The opinions expressed in this article are those of the author. Damage Prevention Professional welcomes and encourages articles and correspondence from all points of view.
That ’s a phrase we remember well if we are over fifty years old since it was in 1970 that it happened.
While the problem before us today is not a “Life-or-Death” situation, today we DO have a problem, and even though it’s buried and out of sight, it IS a matter of life or death.
Defining the Problem
Residents of your city or state will not tolerate you throwing litter out the
window of your car, dumping your ashtray (what’s an ashtray?) or otherwise clutter the street with your trash and discards. There are fines for littering, but even so, trash occasionally appears on the roadways.
To combat the accumulation of trash, most of us have a service that removes trash and garbage from our neighbor-hood on a regular basis or we take it to a landfill or dump. Much of what we send there is recycled, reused or
destroyed. Where it is buried, the decomposition process creates gasses that many times provide energy that is collected for use in generating electricity or steam for other beneficial uses.
And we have street-sweepers that regularly clear the pavement of debris left from autumn foliage and pieces that fall from our transportation vehicles. We like clean streets, don’t we? We believe that trash has its rightful place.
But do our discards belong below the pavement, below the surface, in the under-space? Would we allow someone to bury their trash under the pavement? Under the landscaping? Think about all the utility facilities that have
been placed below the surface, sometimes more than a hundred years ago. How should we handle them when they have outlived their service life? The fact is, we are abusing our rights-of-way.
Why the Concern?
The concern is for safety and cost control. An example of some issues that abandoned lines cause include:
• A utility locator marks an abandoned line that had a signal induced onto it thinking it is the active line, causing the active line to go unmarked and the location of it unknown.
• An excavator encounters lines that are unmarked by the One Call system. The project is delayed until the unknown line is identified.
• A person gets hurt because no one could distinguish between the abandoned line and its replacement.
• A proposed new installation cannot be placed effectively or efficiently because of the lack of available space in the right-of-way.
Who is in Control?
Agencies typically have permit reviewers and issuers in control of what happens within the public rights-of-way. Are they qualified or simply promoted? Are they aware that there are rules, standards and regulations covering utilization
of these rights-of-way?
We have field inspectors. Are they overworked so accurate as-builts cannot be collected? We have various agreements with utility owners. Are we presenting a professional process to those who utilize the system?
Many agencies have no idea of the number of utilities, active, out of service or abandoned, lying beneath the surface of the rights-of-way they control. Sometimes the utilities belong to us! They will many times blame the fact that they don’t have the funds required to actually manage what’s there much less what’s going in. After all, reviewing as-built plans and filing them in a retrievable manner costs money! What’s wrong with this picture?
If this is the case, efforts made should be to increase permitting or franchising fees to cover the costs required to do the job correctly. Oh, “That’s a political issue. Council/ Management/ Legislators will never allow that,” might be an answer. If that’s the case, the politicians need to be introduced to the issue. Most don’t even know the problem exists!
Codes, laws, franchises and other regulations must be reviewed and regularly updated. If they are not enforced they must be forfeited.
Some utility owners are forced to remove their facilities from service claiming them inactive or abandoned due to taxation laws. These laws must be modified to allow inactivity while still allowing them to be located and marked as live lines since they may be reactivated.
Whenever possible, abandoned lines must be removed from the rights-of-way. When excavation encounters unused lines, arrangements should be made to allow/require their removal. Project owners for all contracts requiring excavation should include a bid item in project specifications requiring the contractor/excavator to remove encountered abandoned facilities to the extent of conflict within the project limits. Removal pricing will vary depending on the abandoned utility encountered. If this is done, it would be considered a reasonable alternative and would be the responsibility of the facility owner to pay for removing their facility for the project. Bills for the removal costs should be sent to the facility owner as a separate contract line item. The estimated cost must be established during project design so that the owner can budget for the work and the project owner can recover it from the facility owner prior to project start.
Owners of utilities to be “abandoned” should be required to properly and safely evacuate/ empty the underground facility. Where abandonment is the only reasonable option, the owner of the facility should work with the agency owning the right-of-way to determine final requirements. Final requirements could require filling metallic pipelines with nitrogen or another inert gas to reduce the rate of deterioration from the inside. Metallic and non-metallic pipelines might require the line to be filled with material or plugged in specific locations. All pipelines may require the installation of locating devices to allow the One Call center to accurately locate the facility. Manholes, pull-boxes, J-boxes and similar structures as well as all aboveground features should be properly and safely removed. Where unknown or abandoned facilities cannot be removed, the structures/access points removed, the facility should be surveyed, markers installed making it locatable, and mapped identifying the location with details of the line encountered recorded. The details should be placed on the as-built plans and kept for future use by the owner/
manager of the right-of-way.
Standard utility locations should be established by the agency. Infrequently accessed lines should be placed where pavement cuts and access is more difficult than for those utilities frequently accessed for new connections of frequent maintenance.
Arrangements should be made for accumulating the records of utility facilities owned by utilities that go out of business. The owner of the right-of-way should become the owner/locator of the remaining facilities.
Utilization of ASCE Standard 38, Standard Guideline for the Collection and Depiction of Existing Subsurface Utility Data, should be expected prior to all excavation reducing the uncertainty of addressing unknown abandoned lines during construction activities.
Some unused lines may be repurposed for use by another utility. If a line is repurposed, the owner should work with the public utilities commission to determine if the facility can be sold or leased to another utility (based on local and state laws). The new utility would apply for and receive a permit from the appropriate agency. The new utility owner would also be responsible for One Call designation/locating/marking. In the case of a leased facility, the owner would retain the ultimate responsibility for mapping and marking with the appropriate designation.
Contractors encountering unmapped abandoned facilities should be able to notify the owner of the facility of its location with the expectation that the information provided will be recorded, mapped and marked for future use. A locating device such as a marker-ball should be placed at the location where the facility is encountered to enhance
the ability to locate it in the future unless the facility is to be completely removed.
Owners of facilities already abandoned in place in a public right-of-way and not currently mapped might be required to locate and mark the facility, employ a surveyor to survey the line and record the document so that the owner will be able to locate and mark the facility in the future.
Utilities might answer, “We bought the system years ago, and didn’t know what we were getting into. The previous owner didn’t have any maps.” A person must understand that with today’s technologies, the system CAN be mapped! How important is it to know what you own and are responsible for? Ask your Legal Department!
As-built details must be surveyed in 3-dimensions and recorded. The records must be retained by the owner of the facility and the owner of the rightof- way until the facility is removed.
A standardized symbology should be established by locators for identifying/marking abandoned facilities. An example of one used in Arizona is a circle with the letter “A” in it using the appropriate color code for the type of facility that is abandoned, placed within the dig site boundaries described in a One Call ticket in the appropriate color code for the type of utility that has been abandoned.
Since abandoned facilities are many times physically separated from active facilities, it is not always possible to locate them for marking. For this reason, a circle with an “A” in it is used for marking purposes to indicate an abandoned facility exists in the area. If an excavator has received responses from all underground facility owners impacted on a One Call center ticket and some of them have indicated they have abandoned lines in the area by marking the circle
with an “A” in it in their corresponding color code, it is possible that the excavator could uncover an unmarked line. If this is the case, the excavator would contact all facility owners who have used the circle with “A” mark (they could use the One Call center to do this) so they can come to the job site and visually inspect the exposed facility and tell the excavator if the abandoned facility belongs to them. If it is determined that it is not one of their abandoned facilities,
the excavator would need to contact the One Call center to start an Unknown Line process.
Utility owners must plan further ahead, coordinating their activities with the owner/manager of the rights-of-way they occupy. Utility Coordination Committees need to be established and utilized so pavement replacement, new feeder lines, line replacement and upgrades, and maintenance activities can be scheduled and coordinated to reduce not only impacts to the public but to allow effective, efficient utilization of the available rights-of-way. Available online websites and GIS systems currently allow these activities.
The point here is that we are not managing our below-the-surface rights-of-way with the same intensity that we manage those that are visible. Among the most serious offenders are owners of facilities, generally utilities and agencies, who are allowed to discard lines that are obsolete or no longer useable. In some instances, lines are even discarded for taxation purposes. Because these activities affect facilities residing below the surface, no one becomes aware of the problem until it becomes an issue.
So, what’s the answer? What can we do? While we don’t claim to have all the answers, there are some suggestions listed here that could be implemented immediately. Others may take time but must be considered and implemented in some form if we are to gain and maintain control of our public rights-of-way.
All of these suggestions presume that we are discussing Abandoned Utilities. Abandoned facilities and Out of Service facilities may have differing definitions depending on the locality in which you reside or work.
The point is, we are currently burying our utility trash in the public rights-of-way. We have designated areas for disposing of our discards, and our solid waste management departments plan and effectively manage recycling and disposal sites. Disposal of worn out and unwanted utility facilities, however, remains an unplanned and seat-of-the-pants process. Allowing this process to continue in its present iteration is not only unprofessional, it is dangerous to those working in the rights-of-way. We need to evaluate the situation and begin to find ways to professionally manage the situation.
Al Field is President of Al Field & Associates, LLC with over 40 years’ experience in coordinating governmental
capital improvement projects and is an active American Public Works Association (APWA) Utility and Public Rights-of-Way (UPROW) Committee Member. He can be reached at email@example.com.
These suggestions have been developed by the American Public Works Association Utility & Public Right-of-Way Committee with assistance from other interested parties. They are suggested practices which are not intended to be all encompassing or to conflict with any legal or other responsibilities of the user.