The Essential Elements of a Successful Claim - Construction Claims and Responses: Effective Writing and Presentation - page 64

f. House No. 46 - precast concrete fl ooring complete, blockwork
to fi rst-fl oor external walls and partitions was due to start on 1
February 2010.
3. Progress to the affected dwellings was dependent on the delivery of
ready-mixed concrete, concrete blocks, cement, sand and precast
concrete fl ooring beams and other materials to the working areas.
No other access route for such vehicles was available due to other
activities and completed construction works in this area of the site.
The effect of the excavation of the road crossing by the infrastruc-
ture contractor was to prevent deliveries from being made between
the dates of 1 and 9 February 2010 and, consequently, to suspend
the construction activities until 10 February 2010, the day after the
access was reinstated.
Now let us look at this section again to see how the use of drawings
and photographs, made and recorded specifi cally with respect to the claim
event, may be used to provide substantiation.
The Effect
1. Appendix B contains a site plan which has been marked up to show
the location of the road crossing. The plan also shows that alterna-
tive access to the dwellings in question was not possible, due to the
location of existing boundary walls and other completed works. The
photographs contained in Appendix A also demonstrate that the
works shown on the site plan had already been constructed at the
time in question. Thus, the road crossing restricted the Contractor's
access to the six dwellings by preventing vehicles from reaching the
houses to deliver the construction materials necessary for progress
to be maintained.
2. The infrastructure contactor commenced excavation of the road
crossing on 1 February 2010, which effectively restricted access
from this day. The Daily Site Report of 1 February 2010 3 and the
photographs included in Appendix A herein record that the progress
of the individual dwellings was as follows:
a. House No. 36 - reinforcement to the raft foundation was in
progress and due to be completed on 2 February 2010.
3 Exhibit 3 - Daily Site Report, dated 01/02/10