William J. McConnell

Fundamentals of Construction Claims


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communications and binding dispute resolution. One way to avoid such discomfort is for the parties to review the dispute resolution process up front and periodically during the production phase so both parties are reminded that the defined claim protocol is there to resolve issues early in the dispute resolution process and it serves to prevent claims from snowballing to a point where binding dispute resolution is the only way to achieve resolution. Resolving claims early is typically a benefit to both parties.

      Each of the examples below is based on a contractor being the claimant and an owner being the respondent and the two parties have entered a standard contract form and the owner is responsible for the design on the project. The examples cover the notice of claim provision typically required for general claim items, claims regarding a lack of adequate funding, claims related to a failure to make timely payments, and termination by the contractor.

      A. Notice of Claim Provisions for General Claim Items

      1. AIA A201 General Conditions

      Per Section 1.6.2 of the AIA A201, the claimant (owner or contractor) shall serve notice of claims in writing and deliver such notices via certified or registered mail, or by courier providing proof of delivery. Per Section 15.1.3 of the A201, for claims where the condition giving rise to the claim is first discovered prior to the expiration of the contractor's one-year warranty period, the claimant (owner or contractor) shall initiate the claims process by providing notice to the initial decision maker, the other party, and the architect. Claims by either party must be initiated within 21 days after the occurrence of the event giving rise to such claim or within 21 days after the claimant first recognizes the condition giving rise to the claim, whichever is later. When the condition giving rise to the claim is first discovered after expiration of the contractor's one-year warranty period, it shall be initiated by notice just to the other party.

      Sample Notice Letter that Conforms to the AIA A201

      Via Certified Mail

      April 23, 20__

      Owner

      Address

      Re: Project: Project Name

      Subject: Section 15.1.3.1 Notice of Claim

      Dear Owner/Initial Decision Maker/Architect,

      Pursuant to Section 15.1.3.1 of the AIA A201 General Conditions, Contractor hereby submits a formal Notice of Claim for the additional scope of work identified on the revised architectural plans that Owner issued to Contractor one week ago, on April 23, 20__. Specifically, Drawing A.2.06 indicates approximately 80 additional feet of wall assembly that was not contemplated in the bid set of plans that the Contract Price is based upon. Thus, this scope is outside of the defined Work. Contractor is calculating cost and time impacts associated with this additional work and will issue a formal Claim for an initial decision per Section 15.2 of the A201 soon. If you have any questions or comments, please contact Contractor at your convenience.

      Sincerely,

      Contractor

      2. ConsensusDocs 200

      Sample Notice Letter that Conforms to the ConsensusDocs 200

      Via Certified Mail

      April 23, 20__

      Owner

      Address

      Re: Project: Project Name

      Subject: Section 8.4 Notice of Claim

      Dear Owner,

      Pursuant to Section 8.4 of the ConsensusDocs 200 contract, Contractor hereby submits a formal notice of claim for the additional scope of work identified on the revised architectural plans that Owner issued to Contractor one week ago, on April 23, 20__. Specifically, Drawing A.2.06 indicates approximately 80 additional feet of wall assembly that was not contemplated in the bid set of plans that the contract price is based upon. Thus, this scope is outside of the defined Work. Contractor is calculating cost and time impacts associated with this additional work and will issue a formal Claim with supporting documentation within 21 days of this notice of claim. If you have any questions or comments, please contact Contractor at your convenience.

      Sincerely,

      Contractor

      3. EJCDC C-700 General Conditions

      Sample Claim Cover Letter that Conforms to the EJCDC C-700

      Via Certified Mail

      April 23, 20__

      Owner

      Address

      Re: Project: Project Name

      Subject: Section 12.01.B Claim

      Dear Owner/Engineer,

      Pursuant to Section 12.01.B of the EJCDC C-700 General Conditions, Contractor hereby submits a formal claim for the additional scope of work identified on the revised engineering plans that Engineer issued to Contractor one week ago, on April 23, 20__. Specifically, Drawing A.2.06 indicates approximately 80 additional feet of wall assembly that was not contemplated in the bid set of plans that the Contract Price is based upon. Thus, this scope is outside of the defined Work. The following claim includes sections on entitlement, delay, and damages associated with this issue. If you have any questions or comments, please contact Contractor at your convenience.

      Sincerely,

      Contractor

      B. Notice of Claim Provisions for Lack of Evidence of Owner's Financial Arrangements

      1. AIA A201 General Conditions

      Per Section 2.2.1 of the AIA A201,