811 in Crisis: Study Shows Failures in Utility Locating System Cost $61 Billion Annually
A recent study has found that failures in the 811 one-call system used in the United States to prevent damage to underground utility lines are costing $61 billion per year in waste and excess costs.
The result of this waste is the creation of unnecessary hazards for public safety, particularly in states where the implementation and accountability are most lax. These findings were reported in an independent review, titled “811 Emergency,” conducted by Continuum Capital.
The report includes an in-depth examination of 811 operations in every state and Washington, D.C., and shows 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.
The review was commissioned by the Infrastructure Protection Coalition, a group of associations representing broadband, electric, natural gas, pipeline, transportation, sewer and water industries, and the stakeholders 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. Members of the coalition include the American Pipeline Contractors Association (APCA); Distribution Contractors Association (DCA); National Utility Contractors Association (NUCA); Nulca — representing utility locating professionals; and the Power & Communications Contractors Association (PCCA).
Originally released on Nov. 17, 2021, the study was conducted using a painstaking review of records, regulations, laws and enforcement actions in every state. An update to the report is set to be published this summer.
“Ultimately, ratepayers are picking up the tab for this waste and bearing the public safety risk,” says Tim Wagner, a coalition member and executive director of APCA. “Some states have figured out how to work this system safely and efficiently, and there’s no reason others cannot do the same.”
A handful of states — Arkansas, Florida, Georgia, Michigan, Missouri, Wisconsin and the District of Columbia — account for more than 20 percent of the national waste, for an estimated $13 billion, because of 811 policies that lack serious consequences and, in some cases, do not require mandatory reporting of damage to utility lines, the study showed.
The review found waste and cost overruns largely were caused by: utilities and third-party locators needlessly sent out to locate lines for construction projects that then do not happen; poor instructions given to locators, causing wasted time or additional work; locate marks destroyed by construction and then needing to be reinstalled; and contractor wait time when location efforts exceed the legal notice period.
A Correlation and Solution
One possible solution for the waste and excess costs is wider adoption of subsurface utility engineering (SUE) practices, says Nicholas Zembillas, CEO of Subsurface Utility Engineering LLC, who has more than 40 years of combined experience in Federal Highway Administration (FHWA) and Department of Transportation (DOT) utility policy and utility accommodation, and subsurface utility engineering. Zembillas has been involved with the introduction and development of the SUE practice and SUE standard of care in seven different countries.
When Zembillas reviewed the study’s findings, he discovered an analogy between the better performing states and the use of SUE.
“When I read the report, I found it to be right on the 811 findings,” he says. “Concerning utility strikes, when the report broke it down by state and it identified 811 stakeholder’s view on high and low performing state 811 systems, what caught my attention was a correlation with the study findings and my knowledge of the states that have a successful evolving history with SUE in accordance with ASCE 38. These high performing states have a developed diverse market that is applying SUE to the planning, design and construction project delivery phases.”
Zembillas explains that SUE applies civil engineering, geophysics, survey and mapping, and the use of geospatial and geotechnical technologies. The SUE project delivery process, when following ASCE 38, produces accurate and comprehensive underground utilities mapping and data deliverables — and thus more successful — projects from design through construction. SUE employs the applicable suite of surface geophysical technologies and the fullest extent of applying the best practice techniques to achieve maximum detection, collection and depiction of utilities. Also, SUE is given an adequate time schedule to produce the SUE deliverables for project design.
811, a “Call Before You Dig” program, is being used to provide utility location information for the use on engineering and designer drawings, he says. This practice of using 811 was not meant to be a “Call Before You Design” program.
“The way we’re going to fix this problem, is not all on 811,” Zembillas says. “The 811 program is a ‘Call before You Dig’ program for construction. Each state has established 811 guidelines and horizontal tolerance requirements.” He adds that those approximate horizontal tolerances are not adequate for design and should not be used on construction projects involving construction and subsurface excavation.
“It is going to take all stakeholders to apply the appropriate best practices and the standard of care in project designs that assure reliable, accurate and comprehended utility deliverables,” Zembillas says. “All local governments, utility owners, engineers and designers need to understand there is a standard of care for SUE since 2002, and they should know of it and apply SUE per ASCE 38 accordingly to its fullest extent.”
While more than 40 states and federal government agencies recommend, require and fund for the use of SUE, Zembillas explains that nationwide many local government agencies and private utility owners have been slower to embrace and adopt the standard of care. He says that construction industry organizations, such as American General Contractors (AGC) and NUCA have consistently voiced their strong concerns with the lack of reliable utility information with project owner design and bid documentation for construction. Their long history of endorsing the use SUE appears to be falling on deaf ears.
“Most state transportation agencies have some degree of a SUE program,” he says. “I saw that the states that achieved better 811 results were also states that have a mature and relatively successful SUE program.”
Zembillas says very few utility construction projects apply SUE, and believes the reasons for its lack of use start with the project owner. Some of the reasons can be attributed to the following:
- Project owner lack the knowledge of SUE and the ASCE 38 standard.
- Project owner knows of SUE/ASCE 38 and chooses not to use it.
- Project owner sees SUE as an added cost and chooses not to use it.
“The current process being use for design is not good,” Zembillas says. “They’re relying on a mark that is intended to be approximate and for the use for construction. Approximate is not good enough for engineering and design.”
Fixing the Situation
The 811 study comes at a critical time for U.S. infrastructure, with the passage of the Infrastructure Investment and Jobs Act in November. The bill commits $1 trillion for new projects, including energy, highway, bridge, road, broadband and water and sewer infrastructure construction, all of which will be near existing underground utilities.
“We originally commissioned the study to find what’s broken in the system, because there were a lot of problems that were making excavation dangerous,” Wagner says. “One of the findings was the huge amount of inefficiency, contributing to $61 billion in waste. When you look at what that means with the new infrastructure bill, if the 811 system were fixed, we could build a lot more infrastructure.”
Anyone who is involved with excavation is affected by this study, Wagner says. However, the Infrastructure Protection Coalition isn’t interested in pointing fingers, but rather finding solutions.
“We’re not singling out any one stakeholder,” he says. “It’s a shared responsibility.”
Wagner adds that fixing the problems with 811 will take a joint effort.
“When we brought to light the flaws in the 811 system, we found that the flaws were multi-tiered,” Wagner says. “There are flaws in the process and flaws in the law, so it’s going to take a combination of things to fix it. The reason we got involved in the study is because the system is badly broken. This time last year, we had tens of thousands of unfulfilled locate tickets. The companies found in some cases that it was less expensive to pay the fine than it was to do the locate.”
Now that results of the study have been published, Wagner says all of the stakeholders involved have to continue sharing the information and seeking support to fix the problem.
“The big thing is we have to go out and present the study,” he says. “In the poor performing states listed in the study, we need champions who will help fix the laws or improve the processes. That’s the only thing we can do. We don’t want to just point out the flaws, we want to effect change.”
Wagner notes that there were some people who were upset about the report.
“They don’t want to be told that their kid is ugly, but they’re not paying attention to the fact that we’re saying our own kid is ugly too,” he says. “There are a lot of reasons why a utility is damaged. We just want to make sure less of that happens.”
In the process of putting together the report, which encompassed all 50 states and involved thousands of interviews during the course of a year and a half to complete, Wagner admits that there were a few errors, though not in the material itself. The coalition is correcting the inaccuracies with the republished report.
“The important message here is that this is an imminently fixable situation,” Wagner says. “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.”
May June 2022 Print Issue
Bradley Kramer is managing editor of North American Energy Pipelines. Contact him at firstname.lastname@example.org.
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