The Differences Between the Levels of Service: 811, Private Locate, and SUE
When embarking on an excavation is calling 811 enough? Should you hire a private locator… and is that enough? Or do you need a fullSubsurface Utility Engineering (SUE) report, sealed and signed by an engineer?
The answer is… it depends. On the needs of the client, for one, but also other factors.
In this roundtable discussion, industry experts discuss the differences between these different subsurface investigations, the limitations of each, how the lines are “blurring” between, and more.
One thing is for certain, in many cases that “one call” to 811 is often not enough.
Roundtable Members:
Adam Yunker, GPRS, Inc., Sales Director – Eastern U.S.
Matt Dragon, Proceq, Head of Product Marketing
Greg Jeffries, National SUE Discipline Leader, Colliers Engineering
Simon Pedley, Leica Geosystems, Hexagon Detection Sales Manager
Matt Dragon:
The industry has been evolving for the last couple of years. Today, you have more and more private utility locators not just going out and putting paint on the ground. They’re embracing more technology. They’re actually producing maps. And then also, at the Subsurface Utility Engineering (SUE) level, these contractors are not necessarily providing a SUE package every time. They’re maybe producing a map, but it isn’t an official SUE product that they’re giving their client.
If there’s a line in all the services from all the different types of providers, I think is starting to get blurred a lot.
Greg Jeffries:
When looking at this issue, I think you have to understand what the client wants. What do they need in order to proceed with their project? In a lot of cases, perhaps they only need what I would call a private locate. They don’t need an actual engineer report. They don’t need a CAD drawing. They don’t need the site to be surveyed. They’re just basically looking for paint on the ground is what it boils down to.
We do perform those type of services as the client dictates. However, the new standard [LH1] that’s about to be issued very clearly states that locates that are performed by outside services, in other words by private locators, if they are brought into that engineering design, they can never be considered no better than quality level D, which is defined as information derived from existing records or oral recollections.
Even if they were surveyed in or what have you, they cannot be considered anything more than quality level D because that work needs to be performed under the direction and the guidance of the engineer that’s signing and sealing that report. And if they’re not direct employees of that engineer, then they’re not under that direction.
Matt:
I’d be interested to know your opinion on this. Do you think that there should be some sort of specifications, some sort of a clean break between the private locator and the SUE provider? Should there be another standard for the private locator? Because right now, if all of the sudden I want to buy a truck and the equipment, I could go out and call myself a private locator and there’s nobody policing my quality other than the industry and my clients.
Greg:
I think that’s really market driven, market condition. It’s the client. What are they demanding? What are they requesting? What do they require? I think it’s contingent on them to understand what it is that they need as a deliverable. What’s the end result that they have to get to? And then how do they get there?
There are certainly many instances where we don’t provide any sort of signed and sealed document to a client because they made the determination that they did not need that to get where they needed to go. On the other hand though, there are many instances where we are providing signed and sealed documents because they need that information and they need to have somebody certifying the pedigree of the data that they’re receiving.
Simon Pedley:
I suppose it goes back to what you said though about a two-tier system, who’s accountable for those private locates. Are these providers actually advising their customers correctly? They may not want to give up the work. So they might tell that potential client that all they need is a private locate when they actually need the details and information from a SUE firm. They may not be quality checking anything, but they’re saying well, we can hook a GPS up and give you a GPS map.
Greg:
There are some issues with that too, because in a lot of states if you do that, you’re surveying without a license. There are some other implications that you could run into in those regards.
Adam Yunker:
And if that doesn’t trip them up, it goes back to market driven. If you promise falsely to that client, whether it’s that you don’t have the experience to know what you’re doing or whether you’re claiming you’re at a certain level that you’re not… if there is no legal issue there, they’re probably still not getting any call back at a later date from that client.
Adam Yunker, GPRS, Inc., Sales Director – Eastern U.S.
So yes, I think there could be an advantage to having a standard at some point. I think it’s something the industry will probably push for eventually. But right now, it’s totally market driven.
Greg:
I think there’s a place for both sides of that equation. Just because we produce a map that we have signed and sealed, we’ve indicated its accuracy by assigning a pedigree to the information that’s on that map. Does a directional driller still need to have private locate work done? Do they still need to do a pothole to visually lay eyes on where that utility is before they cross it? Yes.
And most of the time, in fact there are many scopes and specifications that require the directional drillers to expose the facilities. Even though we may have gone out and provided that map and indicated at least up through quality level B where that facility is, they still, by their scope, have to expose it.
Matt:
The problem is that there’s still a large population of excavation-type practices that will call 811, which is the right thing to do, and then they leave it at that. They think they’ve done their legal responsibility, their due diligence. And that’s where it stops. And I would bet even a poor private utility locate would be better a lot of times than stopping at 811.
So, you have 811, which is highly defined what their best practices are for each one of those guys that goes out and does that work. And then you’ve got SUE. And then you’ve got this wild wild west in the middle where you can’t really ensure that anybody’s actually doing the right thing, using the right technologies.
And then if you look at regular specifications by large contractors, there’s a deficit in education there where they’re just saying locate all underground utilities before excavation. So that’s incredibly broad.
Matt:
And how do you interpret that? Depends on who you are and how you want to operate your excavation company or directional drilling. And-
Greg:
What level of risk are you willing to accept?
Matt:
Exactly. Right.
Greg:
I definitely agree with that analysis. There is a huge void potentially in there. 811 is by statue the legal requirement. And really the only reason that a lot of companies follow it is because legally they’re required to. If there wasn’t some statue backing it up, they wouldn’t even call 811.
Matt:
But I would bet most of the hits you see in the industry happen because somebody decided to stop the investigation.
Matt:
Somebody said we’re good enough for here. There’s probably more of it just after 811, and they said, “Well, we did our thing. We’ve got to get going. We have to start digging. We know we’re going to hit stuff and we accept that.” I hear that sometimes too from people.
Greg:
To me, the question, is how many 811 locators do you ever see with a ground penetrating radar (GPR) unit?
Matt:
None.
Greg:
Precisely. And you look at the percentage of utility that’s in the ground that is non-detectable? And so you’ve got an 811 locator out there, and they are making their sweep with an electro-magnetic device. They have no benefit of any of the other technologies that are available. And they’re giving you that information that they’ve derived either from the technology they have. Or how many times have you seen that guy go out and not even pull out his device?
Adam:
And beyond that, I think the one key differentiator here is they’re out there to protect their one asset that they’re responsible to mark. We as private locators or SUE, however you want to define it, we’re there to protect the contractor, the asset, any other assets in the ground. We’re there to protect everything there. We don’t have plans, generally. Sometimes we do. We can get that ahead of time. But that’s what we’re there to do. So, you’re going to find a lot more in-depth investigations completed from this level of investigation. Because you’re there to protect your client and the asset at the same time.
Greg:
Certainly. I think from our standpoint, because we’re affixing a seal, because we’re putting professional licensure on the line and we’re backing it up with errors and omissions insurance and professional liability, that we have to do the amount of investigation necessary using the technologies that are available to us to provide the most comprehensive picture of what’s there in order to do those things. Protect the client, protect the public, and protect our licensure as well.
Jimmy LASTNAME (Moderator):
We call these 811 centers, or One Call centers. They were created mostly many decades ago. Is there a role for these One Call centers to be more of a call center with regards to private locating and SUE? In terms of if I call 811, the “One Call” center, maybe they have access to GIS data, maybe they have some other information. They notify me that I may have private facilities on my property that I also want to get located and here are a list of companies. Or, have automated bids from those companies or something, a clearinghouse of buyers and sellers of services. Is there a role for that as we go forward?
Greg:
I think there have been a couple of One Calls that have tried that so to speak. In fact, in Texas, we had Lone Star 811… before that went away. And they would hand out a list of private locators. And they mainly did that when folks were calling in a locate for an entire property if you will, like their house. We’re doing a swimming pool or whatever. And knowing that in a lot of cases, they were not going to get all the information that they were going to need. So, they would then also provide them with two or three names of private locating companies that could come out and give them that information. So, I think there is a role certainly that they could play.
Adam:
My understanding is that Michigan ran a pilot last year for something very similar. Automated system where either the locator or the asset owner, somebody would implicate that there are private utilities or underground utilities in this area where you’re going to be digging. And they would automatically alert the client, “Hey, there’s additional assets in the area. You’ll need to call one of these.” And it sent a list of service providers in the area to go out and locate those private utilities.
They ran a pilot. They found it successful. They’ve expanded that pilot program. There are several private locators that are part of that. We’re fortunate to be one of them. But something like that could be very impactful to the industry. Because a lot of times the contractors, they don’t know if there’s private assets in the area or abandoned assets in the area or unknown assets in the area.
Greg:
I don’t think the vast majority of homeowners realize that most likely if they have water and gas coming into their house, that that is their problem on their side of the meter.
Matt:
They don’t realize that at all.
Greg:
They don’t realize that in most cases, the water meter’s out at the curb and the gas meter is somewhere near the curb or maybe in the rear alley. But that service line from that meter into the house is the homeowner’s responsibility. In fact, even the sanitary sewer is. Everything that’s on the private side of the curb belongs to the homeowner. And they probably have no idea that that’s their responsibility.
Jimmy:
Well, also the name, One Call, may lull some callers into a false sense of security.
Greg:
Certainly.
Jimmy:
Like this is a One Call. I make this one call. Why do I need to make a second or third call?
Greg:
Agreed. There’s a little bit of a misnomer. Obviously, it was a good idea-
Jimmy:
Back then, 30 years ago.
Greg:
Sure. It was a good idea. But you’re right, there is a potential false sense of security thinking hey, I called 811. I’m good. I’m covered. And no, not necessarily.
Matt:
That really highlights if that’s the direction that things are going to go… that’s why private utility locators, they really need some guidelines or specification or something that they adhere to. Because how do you ensure that if One Call is going to get involved and refer someone to a private locator, how do you ensure that that’s going to be a quality locate?
Greg:
That’s a good point.
Adam:
We’ve got a specification that we follow on every project. It’s trained into them as soon as they come in and all through our process. I think it’s something we’d love the industry to grab onto. Curious from a SUE perspective, I know that engineering on the back end is really impactful to your product and output. But is the engineering only as good as the locator when you guys are out on job sites? And when you do have a SUE engineering project that you’re maybe doing a full level A product on, how do you guys get that consistent output to make sure that your output, the engineer stamp at the end, is solid?
Greg:
A lot of that has to do with our QAQC, our quality assurance quality control program. True, in some regards that yes, the locate is only as good as the designator, we call it designating.
The designation is only as good as the designator that was out there performing the service. But at that point, we also have multiple layers that we look at. We’re not just expecting one guy to go out there and handle this thing from soup to nuts, and the engineer in the office to blindly accept that information.
The way that our process works is that we are going to try and obtain all of the record data that we can get our hands on. And we’re going to take that record data and basically compare that with the information that we derive from the field designations. We’re going to look at that data objectively and make some determinations as to whether or not it makes sense.
And then at the same time, we typically set aside about 20% of the overall work to be QA. From that point, we will send a third person, a third designator or maybe a higher-level, supervisor-level person out there to spot check that information and confirm whether or not we have accuracy. We use some other proprietary tools internally, we do, to catalog the information that we collected so that we’re collecting information in multiple formats.
And then we can look at that information either in CAD or on software platforms even such as Google Earth or a GIS-type platform where we can overlay multiple pieces of information. We can look at the record data that we either received in a CAD or we converted it into CAD in some fashion. We receive field sketches that we can convert into a GIS shapefile. And then we can take the survey information that we’ve collected and convert that over to a shapefile. A
And we can lay them all on top of each other and we can start to make some value judgements as to whether or not we have the right information. And we can look at things that we may have missed in the process. It happens, and you have to go back out and do some subsequent data collection.
Matt:
How many of those utilities are potholed and confirmed?
Greg:
That’s a good point. It depends, again, on what the client is requesting. However, we do pothole some utilities in situations where we have questions as to what the validity is of what we’re seeing instrumentation wise. We’ll do a couple of test holes here and there on occasion to do some confirmation.
Matt:
But if it’s a SUE level A, it requires a certain amount of potholing, right? I mean that’s not every utility though.
Greg:
Right. Again, that’s determined by the client. There are some caveats like in the Colorado law. If you’re crossing a gravity facility, then you have to have a test hole at that crossing. And that may be client-dependent as well. They’re going to say “Okay, every time we cross a gravity type facility, we need to know specifics as to the elevation of that facility.” And mainly because gravity utilities you can’t shift.
Matt:
You can.
Greg:
Well… if you were willing to accept the clogging and the other things. On the other type utilities, a phone line for instance, not that it’s not worth knowing exactly where it is, but the idea is that if you found it you might be able to deflect it a certain amount in order to get your installation past that. It depends.
Matt:
It’s almost like there should be a modified law out there where if you’re going to do this type of work around critical structures like a hospital or a public facility whether it’s high school, whatever, that that level of investigation is done because of that. Because I even recall a couple of years ago there was a directional driller that wanted to save $1,800, a day’s worth of work. And they went ahead and they did it and they didn’t do the private locate. And they destroyed the communication lines in and out of the hospital. I mean that was a really bad day.
Greg:
That’s actually a good point. Critical infrastructure like that, I think there should be a higher level of attention paid to that. How to go about that, I’m not sure, but certainly is worth the conversation.
Matt:
Wastewater treatment facility, water purification facility, anything that serves…
Adam:
Power generation.
Matt:
… the public interest.
Greg:
I think one of the other interesting things is that in a lot of 811 jurisdictions if you will, the water and sewer entities are not required to be members of 811. In Texas for instance, those municipal providers are not required to be members of 811. Only franchise utilities are required to be. There is a possibility that you could call 811 and not get all the information that you need.
Matt:
I think we have a question down there.
Jemmie Wang (Moderator):
Again, SUE is more on the data side than field marking and it’s already a disciplined approach in accordance with the ASE38. But when it comes to the data, sharing of data importing to a system, do you see any resistance from the clients to share the data that you already collected? Can that be used for future references?
Greg:
So if you have a database, so to speak, of information that you’ve already collected, can you then utilize that another project or another entity? Yes, however that information becomes stale very quickly. And that information could only be looked at as record information going forward. In other words, if we did a SUE project all the way up through quality level B on a given stretch of road for instance, and the following year somebody called us and they said, “Hey, we know you did quality level B out here. Can you just give us that and certify it as quality level B?”
We could not be able to do that. We would follow the ASCE38 guideline which said that that’s now quality level D information, and we would have to go out and prove the validity of that information again.
Infrastructure changes so quickly. On any given day how many miles of new fiber optic cable is going in?
Adam:
We’ve done a locate. We collect all our data via global navigation satellite system (GNSS), save that data in a map. We can provide that to the client. We’re generally working on construction sites that are abutting right of ways. You’ve got conflicting private and public assets all over the place. They might have ran a new utility the night before and a different contractor calls us.
We can’t just send them the map and say, “Hey, here’s what we found.” Because the same exact thing. They might have reinstalled a new asset the day before. And it happens all the time. People don’t communicate on job sites even. There are so many moving parts. You’ll hit a line that somebody just put in the day before. Certainly it can be helpful, but certainly would not excavate or design around former information.
Jimmy:
I think one of our audience members has a question. Please come up and state your name and company please.
Fred LeSage (audience member):
Fred LeSage with AXA XL Insurance. We talk about these vital facilities throughout the mapping, whether it’s a telecommunication line to a hospital, a gas line, a private electric line, some other vital facility. Isn’t the real issue that the owners don’t know where their stuff is? And shouldn’t we just require utility owners to at least know where they’ve put these vital pieces of facility that are vital to the entire community? Why isn’t that the way we solve this?
Greg:
It is a good question. And I think that boils down to again, that there needs to be a legislative mandate in order for that to occur. The troubling aspect of that is like I talked about as-builts and we call them wish-builts. I think one of the big deals with that is that most of the infrastructure as its built by a contractor, I’m not throwing contractors under the bus in any way, but they are not generally speaking operating with the idea that they need to provide hyper accurate information back to the owner of that asset at some point in time.
A lot of times you’ll just see them basically mark on the plans other than some elevation changes or if they had to offset it to go around something. In other words, we installed it per plan. I think at that point, it’s very difficult for the owner to go back and understand exactly where those facilities are based on that information.
Matt:
It’s difficult, but I mean …
Greg:
It’s not impossible. No, no. I’m saying it’s very difficult.
Matt:
You have the new things like PointMan and some of the other things that are out there that capture this data. And they did that in Colorado.
Greg:
Still do it. We have a number of folks that do PointMan collection every day for Colorado DOT.
Matt:
So eventually …
Greg:
Right. The interesting thing is that where it’s in Colorado DOT’s right of way, they will have information on what’s in their right of way. But the other cities, what are they going to have? I mean, they’re not going to have that level of information.
Adam:
The question comes in too, say you do require that… What do you do when a contractor, and we deal with this all the time, a contractor gets a note from the city or asset owner, whoever it might be: “Hey, we know we have a water line here. We don’t know where it’s at. Dig at your own risk.” And they still have a job to do, but how do you take into account what that risk level is?
If we did have some sort of enforcement or some sort of requirement to the gentleman’s point, that would help. But at the same time, we still are going to have a conflict there. How do we solve that problem, because there’s a lot of assets that we don’t know where they’re at.
Greg:
There’s so many in service and abandoned assets. I can only imagine the number of abandoned assets. Certainly we come across abandoned assets all the time. Things that were abandoned in place in favor of the new improved facility right next to it or on the opposite side of the street or whatever.
Matt:
And you have to treat that as a working facility until you confirm that it is an abandoned.
Greg:
Right. And I mean, I’m sure you’ve probably been there. Even if the city’s own guy comes out and they’re standing there scratching their head, “I don’t know. Go ahead and cut it. Let’s see if it leaks.”
[LH1]Where is this is new standard issued?