Equipment spread costs
Equipment spread costs;
The relevant period for operations and waiting on weather is from 20 June 2022 to 9 August 2022 inclusive. For the avoidance of doubt, this should include the demobilisation day (as appears to be accepted in the Counterfactual calculations, but is the correct approach in any event). This is 51 days. The amount due is £216,750 (ex VAT).
For the avoidance of doubt, this excludes £34,000 claimed under invoice 02194 for ‘UTV-670 transit’, between 19 August 2022 and 26 August 2022. There is no explanation of the contractual or factual entitlement to this sum by way of pleading, evidence or submission.
- Heading
- hand-down is deemed to be 10.30 on the 11 th of July 2025
- B The Factual and Expert Witness Evidence
- Factual Chronology up to Sailaway of the Susanne A
- D. The Contract
- The Proper Approach to Construction
- Daily Charges for more than 10 days
- Daily Charges for more than 7 personnel per day
- Personnel mobilisation and expenses for more than 7 personnel
- Daily charges for personnel prior to the arrival of the UTV-670
- Daily charges during periods of breakdown
- Daily charges for waiting on weather
- Application of LADs
- The Mobilisation Date
- D. Did Pharos deliver to the UTV-670 to Esbjerg with reasonable skill and care and/or within a reasonable time for the purposes of mobilisation?
- E. The Embedment Works: The Causes of Downtime
- Weather Downtime
- Tidal Downtime
- Seabed Condition Downtime
- Technical and Operational/Tool Downtime
- E. KML’s Allegations of Breach
- Supply of the UTV-670 unable to cope with seabed gradients
- The associated equipment, deck layout and personnel
- F. What was a reasonable time for carrying out the Embedment Works?
- G. Quantification of Pharos’ Claim
- Section 25
- Equipment spread costs
- Personnel costs (excluding expenses)
- Personnel daily expenses
- Transportation of the UTV-670 and other equipment
- Transportation (flights) for personnel/employee
- H. Quantification of KML’s Counterclaim
- Conclusions
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