April 2026 Vol. 81 No. 4
Features
Inside Infrastructure: Utility locators warn of systemic failures in damage prevention process
By Eben M. Wyman, Wyman Associates
(UI) — While there are many issues to consider when it comes to utility construction, the main goal is clear and shared by all stakeholders involved in the process. Safety is paramount and protecting underground facilities prior to and during excavation is fundamental, especially when it comes to installing, maintaining and repairing underground facilities.
Excavation contractors put safety first and preventing damages to underground facilities during excavation activity is fundamental to their work. Contractor organizations have consistently supported policies that reflect shared responsibility among all stakeholders and promote four principal pillars of the damage prevention process:
- Full participation in the 811 process, including membership of all owners/operators of underground facilities to the state 811 center
- Accurate and timely locating of underground facilities
- Visually identifying (“potholing”) of underground facilities by excavators
- Full and balanced enforcement of state damage prevention law
The National Utility Locating Contractors Association (NULCA), which represents utility locating professionals across the United States, recently released a strong position paper describing the fundamental problems with the damage prevention process. In this courageous and hopefully impactful statement, NULCA centers on the increasingly urgent need for systemic reform within the damage prevention industry, highlighting the tragic consequences that arise from a system “designed to fail.”
NULCA underscores the cost of human life when the damage prevention system fails, pointing to a fatal incident in April of last year that resulted in the death of a five-year old boy in Lexington, Mo. According to NULCA, “a subcontractor had contacted 811 five days before breaking ground. Utility operators were notified. A locator was dispatched and marked the lines. Every box was checked. Every step of the process was followed. That evening, a drill struck a gas main that was never marked.”
Contractors, whether contract locators or excavators, are often blamed when things go wrong. The industry, NULCA argues, tends to focus on future goals without addressing the underlying problems that lead to repeated incidents.
NULCA’s clear call to action: the burden of these failures can no longer be silently accepted. NULCA asserts that the evidence – data and case studies – proves the current system continues to face the same problems it has for decades. Key stakeholders must choose whether they are committed to fixing the problem or simply protecting the status quo that perpetuates these challenges.
The position paper conveys a deep frustration of industry professionals with a system that has produced repeated, avoidable tragedies, and emphasizes that responsibility is unfairly placed on field technicians while systemic problems continue.
NULCA reports that locators mark sites exactly as operator records show, which sometimes end up on “the wrong side of the road. Crossing at the wrong block. Or not shown in the records at all.”
Among the main points in NULCA’s position paper are:
- Need for improved contracts – Locating contractors have accepted contracts that were economically impossible to carry out at the level of quality demanded by the job under tight timelines. Some utility locating firms “accepted contracts priced at levels that make quality training, adequate staffing and reasonable workloads economically unworkable, and then delivered predictably inconsistent results.”
- Importance of superior mapping – NULCA says it best: “Mapping must become a priority, not an afterthought. This is a foundational issue. There is no national standard for what a facility record must contain or how accurate it must be. There should be and the technology exists to produce superior mapping. A locator can only mark what can be accurately identified, and when the records are wrong, no amount of skill or training completely closes the gap. Utilities must be held to a standard of record accuracy that reflects the life-safety consequences of getting it wrong.”
- Over-notification – In 2025, the 811 system processed more than 43.5 million incoming locating requests, generating some 265 million transmissions to facility operators. In one case, a single excavator submitted a ticket covering more than 460 million square feet (over 8,000 football fields), with a statutory obligation to get the job done in, usually, two or three business days. According to NULCA, “[t]hat is not a ticket. That is an ambush.” NULCA also makes the point that when excavators are essentially ‘trained’ to over-notify because of a lack of trust that locating responsibilities will be met, that’s exactly what they will do.
- Workforce capacity and training – Recruiting and retaining qualified locating technicians is one of the hardest problems in this industry. Workforce capacity challenges continue, and this is not limited to the contract locating industry. We need more talent in the field in virtually all sectors of construction, including excavation contractors, locators and facility operators. In addition, NULCA concedes they “have not invested enough in training our people, and we have not demanded loudly enough that facility owners invest in the records our technicians depend on to do their jobs.”
- Board membership – Locating professionals should have seats at the table on One-Call boards. In most states, locators cannot vote on 811 board decisions. While One-Call boards have done a good job including more excavation contractors as voting members, there is certainly room for more utility locators who perform critical services and bring unique expertise to the table.
- Re-marking underground facilities – Where excavation is ongoing, “re-marking must be required, not optional.”
- Advance notice – Pointing to the ticket submitted covering more than 460 million square feet, NULCA maintains that more time must be required for locating services relating to large-scale projects.
The Common Ground Alliance (CGA), the leading damage prevention organization in North America, didn’t take long to weigh in.
"NULCA's new paper underscores the urgent need for all stakeholders – facility owners, excavators, locators and policymakers – to embrace their shared accountability to protect vital underground infrastructure," said Sarah Magruder Lyle, president and CEO of CGA and executive director of the Damage Prevention Action Center (DPAC).
"The Common Ground Alliance and the Damage Prevention Action Center are committed to facilitating the collaboration necessary to address systemic challenges, improve the efficiency and effectiveness of the 811 system and achieve our collective goal of significant damage reduction. This, however, requires all stakeholders to commit to addressing these issues."
CGA’s 2024 Damage Information Reporting Tool (DIRT) Report documented that marking accuracy failures and facility identification issues remain among the most persistent root causes of damages in this industry. Locating professionals have repeatedly described cases where marks were placed exactly where records indicated, only for excavation to reveal infrastructure in a completely different location.
This same report also indicated that excavators face significant challenges in starting their work on schedule. In fact, the DIRT report reveals that excavators have only a 50-percent chance of beginning their projects on time because facilities are often either unmarked or mismarked. This persistent issue leads to delays, increased project costs and heightened risks for all parties involved.
It took courage for NULCA to release this statement, and related construction associations should support the concepts described in NULCA’s statement. The underground infrastructure industry has made a lot of progress over the past couple of decades to improve the damage prevention process, but clearly there is much more to be done.
ABOUT THE AUTHOR: Eben Wyman is a veteran advocate for key underground utility and pipeline associations. He can be contacted at eben@wymanassociates.net.
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