The Ticket Is Not the Work

The job was simple: a water and sewer service trench, 12 to 24 inches wide, running from a building to the curb. The locate request was not. It asked for every main and service line on the entire property, 25 feet beyond the property on either side, and both sides of the road. The scope-of-work field was blank.

Marking the area around the trench would have taken about 20 minutes. Following the instructions took 40. The same instructions appeared on 30 tickets from the same excavator, adding 10 hours of locating where no one planned to dig for this project. Those were 10 hours that could have gone to other tickets waiting in the queue.

That ticket is not unusual, and the system it runs through is moving in the wrong direction. The Common Ground Alliance (CGA) reported in July 2026 that the CGA Index, its national measure of damage to buried utilities, reached a record high of 102 in 2025, based on 221,717 unique damage reports. That same year, 811 centers in the United States received 45.5 million locate requests and sent 273 million transmissions to facility operators. Each one starts a legal clock, whether it covers a mailbox post or miles of fiber route.

In two earlier articles, Nulca described how the design of the 811 system produces late and inaccurate locates: unlimited ticket scope, no advance warning of large projects, records that do not match what is in the ground, and rules written without the people who carry them out. This article sets out what Nulca is asking state lawmakers to change. Nulca's Board of Directors adopted these four priorities as its state legislative agenda in July 2026.

That ticket is not unusual, and the system it runs through is moving in the wrong direction.

We start with our own industry. Locating companies are responsible for qualified technicians, accurate marks, honest status reports, timely escalation when conditions change, and quality control. These reforms are not excuses for late or inaccurate locates. Nulca will own what the locating industry can control. The reforms address what locators cannot fix alone: the work request, the project schedule, the facility records and the rules themselves.

1. Make a standard ticket a real unit of work

A locate request, or ticket, is a legal notice that excavation is planned. It is not a measure of work. One ticket can cover a single address. Another can cover miles of corridor. Both arrive in the same queue with the same deadline, which in many states is two business days.

Nulca's proposed state model would change that. A standard ticket would cover no more than one-quarter mile or five consecutive addresses. Locators would have three full business days to respond, not counting the day the request is made. A ticket would remain valid for no more than 15 business days, and excavation would be expected to begin within that time. The excavator would mark the planned dig area on the ground with white paint or flags (known as white lining) and define it electronically on the request, describe the work clearly, name a site contact who can answer questions, and maintain the marks for the life of the ticket.

These ideas are already in use. Virginia caps each locate request at one-third of a mile and keeps it valid for 15 working days. Georgia 811 limits a standard ticket to five addresses and one linear mile. Pennsylvania requires excavators to give at least three business days' notice before digging. CGA Best Practice 3.29 calls for a maximum request area that is "appropriate for a proposed excavation site." Nulca's numbers draw on these models. They are a proposed standard for states to adapt, not a claim that one combination is right everywhere.

The longer window is not a request to work more slowly. A technician with three days and a white-lined work area can mark accurately and on schedule. A technician with two days and an undefined area is forced to triage.

Large projects need their own path, and the stakes go well beyond schedules. In August 2020, a dredge working in the Corpus Christi Ship Channel in Texas struck a submerged propane pipeline, and five people died. The National Transportation Safety Board (NTSB) found that deficient project drawings led the contractor to give the pipeline operator incomplete and inaccurate information during the one-call process, and that inadequate planning was the probable cause. Among the measures NTSB said could have prevented the accident were closer collaboration between the parties and sharing the pipeline's GPS coordinates.

A technician with three days and a white-lined work area can mark accurately and on schedule. A technician with two days and an undefined area is forced to triage.

Nulca proposes a separate large-project process with a planning meeting before work starts, defined phases and an agreed marking schedule. When a project will push a market's ticket volume above the prior year's level, the party responsible would submit an assessment of the expected volume at least nine months in advance. CGA Best Practice 5.35 supports separate handling of large and complex projects, and states including Pennsylvania, Georgia and Washington already use versions of this approach.

Two objections come up quickly. The first is that smaller tickets will mean more tickets. They would, if states only shrank the standard ticket. That is why Nulca pairs the limit with a separate process for large work. The second is that this is simply a request for more time. It is a request for a defined unit of work, and excavators gain from it as much as locators do. CGA's 2024 DIRT Report found that, across eight 811 centers, excavators were delayed in starting work an average of 38 percent of the time because responses to their locate requests were incomplete. It also highlights how unpredictable locates encourage contractors to over-notify, which strains the system further. Clear, right-sized tickets help break that cycle.

2. Put field knowledge in the room where 811 rules are made

The boards and advisory committees that govern 811 centers set rules on ticket formats, response systems, technology and performance requirements. Those rules land first on locating and excavating crews. Nulca's Board is asking states to give contract locators and contract excavators voting representation on these bodies, so decisions reflect how work is actually performed in the contractor operating environment.

The goal is informed decisions, not control of a board. CGA Best Practice 3.04 calls for 811 center boards that represent "the diverse makeup of stakeholders." Some already include locating expertise. The board of JULIE, Illinois' 811 center, has a director seat for contract locators, and South Carolina 811's board includes a seat for facility contract locating.

South Carolina 811's executive director explains why that input matters:

"Contract locators and excavators bring distinct operational perspectives as high-volume users of 811 systems whose field work is directly affected by system and law changes. Including them on 811 boards or in state legislative working groups helps identify unintended consequences before changes are adopted, reducing process barriers and supporting safer excavation."

Misty Wise, Executive Director, South Carolina 811

These boards show that locator representation works alongside facility owners, excavators and public agencies. A board seat alone will not prevent damage. Rules written with field knowledge are more likely to work in the field.

3. Build records that match what is in the ground

A locator can follow every procedure correctly and still start from a record that is wrong. In one case Nulca has previously described, a telecommunications line was found nearly six feet from its recorded location after excavation began. The locator had marked where the records placed the line.

The consequences can be far worse. In April 2017, a house in Firestone, Colorado, exploded, killing two people. NTSB traced the gas to a line from a nearby well that had been recorded as abandoned in 1999. The line was still active, and it was most likely cut during the home's construction. NTSB found that approving construction without complete records of the location and status of the operator's lines contributed to the accident.

Better records do not replace field locating or careful digging. They make both more reliable.

Nulca is asking states to set specific accuracy requirements for new and relocated facilities, using GPS/GNSS (satellite-based) positioning. Records should be updated when facilities are exposed, repaired, relocated or abandoned, or found somewhere other than expected, and facility owners should make them available to locators in consistent digital formats. Older records should be improved in order of risk, not through an impractical requirement to resurvey everything at once.

The American Society of Civil Engineers' Standard Guideline for Recording and Exchanging Utility Infrastructure Data (ASCE/UESI/CI 75-22) provides a technical framework for documenting the location, geometry and attributes of newly installed and exposed facilities. Facility owners benefit as well, because accurate records support planning, asset management and emergency response. Better records do not replace field locating or careful digging. They make both more reliable.

4. Tell people where 811 coverage ends

Contacting 811 before digging is essential, but not every line will be marked. Facility operators that are members of an 811 center are notified and must respond. Privately owned lines, such as power to a detached garage, irrigation systems or propane lines, may not be marked at all. CGA Best Practice 3.32 says 811 centers should tell people requesting a locate that privately owned facilities may exist and that their owners will not be notified.

Nulca is asking states to make that limit clear at every step: plain notice when a request is made, practical examples of what may be private, an explanation of who is responsible, and information on where to find private locating help. An 811 response is not a complete inventory of underground risk, and no one should dig as if it were.

What each part of the system gains

Each of these reforms asks something of someone. Excavators would define their work more precisely. Facility owners would invest in better records. Each 811 center would help manage ticket scope and give clearer notice. Lawmakers would update rules written decades ago, when 811 centers handled far fewer requests, to reflect today's pace of construction. Locating companies would be held to clear standards for accuracy and response.

In return, excavators get dependable locates when they need them, facility owners get fewer damages to their networks, and the public gets a system less likely to fail the moment someone starts to dig.

Nulca's agenda is practical: define the work, put field knowledge in governance, improve the information everyone relies on, and be honest about the limits of 811 coverage. We invite lawmakers, 811 centers, facility owners and excavators to work through these proposals with us, state by state.