SAPMT has reviewed the subject letter no. KPSS/SA/B/AKR/14/0735 dated August 07, 2014 and has the following comments:
1.	IC is urged to provide information in its correspondence which is based on facts. The attached SAPMT letter no. K&TPD/KRP&SFPD/RPI/L-072/13 and K&TPD/KRP& SFPD/RPI/L-052/13 and IC letter no. ICC/SA/KPSF/KD/0002/2013 shall show that IC was unable to provide a mobilization schedule and subsequent mobilization according to the requirements of the contract on time even though the mobilization had to be completed in February 2013. The letters attached shall also show that IC was allowed to start mobilization works under the supervision of SAPMT even though the approvals for schedules and plans were still undergoing revisions. The camp, the precast plant, mobilization on site, mobilization of human resources and the IFC were all delayed. Hence IC claim that IC could not start works before August 21, 2013 are rejected. IC is urged to study the schedule B where the notice to proceed is related to actual work and not mobilization. Mobilization works or design works can be completed before the notice to proceed. All long lead items have been delayed which have no relationship with the notice to proceed. CONTRACTOR's failure to comply, unless otherwise excused pursuant to this Contract, constitutes a substantial breach of this Contract. Please also refer to SAPMT letter no. K&TPD/KRP&SFPD/SF/L-928/14 and 927/14 where various issues regarding progress delays have been highlighted.
2.	IC claim that delays have occurred due to revision in IFC are baseless because the first submission of IFC itself was delayed by IC by approximately 4 months. The second revision has still not been submitted and SAPMT has allowed works with partly revised IFCs to avoid any delays.
3.	IC is urged to refer to the contract SCH-B para 3.5, 3.9 and 3.10, regarding interfaces, where it is IC responsibility to deal with interfaces with utility companies. Inability of IC to facilitate the project by finding solutions or alternatives for interfaces on time or carrying out prompt and effective studies to avoid issues during construction while preparing IFC has caused delays. 
4.	IC is urged to refer to the contract SCH-B para 3.10, regarding interfaces, where it is IC responsibility to deal with interfaces with other contractors working in the area.
5.	IC shall understand that damaging exiting national utilities without coordination with the utility companies and employing an effective interface manager shall result in unforeseen dire consequences and cannot be considered as a reason for delays.
6.	Changing priorities during the execution cannot be considered as a reason for delays, unless IC proves that IC has or had ample resources to start works simultaneously on each and every activity of the project. All procurements and activities have been continuously behind schedule.
7.	Works at gate 2 and 3 have stopped due to IC inability to produce shop drawings on time, unavailability of IC resources to work on buildings, delays in employing a sub-contractor, inability to start works despite the work permits and traffic plans have been approved, unavailability of water and electricity on site and inability to deal with interfaces.
8.	Suspension of ditch has not delayed any other activities at that time, because IC had not started any other activities on the project at that time.
9.	Redesign due to ditch elimination has not delayed any works because the redesign is limited to the relocation of IDAS and removal of ditch, whereby IDAS has not yet started and the precast wall and patrol road has stayed at the same alignment as before.
10.	Any reworks done after suspension of ditch shall be considered during the next amendment to the contract however SAPMT believes that suspension of ditch has not delayed any other activities and by suspending a big portion of scope of work, IC shall be able to deliver the project much earlier.

As a revised schedule submitted by IC has already been approved by SAPMT, and process to amend the contract for deletion of ditch from the contract has been initiated by SAPMT and pending with IC to agree, IC is urged to ensure that the project is delivered on time without any delays.
