Analysis and comparison of project schedules is the best means of determining the impact of delays or disruptions upon a construction project. A compensable delay is one for which the Owner is responsible. The delay or disruption may be shown by comparison of the various project schedules. The impact of "pure" delay is usually readily assessable, but extended or numerous minor delays, and the effect of other disruptions also have impacts which may be demonstrated by schedule analysis. Loss of "learning curve" efficiencies is a common impact of Owner disruption. Here, actual labor costs and estimated labor costs applied under the "As- Planned" schedule are extremely helpful. Loss of labor efficiency is another impact of disruption readily demonstratable through use of project schedule analysis. Working under adverse weather conditions, overtime hours, etc. all contribute to inefficiency and result from delay or other disruptions.
- Teledyne McCormick-Selph v. United States, No. 448-76 (ct. cl. Dec. 13, 1978)
- Fairchild Stratos Corp., ASBCA 9169, 67-1 BCA 6,225
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