DIRT Report

Late Locates: An Ongoing Challenge

To assess the state of locating in 2023, we analyzed 811 center data from states with varying requirements around positive response, including states with and without a positive response system. Across 12 states, reported data on the percentage of tickets where all locates were delivered on time ranged from 30-70%, with most hovering around 50%. Unpredictability contributes to excavators’ failure of confidence in the 811 system, and needs to be addressed – particularly in order to make progress on reducing the top damage root cause year after year: failure to notify 811.

New Mexico and Massachusetts’ Creative Approaches to Locating Enforcement

New Mexico’s damage prevention law has a unique enforcement mechanism for improving utility locating practices and reducing damages to underground facilities. The state's regulations require excavators to submit "warning locate requests" via New Mexico 811 (NM811) when underground facilities haven't been marked and positive responses haven't been provided. This process creates accountability and establishes a clear procedure for addressing delays in the locating process.

Under these regulations, facility operators are required to respond promptly to warning locate requests, ideally within two hours. NM811 is required to make positive response records available to the state’s Public Regulatory Commission’s Pipeline Safety Bureau (PSB) for investigating alleged violations. To ensure compliance, the New Mexico PSB began issuing fines to facility operators in 2020. These fines, set at a minimum of $811, are issued on a monthly basis.

The regulations also offer financial protection to excavators. In cases where facility owners fail to mark or provide a timely positive response, excavators can recover reasonable "downtime" costs. This provision safeguards excavators from undue financial burden and also serves as a powerful incentive for facility owners to complete locates promptly.

While the data to the right provides important information about the state’s efforts to improve locating timeliness, it does not give us a clear picture of excavation readiness in New Mexico over time.

However, the state’s multi-faceted approach, combining clear regulations, strict enforcement and ongoing education, could serve as a model for others looking for enforcement mechanisms for timely utility locating.

For another model of creative locating enforcement, we can look to a case study from the Massachusetts Department of Public Utilities (MA DPU) featured in CGA’s recently published DIRT Special Report: Uncovering Contributing Factors to Locating Practice Errors. The MA DPU’s Pipeline Safety Division, Damage Prevention Program (Division) oversees the enforcement of the state’s dig laws. While analyzing utility damage data, the Division identified two non-gas operators that were failing to complete locate markouts within the required timeframes. Further review revealed critical gaps in the locating and marking process, particularly including communication between the operators and third-party locators.

Rather than immediately impose significant financial penalties, the Division worked with the non-gas operators on an improvement plan, which included an increase of daily locate audits, an extended training program, additional staffing resources and improved frequency of reporting with other parties. As a result of the plan’s implementation, the Division has seen the rate of on-time locates improve to nearly 100% for the two operators. This example of collaborative problem-solving by regulators with facility operators to improve locating timeliness is a model that could be employed across the country to enforce locating timeliness.

Minnesota Leverages Locating Activity to Improve Facility Maps

In an effort to leverage high locating demand to improve facility maps and ultimately make locating more efficient, Gopher State One Call (GSOC), the 811 center serving Minnesota, launched an innovative pilot program to provide GPS-enabled utility locating devices to municipalities and other stakeholders. The program provides free trials of locating devices with real-time kinematic (RTK) Global Navigation Satellite System (GNSS) accuracy available to damage prevention stakeholders across the state, including municipalities, engineering/design firms, contractors, universities and facility owners.

The pilot enables field staff to seamlessly feed highly accurate facility location data back into mapping software, addressing the time and expense of updating legacy maps. By providing free trials of the GPS-enabled locators, the program has empowered participants to demonstrate the value of this technology and justify its implementation. Participants have reported significant improvements, including 50% reductions in field time for engineers and the ability for public works departments to produce more accurate maps while performing locates.

The success of this program highlights the potential for leveraging GPS data collected during the locating process to create and update facility maps in real-time. This approach can lead to improved locating efficiency, reduced damages and better asset management across the industry. CGA's Next Practices Initiative has published a detailed case study about this pilot program, which is available online.

North Carolina Leads Collaborative and Data-Driven Locating Analysis

North Carolina has emerged as a leader in collaborative and data-driven approaches to improve locating efficiency and safety. As documented in the DIRT Special Report on Locating Practice Errors, North Carolina 811 (NC811) conducted an in-depth analysis of ticket screening effects, focusing on "cleared" tickets that were later re-issued because the excavator found evidence of unmarked facilities at the work site. The study revealed that damages occurring after re-issuance had significantly higher percentages of locating practice-related root causes (45%) compared to the national average for all damages (with and without tickets).

Additionally, damage-per-ticket ratios were notably higher for re-issued tickets compared to overall damage data. While systemic issues like outdated facility maps, business practices and/or aggressive policies aimed at reducing workloads despite risks may contribute to improper screening, NC811’s findings identify screening as an issue needing further analysis and solutions from operators. As an industry, we must consider the impact that improper ticket screening can have on both damage rates and excavators’ confidence in the 811 system going forward.

Broadband deployments in the state have also benefited from NC811’s collaborative role in facilitating stakeholder coordination: Another case study from the DIRT Special Report on Locating Practice Errors details Google Fiber’s (GFiber) 39% decrease in locate-related project delays, with the largest improvements occurring in North Carolina, where several large-scale deployments are underway. This improved efficiency was gained by reducing short-notice locates and remarks, fostering increased trust and a safer work environment.

Upon conducting an end-to-end review of projects across 10 states, GFiber found that the greatest opportunity to minimize locate-related delays included early and improved coordination with locators for peer utilities; implementing enhancements that focused on providing rolling forecasts of buildouts and collecting ongoing feedback; and the inclusion of locate companies in preconstruction meetings.

Both case studies underscore the importance of data-informed, collaborative approaches to addressing our significant challenges with locating across the U.S.

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