Page 16 - Louisiana 811 Magazine 2022 Issue 3

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cost to the system. In addition to this observable cost is an invisible cost originating from the following:
1) daily unneeded locate requests;
2) daily locator wasted time due to poor instructions;
3) daily locator wasted Exhibit 2 State Overall Performance time due to destroyed marks; and
4) 5% in contractor wasted time waiting for asset owner compliance with locate request or taking “defensive excavation” practices at additional cost and lost productivity in an attempt to avoid unlocated facilities.
These costs amount to an additional $500 million in waste, inefficiency, and excess cost that is embedded in the system and largely invisible. Regardless of where or from whom these costs originate, they migrate over a 3-5-year timeline toward the most professional contractors and locators, and by default to their utility customers who are primarily the highly regulated electric and gas utilities and ultimately their ratepayers.
Once known and visible, these costs
can be eliminated and mitigated. The nine recommendations proposed, will eliminate $600 million of these damage and waste costs over a 3-5-year timeline and while there are implementation expenditures associated with these recommendations, the gain achieved outweighs the cost by a factor of 30x over the 3-5-year implementation timeline. These savings represent both damage frequency and waste embedded in the system. Severe damage reduction and public safety or societal benefits are not calculated and are on top of these figures.
Ultimately, it is possible to drive out waste, inefficiency, and excess cost from the damage prevention and utility locate process while improving public safety and lowering the total cost to ratepayers, asset owners, and operators (utilities, department of transportation, municipalities).
Louisiana Recommendations Recommendation Summary Overall,
Louisiana achieves less than adequate performance as measured by PHMSA, CGA’s DIRT Report, IPC, and stakeholders. There are weaknesses or gaps in the Louisiana dig law that are directly related to its low performance. Opportunities for further improvement include the following:
14 • Louisiana 811 2022, Issue 3
1. Mandatory Damage Reporting:
Refine the dig law to require reporting of all damages (not necessarily investigation into all damages) to all underground utility types.
2. Balanced Enforcement: Cause enforcement authority to weigh the involvement of all primary participants in the damage and hold the asset owner, excavator, and locator responsible in the damage adjudication process in a fair and balanced fashion.
3. Third-Party Enforcement
Board: Develop or enhance 3rd
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.
4. Effective Metrics: Identify, develop, collect, and track metrics that effectively support trending and continuous improvement of the state damage prevention performance. Annual Reporting to CGA and DIRT: Require state entity(s) responsible for the oversite of the 811 system and collection and adjudication of compliance or damage reports, ticket volumes,
etc. to submit data to the Common Ground Alliance (CGA) to support the preparation of the annual DIRT report.
5. Positive Response Requirement: A web-based electronic positive response requirement by all asset owners/ locators through the 811 system.
6. Excavation Site Accurate Description:
a. Premark / White-line Requirement:
Require pre-mark or white-lining of any proposed excavation area that includes both traditional and electronic response options.
b. 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.
7. Standardize Ticket Size - Distance, Duration, and Life: Standardize the ticket size, distance, duration, and life to the described characteristics.
8. Educational Resources: Develop and publish electronically an excavator’s manual that is updated and republished every 5 years or when an update to
the law takes place, whichever is more frequent. As previously noted, the 2019 Louisiana estimated total damage cost is approximately $400 million in annual and out-of-pocket cost to the system with an additional largely invisible
$500 million in waste, inefficiency, and excess cost embedded in the system. The nine recommendations proposed, will eliminate $600 million of these damage and waste costs over a 3-5-year timeline and these benefits exceed the implementation cost of $24 million
by a factor of 30x over the 3-5-year implementation timeline.
Recommendation Detail
To support investigation and potential implementation of the identified recommendation, the following additional information is provided for research and discussion purposes and includes the following:
• Tactical / Process Issue Addressed:
A description of the tactical activity or process breakdown and inefficiency identified.
• Recommendation: Summary description of the proposed recommendation.
• Solution Summary: A description of the condition, characteristic, practice, process, or law that was identified as high functioning in another state and is a starting point for research and discussion purposes.
• Solution Reference: A description
of where or how to access additional information about the condition, characteristic, practice, process, or law that was identified as high functioning in another state.
Mandatory Damage Reporting
Tactical / Process Issue Addressed
– Process: Hold responsible parties accountable for damages and cause them to change future behavior. Structure system to support continuous improvement efforts through collection of data to identify trends, conduct root cause analysis, and ultimately support building a culture that embraces damage prevention.
Recommendation – Mandatory Damage Reporting: Refine the dig law to require reporting of all damages (not necessarily investigation into all damages) to support more effective damage adjudication and enforcement.
Solution Summary – New Hampshire law states...each operator shall file monthly, with the commission, on or before the 15th day of the following month, probable violations of PUC 800, damages to underground facilities, or both. Excavators are required to notify 811 of any damage as well as... report the damage within 72 hours,
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