About the author:
Michael Ancell is Vice President of Innovative Association Solutions LLC. Ancell can be reached at [email protected].
Failures in the nation’s 811 system used to prevent damage to underground utility lines are costing $61 billion a year in waste and excess costs in addition to creating unnecessary hazards for public safety.
These issues are particularly notable in states where the implementation and accountability are most lax, according to a recently released independent review. The new study, "811 Emergency," includes an in-depth examination of 811 operations in every state, Washington, D.C., and Chicago and shows that these costs and the increased risk to public safety could be substantially reduced if states with the worst records adopt more effective practices and procedures already in use in other parts of the country.
About the 811 Emergency Study
The review was commissioned by the Infrastructure Protection Coalition (www.ipcweb.org), a group of associations representing broadband, electric, natural gas, oil, sewer, transportation, and water industries who design, construct, maintain, or locate these underground systems with both union and non-union workforces. These are regular users and stakeholders of the 811 system who want to see it run safely and efficiently.
Often viewed as adversaries in the damage prevention process, it is significant that groups representing excavators and locators joined together and were driving forces behind this study.
"These stakeholders usually fight among themselves and point fingers at each other when damage or waste is inflicted," said Mark Bridgers, architect of the research effort and principal of Continuum Capital. "The 13 recommendations from the 811 Emergency study are designed to cause all stakeholders to toe the line and work together to achieve the greater good."
The comprehensive study included more than 4,000 survey question responses from the four primary stakeholder groups (811 staff and regulators, utility/asset owners, excavators, and internal and third-party locators), nearly 500 stakeholder interviews from every state in the union, analysis of every state's dig law and changes in the law over the last three years, analysis of Pipeline and Hazardous Materials Safety Administration state assessments between 2014 and 2020, and calculation of waste and inefficiency present in each state and the resulting cost of this waste.
Separate reports were crafted for every state, Washington, D.C., and Chicago (Illinois law allows metropolitan areas exceeding 1 million in population to implement their own process separate from the statewide system). The national and state-specific reports provide an exhaustive, independent review of each state’s system and highlight specific areas where each state should focus for improvement. This can serve as a guide to regulators, legislators, and stakeholders as they seek to improve their 811 systems.
811 Emergency Study Findings
A handful of states — Arkansas, Florida, Georgia, Michigan, Missouri, Wisconsin, and the District of Columbia — account for more than 20% of the national waste (totally approximately $13 billion) because of 811 policies that lack teeth and, in some cases, do not require mandatory reporting of damage to utility lines, the study showed.
The primary reasons for the waste and cost overruns found in this study include:
- Utilities and third-party locators needlessly sent to locate lines for construction projects that then do not happen;
- Poor instructions given to locators, causing wasted time or additional work;
- Location marks being destroyed by construction and then requiring reinstallation; and
- Contractor wait time when location efforts exceed the legal notice period.
These costs amount to $61 billion in waste, inefficiency, and excess cost that is embedded in the system and largely invisible. This amount sits on top of the $30 billion in annual and out-of-pocket cost to the system calculated in 2019 by the Common Ground Alliance.
"Ultimately, ratepayers are picking up the tab for this waste and bearing the public safety risk. Some states have figured out how to work this system safely and efficiently, and there’s no reason others cannot do the same," said Tim Wagner, president and CEO of the Power & Communication Contractors Association, a coalition member.
This study comes at a critical time for the nation’s infrastructure. Pacific Gas & Electric has announced plans to underground 10,000 miles of power lines. Dominion Energy’s system reliability improvement efforts have undergrounded 1,500 miles of electric lines with thousands of miles remaining.
Lead pipe replacement for U.S. water systems is just beginning. Broadband systems are placing tens of thousands of miles of high-speed fiber optic cable underground for improved internet access. And the passage of the national infrastructure bill will result in tens of thousands of miles of highway, bridge, road, broadband, and water ans sewer infrastructure construction, all of which will be near existing underground utilities.
"A lot of excavation work is on the horizon," Wagner said. "The Emergency 811 study makes a compelling case for many states to improve their 811 programs and backs this up with sound data. "The important message here is that this is an imminently fixable situation. We can dramatically improve the system to improve public safety and cut waste with a combination of law, regulation, and process changes mirroring what the best performing states are already doing."
13 Recommendations From the Study
The study produced 13 recommendations that are applicable among several states, including:
- No exemptions. Require all asset owners and operators, including municipalities and departments of transportation to join and participate in the 811 system.
- Mandatory damage reporting. Refine the dig law to require reporting of all damages to all underground utility types to support effective data collection, process improvement, damage adjudication, and enforcement.
- Balanced enforcement. Cause enforcement authorities to weigh involvement of all primary participants in a damage, and in a fair and balanced fashion hold the asset owner, excavator, and locator appropriately responsible in the damage adjudication process.
- Third-party enforcement board. Develop or enhance the third-party investigation and enforcement board, with a balanced number of representatives from each stakeholder group, imbued with both responsibility and authority to manage the entire damage adjudication process.
- Standardize notification time. Standardize the ticket notification time to a minimum of two full business days after the day/date of a call.
- Effective penalty structure. Bring balance to the penalty structure or amount so that asset owners, excavators, and locators each face similar risks and responsibility.
- Effective metrics. Identify, develop, collect, and track metrics that effectively support trending and continuous improvement of the state damage prevention performance. Mandatory reporting is necessary to accomplish this effort.
- Annual reporting to Common Ground Alliance (CGA). Require state entities responsible for the oversight of the 811 system and collection and adjudication of compliance or damage reports, ticket volumes, etc., to submit data to the CGA’s annual DIRT (Damage Information Reporting Tool) Report.
- Positive response requirement. A web-based electronic positive response requirement by all asset owners/locators through the 811 system.
- Excavation site accurate description.
- Premark/White-line Requirement. Require pre-mark or white-lining of any proposed excavation area that includes traditional reference to intersecting streets/roadways paired with one or more of the following options: GPS coordinates, electronic white-line using aerial image(s), or physical white-lining.
- GIS system adoption by asset owners. By 2030, cause all asset owners to adopt a GIS system for asset mapping and require notification through 811 using GPS coordinates.
- Continuous improvement. Develop a culture of continuous improvement within the 811 system and more broadly through stakeholder education and public outreach programs.
- Standardize ticket size, distance, duration, and life.
- Educational resources. Develop and publish electronically an excavator’s manual that is updated and republished every five years or when an update to the law takes place, whichever is more frequent.