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ScheduleInsight · Claim Brief

Tower C — Commercial Tower & Podium

Extension of time & delay entitlement
R10 baseline to R12 update · forensic delay analysis

EOT RECOMMENDED — 12 DAYS
18d NET CRITICAL DELAY · 12d EXCUSABLE · 6d CONTRACTOR RISK
12dof 18d
Prepared for
Calderwood Construction Ltd
Respondent
Meridian Estates (Employer)
Contract
JCT D&B 2016
Analysis basis
R10 baseline vs R12 update
Method
Windows analysis · time impact
Standard
AACE 29R-03 aligned
Net critical delay
18 calendar days
Concurrency
12 days
Report reference
SI-CB-EX-003
ScheduleInsight
Parsed on-device · file never uploaded
Tower C · Claim Brief · R10 → R1228 Feb 2026

Contents

Report
01Entitlement summary3
02Windows analysis4
03Concurrency and its treatment5
04Method, standard and limitations6
Appendices — supporting detail
AWindow register and evidence7
BImpacted-network calculation8
CProvenance9
How to read this report

Section 1 states the entitlement and the reasoning in full. Sections 2 and 3 are the windows analysis and the concurrency treatment that produce it — these are the parts a respondent will test. Section 4 states the method and its limits.

Appendix A is the window register with the contemporaneous evidence relied on for each; Appendix B sets out the impacted-network calculation day by day; Appendix C records the provenance of every file used.

ScheduleInsight · Claim Brief2
1 · Entitlement28 Feb 2026

01 Entitlement summary

EOT
12 DAYS
RECOMMENDED
AWARD

The net critical delay of 18 calendar days resolves into 12 days of excusable, compensable delay (employer risk) and 6 days of non-excusable delay (contractor risk).

A 12-day concurrency exists between the employer and contractor events. Because those days overlap, the contractor's cost recovery for the compensable window is reduced or extinguished for the concurrent period, while the extension of time remains due.

Net critical delay
18 days
Excusable & compensable
12 days
Non-excusable
6 days
Employer risk — 12d
Contractor — 6d
Excusable & compensable Non-excusable

The position in one paragraph

Recommended EOT award: 12 days, with the residual 6 days remaining at the contractor's risk. The 12 days arise from the Employer's failure to respond to RFI-214 in due time, a Relevant Event under clause 2.26 and a Relevant Matter under clause 4.21. The 6 days arise from the contractor's own re-sequencing of Grid G steel erection beyond the period of concurrency. Loss and expense for the concurrent 12 days is not recommended; time is.

What this brief does and does not decide

It establishes what the programme shows and how the contract's delay provisions apply to it. It is not a legal opinion and does not determine quantum. Where the concurrency principle applied here is contested — and the treatment of concurrent delay remains contested in principle — section 3 sets out the alternative outcome so the parties can see the range rather than a single asserted answer.

ScheduleInsight · Claim Brief3
2 · Windows28 Feb 2026

02 Windows analysis

Three windows were analysed between the R10 baseline and the R12 update. Each window impacts the network as it stood at the start of that window, so the effect of each event is measured against the plan actually in force at the time rather than against the original baseline.

W1 — Level 3 pre-pour hold, RFI-214  Employer risk

02–14 August 2027 · impact +12 calendar days on the critical path. The Level 3 pre-pour inspection (activity A1733) was held pending the Employer's response to RFI-214 concerning a rebar detail. Under JCT D&B 2016 clause 2.26 a failure to provide information in due time is a Relevant Event giving rise to an extension of time, and a Relevant Matter under clause 4.21 giving rise to loss and expense. This is an excusable, compensable delay. The window is measured from the date the pour became due to the date the RFI response was received and the pour released.

W2 — Grid G structural steel erection rework  Contractor risk

10–28 July 2027 · impact +18 calendar days gross on the critical path. Erection of columns at Grid G, Levels 4–6 (activity A1422) was re-sequenced after fabricated steel was re-issued. This is a contractor-risk, non-excusable delay. For 12 of these days the effect ran concurrently with the tail of the employer-driven pre-pour hold; the remaining 6 days sit as pure contractor-culpable delay beyond the concurrency.

W3 — MEP rough-in logic correction  Nil award

Non-critical · no entitlement arises. Open-ended logic on the MEP rough-in chain (A1801) was closed during R12, revealing six days that had already been lost but were not visible while those activities had no successors. This is a disclosure correction, not a delay event: no party caused it in the window, and it confers no entitlement in either direction. It is recorded because it affects the arithmetic and would otherwise appear as unexplained movement.

Why windows rather than a single impacted baseline

An as-planned-impacted analysis run once against R10 would credit the full 18 days of W2 and the full 12 of W1 to their respective parties and miss that they overlap. Windows preserve the sequence, which is the only way the concurrency in section 3 becomes visible.

ScheduleInsight · Claim Brief4
3 · Concurrency28 Feb 2026

03 Concurrency and its treatment

Twelve of the eighteen days are concurrent: during that period both an employer-risk event and a contractor-risk event were independently delaying completion.

The overlap

W2 Grid G rework (contractor)18d
W1 Pre-pour hold (employer)12d
Concurrent period12d
Contractor-only period6d

The treatment applied

The approach taken here is the conventional English-law position: the contractor recovers time but not money for the concurrent period. An extension of time is granted for the full 12 days of the employer-risk event, because the employer cannot hold the contractor to a completion date that the employer's own act contributed to preventing. Loss and expense is not recommended for those days, because the contractor would have incurred the prolongation cost in any event by reason of its own concurrent delay.

PeriodDaysCauseEOTLoss & expense
Concurrent12W1 employer + W2 contractor, running togetherDueNot due
Contractor only6W2 beyond the concurrencyNot dueNot due
Net critical delay1812dnil
If the concurrency treatment is contested

The treatment of concurrent delay is not settled and the contract does not address it expressly. On an apportionment approach — as applied in Scots law and occasionally argued elsewhere — the 12 concurrent days would be shared, producing an EOT in the range of 6 to 12 days and a corresponding partial recovery of loss and expense. The parties should be aware that the recommendation in section 1 sits at the top of that range, and why.

ScheduleInsight · Claim Brief5
4 · Method28 Feb 2026

04 Method, standard and limitations

The analysis follows a windows / time impact methodology aligned to AACE International RP 29R-03, using the contemporaneous programmes actually submitted rather than a retrospectively constructed plan.

Method

Limitations

Illustrative example

Produced from fictional project data for illustration. No real schedule, client, contractor or contractual position is used or implied. Nothing here is legal advice.

ScheduleInsight · Claim Brief6
Appendix A · Windows28 Feb 2026

A Window register and contemporaneous evidence

Each window with its bounding dates, the activity impacted, the measured effect and the contemporaneous records relied on.

WEventWindowActivityImpactRisk
W1Level 3 pre-pour hold — RFI-21402–14 Aug 27A1733+12dEmployer
W2Grid G steel erection rework10–28 Jul 27A1422+18dContractor
W3MEP rough-in logic correctionR12 updateA1801nilNeither

Evidence relied on

WRecordDatedEstablishes
W1RFI-214 as issued28 Jul 27Date the information was requested
W1RFI-214 response14 Aug 27Date the pour was released
W1Site diary, pour hold entry02 Aug 27Date the pour became due
W2Steel re-issue notice, fabricator06 Jul 27Cause of the re-sequence
W2Revised erection sequence drawing09 Jul 27Scope of the rework
W3No contemporaneous record; derived from programme comparison alone

W3 is deliberately shown with no supporting record. A window whose only evidence is the programme itself cannot support an entitlement claim, and stating that is more useful than omitting the row.

ScheduleInsight · Claim Brief7
Appendix B · Calculation28 Feb 2026

B Impacted-network calculation

The completion milestone position after each window is inserted and the network recalculated. Movement is cumulative down the table.

StepNetwork stateCompletionMoveCumulative
0R10 baseline as approved01 Nov 270d
1W2 inserted — Grid G rework19 Nov 27+18d+18d
2W1 inserted — pre-pour hold19 Nov 27+0d+18d
3W3 — disclosure correction19 Nov 27+0d+18d
Net critical delay, R10 to R12+18d+18d
Why step 2 shows zero

W1 adds nothing once W2 is already in the network, and this is precisely what concurrency looks like in the arithmetic. Reversing the insertion order gives the mirror image: W1 first produces +12d and W2 then adds only 6. Neither order is more correct, which is why the 12 overlapping days are treated as concurrent in section 3 rather than credited to whichever event happened to be inserted first.

Order-sensitivity check

Insertion orderW1 attributedW2 attributedTotal
W2 then W10d18d18d
W1 then W212d6d18d
Concurrency-adjusted (adopted)12d6d18d

The total is stable at 18 days under every order; only the attribution moves. Publishing the sensitivity is the honest way to present an analysis whose result depends on a modelling choice.

ScheduleInsight · Claim Brief8
Appendix C · Provenance28 Feb 2026

C Provenance and reconciliation

Every file relied on, with the figures taken from it, so the analysis can be reproduced independently.

RoleFileData dateActivitiesCompletion
BaselineTowerC_R10_2025-11-30.xer30 Nov 253,61001 Nov 27
IntermediateTowerC_R11_2026-01-31.xer31 Jan 263,74409 Nov 27
UpdateTowerC_R12_2026-02-28.xer28 Feb 263,84219 Nov 27

Reconciliation to the Baseline Comparison

FigureThis briefBaseline ComparisonAgrees
Net critical delay18d18dYes
Gross event duration36d36dYes
Employer-risk days12d12dYes
Completion date19 Nov 2719 Nov 27Yes

The two reports are produced from the same files and must agree on the facts even where they differ in purpose. Any divergence would indicate an error in one of them.

Method
Windows / time impact
Standard
AACE RP 29R-03 aligned
Contract
JCT D&B 2016
Clauses engaged
2.26 (EOT), 4.21 (L&E)
Computation
In-browser, file not uploaded
Report reference
SI-CB-EX-003
ScheduleInsight · Claim Brief9

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Every report in the set is built from a Primavera P6 or Microsoft Project file, parsed in your browser. Nothing is uploaded and nothing is retained.