A delay submission is not an argument to be won on the page. It is a document that has to let an assessor reach a view, which means it has to be short, ordered and checkable. Getting that right is most of the value in extension of time claim preparation.
The common failure is volume: hundreds of pages that establish how much work was done rather than what the assessor needs to decide.
What the document has to establish
That a relevant event occurred, that notice was given as the contract requires, that the event delayed completion, and by how long.
Four things, in that order, each supported by something the reader can check.
Anything that does not go to one of those four belongs in an appendix or nowhere.
The opening summary
One page: the sections if any, the events relied on, the extension sought for each, and the contractual provision for each.
An assessor who can see the shape of the claim in a minute reads the rest differently from one who cannot.
It is also the page that gets circulated internally on the other side, which is a practical reason to write it carefully.
The contractual basis
The clause relied on, quoted, with the amendments as they actually read rather than as the standard form reads.
The notice provisions and what was served, with dates and references.
This section is short and it is the one that decides whether the rest gets read on its merits.
The programme position
Which programme was in use, its status under the contract, and what it showed as governing completion.
The updates relied on, dated, so the position at each event is established.
Where the programme is weak, say so here rather than letting the reader discover it in the analysis.
The events
One page each, in the same format: what it was, when it arose, which activity it affected, what happened to that activity, and the delay that followed.
Documents referenced rather than reproduced, so the page stays readable.
Largest first. On most projects a handful of events account for most of the delay, and the small ones can be grouped or dropped.
The analysis
The method, stated plainly, with its limitations acknowledged in a sentence.
The result by period or by window, shown on something the reader can look at rather than described in prose.
A method that matches the records available, rather than the method that would be ideal, is the one that gets accepted.
Dealing with the contractor’s own delays
Identify them, say what they affected, and exclude the periods attributable to them.
A claim that does this is read as prepared. One that ignores delays the records plainly show is read as advocacy.
It also removes the other side’s best opening, which is worth more than the periods conceded.
The money, or its absence
Say whether loss and expense is claimed, and if so that it travels its own route and is dealt with separately.
A combined submission that merges time and money under traditional forms frequently fails on both.
Under NEC the position is the opposite, and the two belong together in the quotation.
What to leave out
Narrative history of the project, which establishes nothing and consumes the reader’s attention.
Complaint about conduct, which has no place in an assessment and colours everything around it.
And every event the records will not support, which should be mentioned as background at most.
Length
A main document of twenty to thirty pages, with appendices carrying the volume, suits almost every project.
Longer documents are not read in full, which means the strongest points compete with the weakest for attention.
If the claim cannot be summarised in a page, it is usually not yet understood.
Before it goes in
Read it as the assessor will: can each of the four requirements be checked from what is in front of them?
Check the arithmetic, the dates and the cross references, because one error found by the other side is worth several pages of argument to them.
And confirm that nothing in it overstates what the records show, since that is the hardest thing to recover from.
What to expect back
A partial award, most of the time, which is a normal outcome rather than a failure of the submission.
Requests for particulars, which should be answered quickly and narrowly.
And where nothing comes back at all, a decision about whether the failure to assess is itself the dispute to pursue.
Writing it so it can be answered
A submission that can be answered point by point gets answered point by point, which is how a dispute narrows to the two or three issues that actually divide the parties.
One that cannot be answered in that way gets refused in general terms, and the parties then spend months establishing what the disagreement even is.
So the structure is not presentation. It is what determines whether the next six weeks are spent on the merits or on the paperwork.
Where it fits
Structure is the last step and it is worth as much as the analysis, because an unreadable claim does not get assessed.
Where the submission has to be defended or answered, the same structure is what makes initial dispute review quick on either side.
The records and notices it depends on come from ordinary cost control and variations administration while the project runs.
A claim that has to be assembled from scratch at the end is longer, weaker and considerably more expensive than one drawn from records kept as the work went along, which is the same conclusion every part of this subject arrives at.
It is also the one piece of advice that costs a client nothing to act on.
Running late with nobody agreeing why?
Extension of time claim preparation sets out the events relied on, their effect on the programme and the contractual route to relief, in a form that can be assessed rather than argued over.