MEP scope disputes are rising on ICI projects. The operators Provision interviewed for The Scope Gap Playbook flagged plumbing as a repeat offender — not because plumbing is complicated, but because Division 22 scope packages routinely inherit the same three problems: the trench is ambiguous, motor starters fall through the cracks, and rough-in locations are drawn in two places that don't agree.
Each of those gaps costs money. Together, they can turn a competitive plumbing bid into a change order machine.
This article walks through the Division 22 scope gaps that show up most often in GC bid packages — and what it takes to close them before bid day.
Plumbing bids look clean on the surface. A sub returns a number, the GC levels it, and the package moves forward. The problem is what's not in that number.
Construction disputes in North America averaged $60.1 million per claim in 2024, according to the Arcadis Global Construction Disputes Report. Errors and omissions in contract documents have repeatedly ranked as the top dispute cause in North America across Arcadis's tracking period. Division 22 scope gaps fit that category exactly — they aren't field errors. They're document failures.
The pattern is predictable. A plumbing scope sheet says "install per plans and specs." The sub prices what they see. The GC assumes the sub priced everything. At buyout, nobody owns the trench. By framing, nobody owns the motor starters. At rough-in, the architectural ceiling height and the structural beam depth don't agree, and the sub wants a change order to reroute.
"If you miss anything, they'll bill it," said a Pre-Construction Lead at a Top-ENR Canadian GC. That's the reality of plumbing buyout in 2026.
Underground plumbing work requires excavation. That's obvious. What's not obvious — without a scope package that says so explicitly — is who does each part of the trench sequence.
The Scope Gap Playbook documents a $45,000 discrepancy on a single slab from a depth mismatch between civil/structural and architectural drawings. Underground plumbing generates the same conflict — civil grading elevations and architectural slab finish don't always agree on invert depth, and the plumber prices to one set while field conditions match the other.
The fix is to specify trench scope line by line: excavation, shoring (if required), bedding material and supplier, backfill material and compaction standard, spoil disposal, and surface restoration. If you're using Scope Agent to generate your Division 22 package, it cross-references the drawings and specs to flag where trench responsibility is unassigned.
Every plumbing system that uses a pump, a booster, or an ejector has a motor. Every motor needs a starter. And on most ICI projects, that starter is sitting in the gap between the mechanical spec and the electrical spec — owned by nobody.
Division 22 specifies the plumbing equipment. Division 26 specifies the electrical distribution. The motor starter sits at the intersection. The mechanical engineer often assumes the electrical scope includes it. The electrical engineer assumes the mechanical scope includes it. The specs may not say either way.
This is not a hypothetical. Operators interviewed for the Scope Gap Playbook specifically flagged generator field-conditioning costs and motor starters as recurring MEP orphans — items that appear in neither the mechanical nor the electrical bid because each sub assumed the other had it.
Check Division 22 Section 220500 (Common Work Results for Plumbing) and Division 26 Section 260500 (Common Work Results for Electrical). Look for these specific callouts:
If the spec is silent, the scope package must assign it explicitly. Left unresolved, both subs exclude it. You find out at rough-in.
The Risk Review tool reads the full spec set and flags clauses like this with a citation to the exact section — so your team isn't reading two divisions in parallel trying to reconcile what each says.
Rough-in conflicts are where plumbing scope gaps become field problems. By the time the discrepancy surfaces, walls are framed, sleeves are set, and the sub wants a change order to move work that shouldn't have been installed where it was.
The plumbing sub prices to the plumbing drawings. When the structural beam reduces the available plenum by eight inches, the pipe route changes. When the partition relocates between schematic and permit set, the rough-in location is wrong. Neither of those changes shows up in the original bid number.
The most common scope-writing anti-pattern in Division 22 packages is "install per plans and specs." It sounds complete. It isn't. It tells the sub nothing about which drawing controls when they conflict, who coordinates with other trades in the plenum, and what tolerance is acceptable on rough-in dimensions.
"As per plans and specs" was the most-cited anti-pattern in operator interviews for the Scope Gap Playbook. It's a liability statement dressed up as a scope description.
A Pre-Construction Lead at a Top-ENR Canadian GC put it plainly: "It's descriptive — bread, put it on a plate, use the open jar… You have to get to that level of detail or else they'll just be like, 'you didn't tell us that.'"
Instead of "install per plans and specs," a Division 22 scope package should include:
This level of specificity doesn't add scope — it closes ambiguity. Subs who see it know you've read the drawings. Subs who see "per plans and specs" know you haven't.
The trench, motor starters, and rough-in conflicts are the top three. But Division 22 buyout surfaces several other recurring gaps that estimators should check before scope issuance.
Domestic water insulation and drain insulation are sometimes specified in Division 22, sometimes in Division 23, and sometimes split between them. If the scope package doesn't assign it, neither sub prices it.
Who furnishes and installs pipe sleeves through concrete? Who pays for core drilling after the slab pours? These are small dollar items individually. Across a multi-floor ICI project, they add up. And if the concrete sub is gone by the time the plumber needs the core drill, the GC is paying out-of-pocket.
Mechanical rooms with high pipe density generate hanger conflicts between trades. The plumbing sub assumes the scope covers standard hangers to the structural. Unistrut, trapeze assemblies, and seismic bracing are sometimes priced separately — or not at all.
Division 22 specs require pressure testing before concealment. But who attends the inspection? Who pays for re-tests on failed sections? Who provides the documentation? If the scope package is silent, the sub's assumption and yours may not match.
On projects with owner-furnished equipment (OFE), plumbing fixtures are sometimes owner-supplied and contractor-installed. If the scope package doesn't confirm the split, the plumbing sub prices fixtures they won't supply — or excludes the installation of fixtures they're expected to set.
The Scope Gap Playbook identifies eight habits that separate high-margin GCs from the ones fighting change orders. Three of them apply directly to Division 22.
Build the Division 22 scope from the actual drawing set — not from a previous hospital or office scope you ran last year. Plumbing layouts differ. What's in the plenum differs. The trench depth differs. A boilerplate scope misses project-specific gaps every time.
The motor starter problem is solvable before bid day if you call the MEP subs and ask: "What are you excluding?" Most subs will tell you. That conversation at bid is $10,000. That conversation at buyout is a change order. That conversation at rough-in is a dispute.
Before the Division 22 package goes to subs, run a review against the spec sections and drawing set. Look specifically for MEP orphans — items that live at the boundary of two trade scopes. Motor starters, control wiring, test and balance, and sleeve installation all live in those boundaries.
"If we could catch three scope gaps or three missed items on every scope of work, then this thing pays for itself," said a Senior PM at a Toronto mid-market developer. For Division 22 on a mid-size ICI project, three gaps easily represents $50,000–$150,000 in change order exposure.
Generating a complete Division 22 scope package manually takes time most estimating teams don't have — especially when you're running three pursuits at once. The typical alternative is pulling from a previous job and hoping it's close enough. It usually isn't.
Scope Agent reads the full project set — drawings, specs, and contracts together — and generates a trade-by-trade scope package in under 60 minutes. For Division 22, that means the trench responsibility, motor starter assignments, and rough-in coordination requirements are surfaced from the actual documents, not inferred from a boilerplate.
Every item in the output is cited to the source: the drawing sheet, the spec section, the page number. When a sub pushes back on scope, your team has the citation. That's the difference between a clarification and a change order.
Risk Review runs a parallel check on the contract and spec language — flagging the clauses that create "readily inferable" exposure, undefined MEP boundaries, and missing test-and-inspection requirements. Provision has reviewed over $100 billion in project value and processed more than 100,000 documents. The accuracy benchmark on pre-built checklists is 99%.
For teams managing multiple Division 22 packages across concurrent bids, Chat Agent lets estimators query the full project set conversationally. "Who installs the motor starters for the domestic booster pump?" returns a cited answer in under 20 seconds — without reading two spec divisions to find out.
You can see how these tools work on a real plumbing scope package. Book a demo and bring a set you're working on now.
The three most common are trench ownership (who excavates, backfills, and disposes), motor starters orphaned between Division 22 and Division 26, and rough-in conflicts between architectural, structural, and mechanical drawings. Each generates change orders that could have been caught at bid with specific scope language.
It depends on what the scope package says — which is the problem. Without explicit assignment, the site contractor and the plumbing sub each assume the other owns some part of the trench sequence. Excavation, backfill, compaction, and spoil disposal should each be assigned by name in the Division 22 scope package.
Motor starters for plumbing equipment sit at the boundary of Division 22 and Division 26. Mechanical engineers often assume electrical scope includes them. Electrical engineers often assume mechanical scope includes them. If neither spec section assigns them explicitly, both subs exclude them and neither prices them.
In practice, it means the sub prices what they choose to read from the drawings and interprets ambiguities in their favor. It's the most common Division 22 scope anti-pattern because it sounds complete while leaving coordination responsibilities, trench sequencing, and MEP boundary items entirely unresolved.
When architectural ceiling heights, structural beam depths, and mechanical routing all conflict in the plenum, the plumbing sub installed work to one drawing set while field conditions match another. By the time it's discovered, walls may be framed and sleeves set — making the reroute a change order rather than a coordination issue.
Division 22 is the MasterFormat specification section for plumbing systems. It covers domestic water, sanitary drainage, storm drainage, plumbing fixtures, equipment connections, and related systems. On ICI projects, Division 22 scope packages define what the plumbing subcontractor is responsible for — and where that scope starts and stops relative to other trades.
Three practices reduce Division 22 change orders: building scope packages from the actual drawing set rather than boilerplate, assigning MEP orphans (motor starters, sleeves, insulation) explicitly in the scope language, and running a pre-issue scope review against the spec and drawings before the package goes to subs.
Scope Agent reads your full plumbing spec and drawing set, then flags every unassigned item by trade.
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