCUREMENT DELAY EVENT 7: BELT FEEDER

PROCUREMENT DELAY EVENT 8: MOLY BAG FILLING SYSTEM

PROCUREMENT DELAY EVENT 9: BRIDGE CRANE

EPC Planned

Provisional Acceptance

Target Date 31 December 2010

Factual Analysis Dealing with Scenario 2 Level 3 Critical Path Analysis

Primary Critical Path

100

100

Use of man hour histograms to analyse displaced start and subsequent effect upon man hour expenditure Blue = cause of delay Red = effect of delay

Factual Analysis Dealing with Scenario 3 – Resource Analysis


Thank You Questions & Answers