APPENDIX B—SURVEY RESPONSES

This appendix documents the responses of survey participants that were summarized in the main body of this report.

Project Owners

Question 7. What are challenges or obstacles your department faces when dealing with OOS utilities in the right-of-way?

Responses from 43 participants include the following:

1. Confused messages to the utility. Policy is no facility remains in the right-of-way unless it is permitted and blue staked. Permit office is not always in the loop, so follow up is unlikely. The field engineer makes decisions not shared or consulted with others.
2. Contact information is often old and no longer available.
3. The contractor will normally want confirmation in the field that the utility is abandoned.
4. Determining ownership and whether the facility is truly out of service.
5. Determining the correct owner. Timeliness of corrective actions.
6. Determining the owner of the facility.
7. Difficulty locating, identifying, and relocating the utilities.
8. During the construction phase of a project every utility that is exposed tends to concern the contractor, at which time I confirm with the contractor that all utilities have been relocated within the construction area. I identify the utility by looking at previous locate marks and call the utility to come out and verify that the utility is in fact dead and that construction in that area may resume. I do relocations a few months before construction begins so I have a very good understanding of where OOS utilities are and where the new utilities have moved to. I am the right-of-way coordinator, so that is part of my duties within the scope of the project. I keep myself available during the initial periods of construction where grading occurs, and this tends to be when we find most of the OOS utilities.
9. Finding the owner, determining whether it is in service or not, safety, authority to remove once we run out of options.
10. Finding the owner due to frequent ownership changes over time.
11. Finding the owner. Knowing that the OOS utility is there.
12. Finding the utility. Getting it moved on time. Reimbursing the utility if applicable.
13. Gaining consensus on allowing OOS utilities in right-of-way from a policy standpoint. Finding OOS utilities is very rare in Washington State. However, once a region/district utility office does during a project, they never forget it.
14. Getting accurate location information from the utility owner if they are still in business. Verification of abandonment/identification of previous ownership. Project coordination/delays if utility is required to perform unplanned work in active construction zone. Multiple utilities/entities involved. Relocation conflicts.
15. Identification of current or prior owner is the greatest challenge.
16. Identifying who owns it and getting any form of accountability for not having identified or removed it in the first place.
17. In the field, grade conflicts with proposed new facilities. Old and compromised existing facilities (i.e., clay tile, transite, or other sewer pipe) failing during excavation, old water mains found to be leaking, duct bank installations damaged or deteriorated.

18. Knowing if they exist, the exact location of the OOS utilities, and who owns them.
19. Lack of right-of-way availability. Lack of urgency of utility companies.
20. Locating the issue ahead of planning rather than during operation.
21. Locating them and companies taking ownership or responding.
22. Mainly time-related—finding OOS utilities too late in the project development process, which requires rescope and/or rework.
23. One of the biggest challenges is determining the owner of the facility and verifying the utility is indeed out of service. In places, our right-of-way is limited, so OOS utilities can present a challenge for utility coordination and relocation processes.
24. Owner, field location, status.
25. Ownership and redesign.
26. Poor documentation of location of OOS infrastructure. Lack of requirement for utility companies to remove abandoned infrastructure from the right-of-way at their expense.
27. Poor recordkeeping and slow response.
28. Sometimes, it is challenging trying to find out who owns the OOS utilities.
29. The biggest challenge, in my opinion, is that we may not receive or own documentation that definitively locates a utility line or notes that an abandoned line exists, whether the files come from the utility companies or when researching older as-built plans. This inability to locate abandoned lines provides a safety issue for the construction and maintenance field workers during site clearing for vegetation and/or doing any sort of excavation work.
30. The greatest challenges are the risk they present to project schedule, budget, available space in right-of-way, abandoning in place versus removal, difficulty tracking down owners, mislabeled locate requests, incomplete SUE data, risk to contractor and DOT maintenance personnel safety, inaccuracy of data/unknown how many abandoned facilities are in right-of-way.
31. The permitting of OOS utilities is required within Nevada DOT. The encroachment permits require utilities to remove facilities that are no longer in operation. Utilities will attempt to abandon in place, and the DOT requires them to be permitted in the same manner as an active utility and includes their removal if found in conflict with a future project. The environmental impacts experienced are related to facilities that contain or are coated with asbestos containing material. The owner/installer of these types of facilities would like to leave them in place rather than remove and be responsible for the disposition of them. This oftentimes requires lengthy negotiations with the owners to encourage compliance with the encroachment permit that authorized the installation.
32. The unknown. What was or is in the pipe—gas, electrical, etc.?
33. There is no standard way to report these OOS utilities. There are no funds available to remove them. Abandoned fiber and electrical lines are not represented by One Call, so they are hit with no locate information. They cause work delays.
34. They cause an immediate delay. Many times, it is difficult to find out what utility company actually owns the abandoned pipe, conduit, etc. They never seem to want to admit ownership. This process can take one day to resolve or possibly several weeks.
35. This has been a nonissue since I have been in this department.
36. Trying to identify if they are a live utility and who the owner is during design. Confirming if they are out of service. Also, assisting our construction section identify unknown utilities when encountered during construction.
37. Trying to re-sequence work or adjust the design quickly to minimize delays in construction. Getting a cost estimate and a change order processed in a timely manner to avoid additional delays.

38. Typically, OOS utilities are found during construction or maintenance activities and were unknown prior to. When that happens, then work stops until we can determine that the facility is not in use and determine a path forward. It is usually hard to get companies to provide input on the facilities since they have no record of the facility any longer. This makes it hard to get resolution. A lot of times, we collect insight from companies, have the gas company come out and drill the line, and have the state’s contractor remove once verified as out of service. There are times where our SUE investigation or utility coordination process identifies unknown or OOS facilities during the design phase. In those cases, we work with utility companies to see if we can iron out ownership and identify a path forward in our construction plans and utility statement. The process often becomes similar to what I outlined in the construction process.
39. Utilities complying with state law requiring them to maintain records and flag OOS utilities.
40. Verifying if a utility is out of service.
41. We do not have a method to change the status or ownership of existing permits. This makes it difficult to determine the owner of OOS facilities. We also do not address this in our rules or policy very well, but we would like to do that in future updates.
42. We only coordinate/oversee utility facility relocations/ removals/ installations related to capital improvement projects. We do not permit/oversee utility facility installations/ relocations/ removals/ installations that are unrelated to our capital improvement projects.
43. When OOS utilities are encountered during construction without prior identification, there is a stoppage of work to contact the appropriate utility owner and confirm the status of the located infrastructure. This can lead to claims from the contractor for various reasons but has an immediate impact on productivity.

Question 8. Please describe issues you experienced with the removal of OOS utilities during highway project construction.

Responses from 34 participants include the following:

1. An abandoned gas line was discovered and finding the correct owner to perform the corrective actions took considerable time. The contractor was instructed to purge the known abandoned gas line that contained substantial amounts of water that impacted the work zone.
2. Asbestos cement pipe removal.
3. Although I was not present, as part of the design team whose project was in construction, we were informed about this situation where a contractor’s employee was seriously injured when an unknown abandoned cable line was potentially installed at a shallow depth (or maybe was made shallower due to years of erosion). The cable got caught in the cutting blades of the equipment the staff person was using to clear large areas of vegetation. The line was severed by the blades, and one end of the cut line whipped around and struck the staff person. The person had to be hospitalized. From what I recall, after the incident, there was trouble locating the original owner of the line and determining the path of the line so that the project could remove it before continuing with construction activities. This led to some delays and increases in support and construction costs.

4. Confirming with the utility owner that it is in fact abandoned and getting their approval to remove it. Sometimes the contractor needs to bring in different equipment to remove the utility, which can add time and cost.
5. Conflict with other utilities or roadway structures.
6. Confusion about what it is. Is it in service? Utility companies destroy maps if under new ownership. Sometimes it is hard to find someone willing to be a responsible party.
7. Contamination of facilities.
8. The contractor was not planning to do this work, so it was not in the schedule, and he did not have the right equipment.
9. Delayed timelines for utility relocations/removals/installations that impact the capital project schedule. Limited staff and crew availability. Delayed timelines to receive relocation plans from the utilities to be incorporated into the capital project plans during design and before property acquisition commences. Delayed identification of some utility facility owners. Limitations imposed by pole owners of who/what can be attached to their poles. Early coordination of attachment heights to ensure correct pole heights are installed. Use of utilities’ property rights to relocate facilities for capital projects without the need for additional right-of-way or easements. Balancing the ability to secure desired rights-of-way and/or easement for utility facilities versus redesigning the project to meet the project goals and available funding, and many more.
10. Determination of what was inside the OOS facility and if it is safe to remove.
11. Every situation is different. If the utility impacts the contractor, it is a high impact for possible cost and delay. Depending on what the utility is, it may open up environmental, right-of-way, and safety concerns. Issue becomes coordination and determining what additional work is needed, by whom, what is affected by it, tracking all associated delays and costs, and finally determining where to direct those extra costs.
12. Facilities were in place prior to the DOT obtaining the right-of-way establishing compensability for the owner of the facilities. This placed an increased cost and burden on the DOT’s project to decide the best method of removal, installer, or DOT (our contractor). When the material is considered an environmental concern, the DOT will negotiate to have the installers remove the facilities to limit the liability to the DOT and long-term responsibility when disposed of. The negotiations have the potential not only for increased cost and environmental risk but a time delay for letting out the project.
13. Gravity sewer can be challenging and could be very lengthy in order to remove a segment or change grade. Natural gas and electrical or communication facilities can be challenging as well.
14. Had a utility relocate to wrong place and delay a project.
15. Have had issues with certain utility companies relocating or removing their utilities in a timely manner, both buried and aboveground. Once utilities were relocated, retired in place utilities cause issues with construction due to not being marked or fully removed.
16. Hazardous materials contained with the utilities such as asbestos.
17. It is a long process to identify the owner.
18. It is difficult to get the utility identified so construction crew knows it is safe to remove the abandoned utility, and then there is always a little anxiety as the removal operation starts.
19. Unknown utility conduit incased in concrete, had to locate ends and dig to make sure nothing was in it.
20. Marked as unknown in SUE plans, or unknown by locators whether active or abandoned. Every day of discovery is a day of delay and increased costs to project

20. schedule. Removal is complicated due to other utilities, drainage structures, driveways, highway crossings etc.
21. On most major projects we encounter an abandoned facility and have to find who owns it. This causes delay and eventually the utility will deal with it, but they never care or pay for the underlying delay to the project.
22. OOS utilities result in additional cost and potentially time added to a project when discovered during construction.
23. Outdoor advertising signs. Georgia pays for the relocation by law.
24. Project delays, identifying who owns the utility facility, confusion on which facility is active or out of service, and damaging utility infrastructure that was marked as out of service.
25. Significant project delays associated with poor advance identification during the design phase.
26. Sometimes, we have trouble identifying the utility, and if the line is active or inactive.
27. Uncertainty of ownership, viability of utility, or whether it is in use or abandoned leads to delays and research. Safety becomes an issue if a line needs to be cut.
28. Unclear to contractor which facilities were out of service, so had to assume all were in service. Construction was delayed until utility owners could confirm the status in the field. Have also had the contractor, based on utilities’ records, be certain the facility was out of service only to find it was not after damaging the facility. OOS utilities are not shown on locates and may not be identified in the construction contract leading to change orders to pay for unexpected removal.
29. Usually this comes in the form of being able to quickly iron out a path forward to keep the contractor working. To be safe, the contractor has to assume the facility is live/active until confirmed otherwise. Sometimes the material of the facility could be hazardous and require special remediation to remove. This adds time and money into resolving.
30. Utilities often need relocation in order to construct a widening or realignment, getting these moved correctly the first time and in a timely manner is difficult even when they are known far in advance. When we discover utilities not on the plans it causes severe delays, increases costs, and has a large impact on the work.
31. Utilities were not relocated as specified and OOS utilities were cut at access points rather than removed, which caused delays and safety issues.
32. We found an old line that no one would claim or could identify. We ended up having to add to the project to do an adjustment of water line to go under unidentified lines.
33. We had challenges identifying the owner/former owner, and even more challenges assigning cost responsibility of removal/mitigation to the owner.
34. Where we had planned to remove an abandoned pipe, we found that the surrounding area would not support the pipe, so we ended up having our contractor fill it in at DOT’s expense.

Question 9. What are successful strategies or practices implemented in your department to manage and resolve issues related to OOS utilities?

Responses from 40 participants include the following:

1. A successful strategy is keeping good records.
2. Adjust design to go above, under, or around OOS utilities.
3. An expected and mutually beneficial utility coordination process. Open communications with confirmed points of contact. Sincerely developed, trustworthy business

3. relationships. Educating directly related and indirectly related staff about the above. Ensuring an overarching business intention and execution to foster the above.
4. As mentioned previously, we reach out to all companies to discuss/work out how to verify OOS utilities and identify a path forward to remove. This can be time-consuming, but we have successfully navigated through the process many times to resolve issues. We have been successful in identifying potential OOS facilities through SUE investigations. We also used a mapping tool to get good location data (x, y, z) on an OOS sewer facility to understand its exact location as part of early design efforts on a bridge project.
5. As much awareness as possible of utilities within right-of-way during design to allow time for research. SUE investigations if warranted.
6. Ask at utility coordination meetings if they are aware of any additional OOS facilities.
7. Communication with the utility companies during design can allow for those entities to identify on review plans or share records of abandoned utilities with the design team. This information may then be shared with the construction contractor to prevent impacts if/when these facilities are uncovered.
8. Constant contact and a well-maintained relationship with utility companies. When I have found that certain utilities are not relocated in a timely manner, I will pull/deny utility permits until the utility company started relocation process.
9. Coordination to find them and identify their contents; determine whether to abandon-in-place or remove.
10. Deny all applications to abandon old utility lines. No exceptions.
11. Early identification and coordination.
12. Early identification of location, condition, or planned upgrades. Once issues are found during construction, raise immediate attention of what the issue is to the utility owner and plan development to correct the issue.
13. For underground utilities, require removal in lieu of abandon in place when the installation of new facilities is requested. This is done to preserve space in the right-of-way.
14. Having the utility remove the OOS facility. Having the OOS report to the state One Call system.
15. I started requiring all utilities to remove all OOS facilities (or occasionally burst the lines in place). The utilities went to war after that and threatened to go to the legislature but either did not follow up or did not go far.
16. Identify all conflicts before the construction phase.
17. Identify these types of utilities early in the design process.
18. Implemented a new MaintStar utility tracking software system to better manage and track existing utilities. Improved coordination with 811 utility-locating program.
19. Keeping a list of utility owners contact information and listing if they are active or inactive. Having a discussion with the utility owner to verify utility locations, OOS utilities and determine a plan of relocation. If needed, the department will enter into an agreement with a contractor to test a pipeline and/or cut, purge and cap it. Have the contractor notify the construction residency before beginning work. Keep a set of final as planned utility relocation plans.
20. Keeping good as-built records. Maintaining good working relationships with utility companies.
21. Keeping good records of relocations and getting as-builts following relocations so you can give them to the contractor for peace of mind. Also making sure that locates are

21. regularly called in so that if there are OOS utilities it is easier to identify whether they are active or not. If they are not active, they will not be located.
22. Making utilities contractually responsible for meeting deadlines associated with utility identification and relocation.
23. None identified.
24. None that I know of. We just started contacting all of the local utility owners to try and solve the unknown.
25. None to report.
26. None, they are handled on a case-by-case basis.
27. Planning and workflow software.
28. Redesign around the obstructions and/or work with utility owner to have them remove it during construction.
29. Talk about them ad nauseum during planning. Charge utility for exact cost of delay immediately.
30. The department has been trying to implement policies where utility companies share the location of their lines with us through georeferenced as-built plans or, at minimum, through any relocation and/or abandonment plans, especially for those projects coming through the encroachment permit process. We are always looking for ways where utility lines can be marked or maybe have some sort of wayfinding mechanism installed so that it can be more easily located for future projects.
31. The DOT conducts SUE investigations to identify existing utilities, which include abandoned or out of service items during the design phase. The DOT then works with the owner of the facilities to have the impact removed to accommodate the project. The state regulation limits the compensation paid for the removal and can often times create lengthy negotiation with the owners of the facilities to encourage them to remove the impact to the project limits. When a facility is requested to be abandoned in place—with justification of lessoning the impact to the public that would be experienced by the removal—the owner is required to amend the permit or establish a new permit that clearly indicates that the owner is responsible for the facility for the time that it remains in place without regard to it being active or dormant. Early identification of existing OOS facilities is key to removing the impact of cost and time delays to our projects.
32. The utility accommodation policy requires that utility owners must maintain a permanent record of the OOS utility and should be able to locate it in the field. See https://wisconsindot.gov/Documents/doing-bus/real-estate/permits/09-15-01.pdf Section 5.0– 5.3.
33. Thorough SUE investigations performed during preconstruction phases, communication, and coordination with utility owners.
34. Tighten the language on removal requirements for better enforcement.
35. Try our best to locate the owner. Determine that the line is a deadline and move on.
36. Utility coordination coupled with SUE exploration is key to project success and worth every penny spent.
37. Very heavy utility coordination in phase I/II helps to minimize the number of OOS utilities encountered in construction. The utility coordinators get involved again if an OOS utility is encountered in phase III.
38. We follow our standard specifications for changed conditions.
39. We leave them in place for the most part. If they conflict with construction, they are removed only where they have an impact.
40. We typically do not allow OOS utilities left within our right-of-way. There are some legacy facilities in existence. And, on extremely rare occasions, we prefer that a facility is

1. abandoned in place because the removal is too difficult and may compromise features of the right-of-way or traveled lanes. In any scenario, we still track the facilities in our database in order to identify in future work or utility installations.

Question 10. Please describe or provide a link to your department’s document(s) with requirements to place a utility out of service.

Responses from 31 participants include the following:

1. A utility provider is required to notify the division of abandonment of any utility that is permitted within our right-of-way. It gives timelines for notice and removal after notice, as well as options for methods of abandonment. We also reference West Virginia state code for the removal of double and triple poles.
2. Accommodation policy.
3. Alaska Utilities Manual 3.14. Abandoned, Deactivated, or Discontinued Utilities.
4. Alaska’s utility manual says, “The utility owner shall completely remove at its expense any utility facility no longer required, unless determined by the regional utility engineer that removal is not feasible, and the facility does not constitute a future liability to the department. When removal of the utility is not feasible, document the location, status and ownership of the abandoned, deactivated, or discontinued utility. Abandoned facilities such as pipes or casings may aid future utility installations. Consider the condition of the facility and code compliance. Abandoned pipes may have to be filled with sand slurry or grout to avoid subsidence or settlement affecting a department facility. Utility pipelines that transported hazardous/flammable materials must be removed at the owner’s expense and may not be abandoned.” In practice, this is difficult to enforce.
5. Any casing that is larger than 2 inches needs to be flowable filled with concrete. We do not have any requirements for buried in place communication lines.
6. https://connect.ncdot.gov/municipalities/Utilities/UtilitiesDocuments/20220713%20NCDOT%20UAM%20Ver%202-0.pdf.
7. District of Columbia DOT Standard Specifications, numerous locations, including Section 207.03.A. https://ddot.dc.gov/sites/default/files/dc/sites/ddot/publication/attachments/DDOT_StandardSpecificationsHighwaysStructures_2013.pdf.
8. Guidance document clearly states no abandonment of utility lines.
9. http://onlinemanuals.txdot.gov/TxDOTOnlineManuals/txdotmanuals/utl/disposition_of_existing_abandoned_or_idled_utility_facilities.htm.
10. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=1401425.
11. Department of Transportation (045) Utility Accommodations Chapter 5, https://rules.wyo.gov/Search.aspx?mode=1.
12. https://wisconsindot.gov/Documents/doing-bus/real-estate/permits/09-15-01.pdf, see Sections 5.0–5.3.
13. https://wsdot.wa.gov/engineering-standards/all-manuals-and-standards/manuals/utilities-manual.
14. https://www.ardot.gov/wp-content/uploads/2020/09/Utility-Accommodation-Policy-effective-1-1-2012.pdf.
15. https://www.dot.ga.gov/PartnerSmart/utilities/Documents/2016_UAM.pdf.
16. https://www.dot.state.mn.us/utility/guidance.html.

17. https://www.dot.state.pa.us/public/pubsforms/Publications/PUB%2016M/PUB%2016M.pdf, page 1–23, paragraph 6.
18. https://www.maine.gov/mdot/utilities. This link will cover installations, relocations, and removal procedures.
19. https://www.michigan.gov/mdot/-/media/Project/Websites/MDOT/Business/Permits/Utility-Coordination/Utility-Accommodation-Guidance.pdf?rev=76196392cde84a59a183b599e7e226d9&hash=88D81C95A2E0D045929923B94F1C8F4C.
20. If out of service, the utility company must remove what is in conflict (5 feet around the utility) and obtain a permit to leave unconflicted utility in place. Permit says if it ever conflicts, it must be removed. The utility company remains responsible for ownership and blue staking. We are careful in the terms we use. No abandonment since utility remains owner and responsible.
21. Kansas Utility Accommodation Policy, https://www.ksdot.gov/Assets/wwwksdotorg/bureaus/burConsMain/Connections/Kansas_UAP_2007_Revised_5_2020.pdf.
22. Nevada DOT utilizes the encroachment permit to establish the responsibilities of the owner when requesting to abandon in place a facility to longer in service. The requestor must submit an impact statement that is reviewed for acceptance by the DOT. The statement must include the benefit to the DOT and traveling public and state the understanding that while the facility is no longer in use they understand and recognize that they are responsible for it in the same manner as an active service. The DOT will ensure that actions are taken (i.e., slurry filled conduit) to ensure the out of service facility will not have a negative impact to the roadway or improvement to the right-of-way.
23. New Mexico DOT website in our utility section.
24. See Texas DOT utility manual.
25. That is handled through our permitting office and reflects Ohio DOT standards.
26. The Delaware DOT utility regulation touches on utility retirements though there is not too much detail at this time, https://regulations.delaware.gov/AdminCode/title2/2000/2400/2401.shtml.
27. The manual can be found online, but as I mentioned, we need to add some additional requirements/guidance once we figure out what we want to do and how to do it, https://iowadot.gov/rightofway/pdfs/UtilityPolicy.pdf.
28. Title 70 states that all lines must be removed from the right-of-way when it is taken out of service or replaced.
29. We are about 2 months away from publishing our new utility accommodation policy. When available, it will be located at https://dot.nebraska.gov/business-center/utilities/.
30. We do not have exact requirements listed since it depends on the type of utility line and location. These two manuals provide the guidance: Caltrans Encroachment Permit Manual Chapter 600, Section 602.3, https://dot.ca.gov/programs/traffic-operations/ep/ep-manual and Caltrans Project Development Procedures Manual Chapter 17, Section 3 Article 10, https://dot.ca.gov/programs/design/manual-project-development-procedures-manual-pdpm.
31. www.dot.ga.gov.

Question 11. Please describe or provide a link to your department’s document(s) with requirements for coordinating abandonment with the utility owner.

Responses from 23 participants include the following:

1. Abandoned facilities are treated in the same manner as an active utility.
2. Being developed currently with our new utility accommodation program, https://dot.nebraska.gov/business-center/utilities/.
3. https://connect.ncdot.gov/municipalities/Utilities/UtilitiesDocuments/20220713%20NCDOT%20UAM%20Ver%202-0.pdf.
4. Coordination with the utility owner is accomplished through a district’s utility engineering (design) and right-of-way utility groups for Caltrans capital or locally sponsored highway projects. For utility owner projects coming in through the encroachment permit process, the district Encroachment Permit Office leads the coordination. The following manuals are used for both situations: Caltrans Encroachment Permit Manual Chapter 600, Section 602.3, https://dot.ca.gov/programs/traffic-operations/ep/ep-manual and Caltrans Project Development Procedures Manual Chapter 17, Section 3 Article 10, https://dot.ca.gov/programs/design/manual-project-development-procedures-manual-pdpm.
5. Guidelines for removal and requirements to be addressed if encountered in the field.
6. http://onlinemanuals.txdot.gov/TxDOTOnlineManuals/txdotmanuals/utl/disposition_of_existing_abandoned_or_idled_utility_facilities.htm.
7. https://edocs-public.dot.state.mn.us/edocs_public/DMResultSet/download?docId=1401425.
8. Department of Transportation (045) Utility Accommodations Chapter 5, https://rules.wyo.gov/Search.aspx?mode=1
9. https://www.ardot.gov/wp-content/uploads/2020/09/Utility-Accommodation-Policy-effective-1-1-2012.pdf.
10. https://www.dot.ga.gov/PartnerSmart/utilities/Documents/2016_UAM.pdf.
11. https://www.dot.state.mn.us/utility/guidance.html.
12. In the same manual provided earlier.
13. It is up to the district utility coordinator to contact and keep up to date with the abandonment of existing utilities.
14. New Mexico DOT website within the utility section.
15. Part of our permitting and project planning process. We ask for identification of any facility—live or abandoned in place.
16. The procedure is in an internal manual. I will contact TTI to provide information.
17. Same as previous.
18. Same response as previous. See Delaware DOT utilities regulation, https://regulations.delaware.gov/AdminCode/title2/2000/2400/2401.shtml.
19. See Texas DOT utility manual.
20. The utility owner shall completely remove at its expense any utility facility no longer required, unless determined by the regional utility engineer that removal is not feasible, and the facility does not constitute a future liability to the department.
21. We do if it can be located.
22. We follow Title 70 and Department of Transportation and Development utility permit guidelines.
23. Within the permitting documentation.

Question 12. Please describe with what other government agencies or stakeholders your department collaborates or coordinates when managing OOS utilities.

Responses from 21 participants include the following:

1. Coordinate with the 811 locating system.
2. Coordination with counties and municipalities. Coordination with contractors if found during construction phase.
3. Coordination with stakeholders during the design development phase according to the utility process.
4. District utility coordinators keep in contact with all city, county, and other state agencies.
5. https://www.ardot.gov/wp-content/uploads/2020/09/Utility-Accommodation-Policy-effective-1-1-2012.pdf.
6. I am only aware of environmental requirements that are worked with the Department of Environment Quality.
7. Local agencies.
8. Local governments.
9. Local governments and utility companies.
10. Local municipal utility owners.
11. Municipalities and counties, utility owners.
12. New York State Department of Environmental Conservation and New York City Department of Environmental Protection Police—both when appropriate.
13. Our municipal and state DOTs have access to our project mapping, and they are supposed to seek review of incoming.
14. PUCs will get involved with policy and dig safe issues.
15. The owner of the facility is required to obtain or maintain the required permits from other governing agencies to include local public agencies and state and federal agencies. When a project includes work involving other agency participation, a coordination meeting takes place with the utility and the other partners to ensure the utility understands any differences in their responsibility to remove or have removed facilities with regard to the controlled right-of-way. Not all agencies require the utility to remove the facilities like the DOT does.
16. Various state departments and local governments.
17. We hold district utility programming meetings, one per year in each construction district. We discuss all utility projects. OOS utilities are rare.
18. We work to hold the utility owner responsible for the facility they are choosing to abandon in our right-of-way, just like any existing utility owner.
19. When developing utility accommodation policies, headquarters staff and executives meet with FHWA to obtain direction and guidance on appropriate policies, and the executive level has also been in communication with several major utility companies over the last several years.
20. Wisconsin DOT’s utility accommodation policy is available to other governmental agencies and stakeholders.
21. Yes, if they are a facility owner similar to how private utilities are coordinated with.

Question 13. How are OOS utilities found and identified during a highway project?

Planning Phase

Responses from 39 participants include the following:

1. 811 and permit review.
2. All are identified and coordinated.
3. Conducts an advance utility inspection.
4. Coordination with utility owners.
5. Correspondence with utility, access to their maps.
6. Employee knowledge.
7. Existing maps and GIS data, confirmed with the utilities themselves.
8. Facility map request.
9. Field visits and as-built searches are initiated by a district’s utility engineering (design) team. Requests to utility companies are submitted. Preliminary utility plan sheets and a utility matrix are developed listing all known lines, active and inactive.
10. GIS maps, imagery.
11. Our utility coordinators maintain records and seek input from utilities in the surrounding area.
12. Identify which utilities are within the construction zone and have them relocate.
13. If known from prior as-builts or through discovery from site characterization.
14. If we know they are there.
15. Inquiries, permit records, and coordination activities.
16. Institutional knowledge of Wisconsin DOT staff.
17. Letter to utility owners to identify facilities.
18. Notification of utilities of upcoming work.
19. One Call.
20. Potholing.
21. Preliminary survey.
22. Project communications with utility companies.
23. Reaching out to all utility companies to ask if impacted.
24. Records or maps.
25. Records, topographic survey.
26. SUE investigation is begun, and request is issued to utilities for redlines to include OOS utilities.
27. SUE investigations, when performed, and by information received from utility companies.
28. SUE investigations, permits, outreach.
29. SUE investigations, permits.
30. Surface features not claimed by locates—outreach to known utilities in the area and past permits.
31. Survey.
32. Survey and previous roadway plans.
33. Surveying.
34. This is not typically performed in this phase.
35. Through coordination with utilities and state One Call system and a review of existing permits within the area.
36. Through coordination with utilities and SUE investigations.

37. Through utility coordination processes.
38. Utility information requests/design locates.
39. When doing locates to map facilities.

Design Phase

Responses from 42 participants include the following:

1. Abandoned utilities are identified in field meetings with the utility owner.
2. All are called out in special provision.
3. Call Before You Dig.
4. Conducts a utility field inspection.
5. Coordination meetings.
6. Coordination with plan development with utility owners.
7. Coordination with utility owners.
8. For the most part, they are known from the survey so design can take place.
9. Marked during survey or utility brings up during coordination meetings.
10. Meetings.
11. More of the same but with utility clearance letters and some potholing.
12. Occasionally during test pits.
13. One Call/ SUE investigations (when used).
14. One Call/utility coordination.
15. OOS utilities should be identified during development of a utility conflict matrix.
16. Permit research, employee knowledge.
17. Potholing.
18. Pre-final plans are sent to utility companies for review.
19. Preliminary surveys.
20. Research continues through the design phase as deeper technical studies are analyzed. Test holes are initiated to locate utility lines more accurately. Risks involving utilities are added to a project risk register. Consistent communication efforts with utility owners continue.
21. Reviewing mapped utilities in the plan set.
22. Same as above—updated information.
23. Same as during planning.
24. Shown in plans if we know they are there.
25. Site visit, involvement of utilities in design review process.
26. SUE investigations and included on the design.
27. SUE investigations.
28. SUE investigations.
29. SUE investigations and utility records.
30. SUE investigations, in addition to communication with utility companies.
31. SUE or noted on plans.
32. SUE, utility markups, permits.
33. Surface features not claimed by locates—outreach to known utilities in the area and past permits.
34. Surveying, 811.
35. Through coordination with utilities and state One Call system and review of existing permits within the area.
36. Through coordination with utilities and SUE investigations.
37. Through utility coordination processes.

38. Utilities must clear conflict, use SUE and, in some cases, blue stakes.
39. Utility company inquiries, permit records, and coordination activities, possibly SUE investigations to locate.
40. Utility information requests, design locates, soft digs.
41. Verifications by utility provider.
42. When relocations are completed, show both the abandoned utility as well as its new location.

Construction Phase

Responses from 45 participants include the following:

1. Excavation.
2. 811 tickets.
3. 811 or open excavation.
4. Accidental location identified through local contacts.
5. Blue stakes, marking on plans.
6. Contractor can follow the standard plans, and he bids knowing about it.
7. Dig them up.
8. Digging into something that was not marked via 811 or shown in plans.
9. Discovery during road work—outreach to known utilities in the area.
10. During construction—excavation, test pits, or location service identifies an abandoned line.
11. Encountered or marked by company.
12. Excavation.
13. Excavation.
14. Excavation, locates, soft digs, oops.
15. Found by contractor during construction.
16. Having as-builts on hand to show the previous and current location of utilities.
17. Help identify when encountered.
18. If facilities were not located during the mapping phase, they would be discovered during construction.
19. In rare cases, the OOS utility is discovered in this phase. If discovered in this phase, most challenges are presented as well.
20. Known lines are surveyed and staked out. Any time that an unexpected pipe or line is uncovered, operations will cease until a proper investigation is completed.
21. Line locate process during construction.
22. Marked in the field, and it is not addressed in the project plan or special provisions.
23. Miss Dig One Call system and by discovery upon excavation.
24. One Call system notification.
25. One Call system, excavation.
26. OOS utilities are treated as an active service until the owner verifies it is out of service. The utility is expected to have removed the OOS utility prior to the construction phase or to have entered into an agreement with the DOT to have facilities removed by the DOT forces.
27. Physical disturbance.
28. Physically found.
29. Potholing, One Call system.
30. Potholing and accidentally running into them during excavation.

31. Preconstruction utility meeting to cover utility facilities and utility obligations and coordination during construction.
32. Reactively.
33. SUE investigations and being hit during excavation.
34. SUE investigations, locate requests.
35. Test holes.
36. The contractor uncovers a utility that we did not have identified, and then our staff contacts known companies to try and figure out who the owner is.
37. There are always surprises in construction.
38. Through physically finding utilities (either by location or digging them up.)
39. Typically, by mistake—the contractor encounters it while performing work.
40. Unidentified or incorrectly marked utility in the field.
41. Usually during excavation operations or test pits.
42. Utility relocation agreement, unexpectedly.
43. Visual identification of utilities in the field.
44. When calling 811 for locates or when digging.
45. Work with the DOT district personnel to manage risks.

Question 14. Please describe technologies or tools your department uses to aid in the identification of OOS utilities.

Responses from 12 participants include the following:

1. Arkansas One Call.
2. Excavated test holes.
3. Magnetic confirmation.
4. Potholing for identification.
5. SUE investigations that include the exposing of the facilities and the verification by the owner of the facilities that they are out of service. This occurs during the design and construction phase. If a facility has obtained the authorization to remain in place, the owner is required to respond to the contractor to verify its status. Calling Before You Dig helps to ensure a response by the utility along with contacts provided to the DOT during the design phase that are provided to the contractor and DOT crew to ensure participation by the utility.
6. SUE investigation.
7. SUE investigation.
8. SUE consultant roster and SUE procedures, internal online utility franchise/permit database to track all facilities and develop a conflict matrix, including OOS utilities.
9. Use best technology available using a third-party consultant. GPR, signal tracking, utility representatives.
10. Utility location contractors.
11. We use ground-penetrating devices to locate utilities, as well as calling in a locating service to mark out the approximate location of the lines.
12. We use SUE investigations when designing projects.

Question 15. Please describe your department’s procedure for identification and assessment of risks associated with OOS utilities.

Responses from eight participants include the following:

1. Alaska Utilities Manual.
2. Contact the facility owners to address.
3. Nothing specific to OOS utilities but they can be organized as a conflict in a utility conflict matrix.
4. Right-of-way coordinator and United States Infrastructure Company locates.
5. Starting with the project plans, followed by an 811 ticket, then multiple field visits and reviews.
6. Utility information requests, design locates, soft digs, project design re-evaluations, utility relocation plan re-evaluations, etc.
7. We have a general positive location procedure for locating utility lines, but I am not aware if there have even been specific procedures for OOS utilities.
8. We utilize the SUE investigations, field meetings with the impacted company, and design meetings to establish potential conflicts to find the resolution in coordination with the facility owner.

Question 16. Please further describe your department’s dedicated team or personnel responsible for addressing OOS utilities.

Responses from 21 participants include the following:

1. A utility coordinator is assigned to each capital improvement project, and they work with the project management team (including the project manager, other various support staff, and the design consultant), the utility company representatives, and the project construction team (including the project inspectors and construction contractor). The utility coordinator serves as the primary contact for all utility matters for their assigned projects, from identification of utility conflicts to resolution of utility conflicts.
2. Arkansas DOT utilities section.
3. District utility coordinators.
4. Each region for New York State DOT has a utility engineer to help deal with all utility issues.
5. Each region in the state has a utility coordinator.
6. Headquarters Division of Design, Office of Project Support, is the owner of Chapter 17 from the Project Development Procedures Manual, which lists policies for encroachments and utilities. The Division of Traffic Operations, Office of Encroachment Permits coordinates with the Division of Design, Office of Project Support to incorporate and then enforce these policies through the encroachment permit process.
7. New Mexico DOT has a utility section dedicated to solely to this activity.
8. Our local/regional office personnel address OOS utilities as they are identified.
9. Regional utility sections.
10. Right-of-Way Division-Utilities Section.
11. Right-of-way utility agents are assigned to projects to coordinate with the design team and throughout the project to completion and close out of all agreements with utility companies.
12. Right-of-way coordinator.
13. Statewide right-of-way permits engineer is responsible for addressing OOS utilities as Wisconsin DOT does not have a dedicated team.
14. This is our utilities team, and they handle all utilities on projects, not just OOS utilities. OOS utilities would be handled by the same team if it is discovered during the life of the project.

15. This would fall onto the region/district utilities office(s).
16. Utility coordinators.
17. Utility coordinators assist construction when encountered.
18. Utility permits section within the Office of Land Management.
19. We have a utility coordination team.
20. We have a utility section that handles permit tracking, utility moves, and OOS issues.
21. We have a utility section that provides utility coordination for all projects.

Question 17. How do you manage an OOS utility that is found during a highway project?

Planning Phase

Responses from 32 participants include the following:

1. Avoid/mitigate/accommodate.
2. Avoidance.
3. Conducts an advance utility inspection.
4. Contact owner, verify, remove if necessary.
5. Coordination with owner to verify location and contents.
6. Coordination with the utility owners.
7. Coordination with utility owner.
8. Design a locate to identify current utilities in the construction zone. Have utilities relocated.
9. District utility engineering groups identify and begin consultation with District Utilities Right-of-Way. Initial conversations with the utility are held. For lines shown on as-builts, District Right-of-Way Utilities searches for owners and gathers information about the line.
10. Document.
11. Generally, not found.
12. Identification of utility facility.
13. Identify.
14. Identify it.
15. If the owner is known, we work with them on the project development just as if they were in service. If the owner is unknown, we do our best to determine the owner.
16. Incorporate into capital project design plans.
17. It is not typical to discover utilities during this phase.
18. Locate and map it.
19. Not applicable.
20. Not applicable.
21. Nothing.
22. Outreach to known utilities and request involvement from them.
23. Plan to relocate either the roadway or the utility.
24. Planned removal where possible.
25. Request for facility information from the utility companies.
26. Research and coordinate with the company.
27. See response to earlier questions related to design.
28. Shown on project plans.
29. The project manager will reach out to the potential owner to determine a resolution.
30. UCPM 1805.03.

31. Unsure.
32. Work with the utility to relocate.

Design Phase

Responses from 34 participants include the following:

1. Add it to the permit log.
2. Ask utility companies to self-identify abandoned lines.
3. Attempt to determine owner.
4. Avoidance.
5. Check with utility companies (owner).
6. Conducts a utility field inspection.
7. Confirm if utility facilities can be avoided by the proposed capital project or confirm a utility relocation plan to eliminate the conflict.
8. Confirm that utilities have relocated, get as-builts from utilities and confirm that old utilities are dead.
9. Contact owner, verify, remove if necessary.
10. Coordinating with the utility and determining prior rights.
11. Coordination.
12. Coordination with owner to verify location and contents.
13. Coordination with the utility owners.
14. Coordination with utility owner.
15. Designed removal, or design avoidance where impractical to remove.
16. Determine plan of action.
17. District utility engineering works with utility companies to identify potential conflict areas and determine plan of action. Then they work with the design project engineer to determine design options for the project to avoid or remove OOS line. Project estimate may include additional contingency if there is a potential that an abandoned line may be discovered.
18. Document.
19. Have facility owner adequately protect or remove facility in advance of construction.
20. If it has been located and mapped, attempt to mitigate conflicts during design.
21. Include removal in utility relocation agreement if possible.
22. Mapping of existing utilities on our plans and review by the utility companies to ensure accuracy and items identified as active or out of service.
23. Not applicable.
24. Ongoing coordination during plan development.
25. Outreach to known utilities and request involvement from them.
26. Place roadway features in a way that least impacts existing utilities.
27. Put this information in a special provision.
28. Same as above.
29. See response to earlier questions.
30. The project manager/design team will reach out to the potential owner to determine resolution.
31. UCPM 1805.03.
32. Unsure.
33. We coordinate with the facility owner.

34. We would identify all utilities, including OOS facilities, during this phase as part of the plans, specifications, and estimates. OOS facilities would be managed like any other utility in conflict with the project.

Construction Phase

Responses from 41 participants include the following:

1. Assess impact to planned construction work. Consult with permit and design staff to determine ownership. Track additional contract work by construction contractor per standard specifications. Work with permit and design staff to coordinate efforts by utility if relocation is necessary.
2. Avoid or remove.
3. Calling them, documenting that they aren’t doing anything, documenting it is causing a delay, escalating who is howling for relief, eventually getting the utility to do its job, filing a claim with the utility who will ignore us until we get our attorneys involved, then they will argue and threaten while going around to the legislature to complain about how unfairly they are being treated/singled out, etc. Eventually wear everyone out without actually being accountable at all.
4. Change order, if not in the utility relocation agreement.
5. Confirm it is abandoned.
6. Confirm utility owner and schedule conflict resolution that minimizes project impacts.
7. Contact owner, verify, remove if necessary.
8. Contact utility section, determine owner, address the issue.
9. The contractor is aware of this in the standard plans and bids accordingly.
10. Coordinate between the contractor, the utility, and the DOT utility coordinator to determine what needs to be done, then issue a change order for the contract.
11. Coordination meetings with utility companies, DOT staff, and contractors to address unexpected impacts and time constraints for concurrent activities.
12. Coordination with owner to verify location and contents.
13. Find owner, discuss appropriate action—removal or abandonment.
14. Follow blue stake laws and coordinate with the utility.
15. Have district utility coordinator relocate before construction.
16. Identify type, coordinate with owner.
17. Line locate process during construction.
18. Look through permit system, contact utility owners.
19. Not applicable.
20. Ongoing coordination with the contractor to meet schedules.
21. Outreach to known utilities and request involvement from them.
22. Permits and use on construction revisions. Where possible, removal by roadway contractor.
23. Preconstruction meetings are held when the OOS utility owner is known. If an unknown line is found, then construction contacts the district utility engineering and right-of-way utilities units for help in determining the owner of the abandoned line. Work activities may be halted, or the crews may be moved to a different location.
24. Put together a team of electricians, engineers, etc.
25. Relocate either the utility or the conflicting roadway feature.
26. Removal.
27. Research old encroachment permits.
28. Same as above.

29. See response to earlier questions.
30. The project manager/construction management team will reach out to determine the best course of resolution.
31. The utility owner is responsible for cutting, purging, and capping pipelines, and the department will help if needed. The contractor will remove abandoned lines as needed.
32. This is out of my realm of expertise.
33. Try to identify the owner or former owner to assign cost responsibility. Coordinate heavily with contractor to mitigate risk (safety, environmental, cost) as much as possible.
34. Try to identify the owners of hit abandon lines.
35. Verify with Georgia System Operations Corporation and utility companies.
36. We coordinate with the facility owner.
37. When found, confirm with as-builts that it is a utility that has relocated, then tear out OOS utility if in the way of construction.
38. Work with DOT district personnel.
39. Work with facility owner to adequately protect or remove facility.
40. Work with the contractor and utility to devise a way to address.
41. Work with utility.

Question 18. How do you manage OOS utilities outside of an active highway construction project?

Responses from 38 participants include the following:

1. Aerial facilities must be removed from the Arkansas DOT right-of-way within 6 months; buried facilities must be as well unless written approval from Arkansas DOT is obtained. If not removed in accordance with the Arkansas DOT policy, it will be removed at the expense of the owner.
2. Avoid or remove.
3. Bring together appropriate staff to address and resolve any issues from the OOS facility.
4. Cancel abandon signs.
5. Construction program does not get involved with OOS outside the work zone.
6. Coordination with utility owner.
7. Do not know.
8. During maintenance activities, a local district utility supervisor will be contacted to discuss an OOS utility found on site. This will be coordinated to determine ownership, contents, and necessary removal.
9. Ensure the project is not going to encounter OOS facilities during the project.
10. I do not.
11. I have no need to manage utilities outside of highway projects.
12. If applicable, we keep a record of them in our utility database.
13. If they are known, designers coordinate with utility owners during the design phase of the project.
14. If we get involved, we will manage using the same process outlined previously.
15. Keep records if applicable.
16. Not applicable.
17. Our permitter will send and cancel the permit it pertained to.
18. Our permitting process (see link previously sent.)
19. Permits and active field inspections.
20. Permitting.

21. Personally, I do not. Contractors working to install new utilities generally let me know what they find.
22. Remove if possible.
23. Require removal for aerial abandonment. For underground utilities, require removal of abandoned facilities only when new facilities are requested and right-of-way space is limited. The utility is allowed to abandon in place where feasible.
24. Right-of-way construction permitting.
25. State law requires utilities to keep adequate records.
26. The maintenance team will deal with the OOS utilities on a case-by-case basis.
27. These are handled through the permitting process; however, we do not have a good method to update our permit records with OOS status.
28. They are issued permits, or they need to remove their facilities.
29. This is handled by another department—our municipal DOT or state DOT.
30. Through our utility permitting system, we try to manage the way the utilities are abandoned. There is no method for sharing this information with the design side of the agency.
31. Unknown—this is handled by our permitting office.
32. Unsure.
33. Unsure.
34. Unsure.
35. Utilizing the encroachment permits. Permits are amended to identify the OOS utility, or the facility is removed at the time it is taken out of service.
36. We do not.
37. We typically do not allow OOS facilities and request that the utility remove them in most cases.
38. We would rely on as-builts to manage any OOS utilities.

Question 19. Please describe the tools or procedures your department uses to track the status of OOS utilities.

Responses from nine participants include the following:

1. All encroachments within the right-of-way remain permitted until they are removed. These permits are reviewed during the planning and design phase of a project to allow for coordination with the owner of the facility.
2. Conflict matrix.
3. Internal franchise/permit database, developed by agency application development staff.
4. Permits.
5. Right-of-way permits.
6. SUE investigations of actually located OOS utilities, then these are data recorded.
7. The department has instituted a policy to develop a utility management matrix during the design phase and to acquire as-built information in electronic format from the utility companies to create a utility GIS database. Currently, we are experiencing setbacks with obtaining the as-built information since most utility companies are hesitant to share this data over privacy concerns, and some have required signed NDAs before the data are provided.
8. We use CityWorks (manual data entry, collection, and reporting for utility information), which also digitally retrieves associated project data from Primavera for inclusion in the

8. reporting. The reports are distributed to the project teams, the utilities, and other stakeholders to monitor project progression and/or critical needs.
9. Workflow software.

Question 21. Please describe your department’s experience with the repurpose of OOS utilities by other facilities.

Responses from 14 participants include the following:

1. Communication companies have amended permits to obtain ownership of conduits from electric or other communication companies.
2. Fiber placed inside old OOS natural gas lines.
3. If abandoned with no owner, Ohio DOT takes ownership of conduits for own purposes.
4. It does not happen often except for electrical conduit.
5. Permit office works with utility. If repurposed, two parties agree on who is responsible for what. When all is done, the abandoned utility is allowed to give up ownership and responsibility for mapping (only for the actual location).
6. Rather limited.
7. This is handled by our municipal DOT or real estate department.
8. Using old water main to run communication lines in.
9. Utilities retain ownership of OOS facilities. If they allow them to be repurposed, we will allow it.
10. Very, very rare. Only if suggested by a utility owner too. Typically, a utility elects to use an older casing for new communication lines, but this has occurred once or twice in my memory.
11. We do not direct utilities.
12. We do not really have experience with it but would allow it. It is not something we have really been approached about.
13. We have had a few gas companies that have repurposed OOS facilities as conduit for communications lines. These require a new permit.
14. With approval could be utilized.

Question 22. What improvements or additional measures could be implemented to enhance the management of OOS utilities in the right-of-way?

Responses from 32 participants include the following:

1. A legal requirement for the utilities’ timeliness to complete their utility facility relocations once notified by the municipality.
2. Adjusting state codes to require sharing of essential utility information with DOTs and stronger partnering meetings for better accommodation policy development. Devices that can more accurately locate subsurface utilities and capture location coordinates.
3. Awareness and clear procedure.
4. Better as-built plans by utilities/owners.
5. Better data tracking, consistent management across the state.
6. Better location identification, better planning on the utility owner’s part to replace or repair during construction.
7. Better recordkeeping.
8. Better requirements imposed by the FHWA and tracking.

9. Digital as-builts, better in-place surveying to verify bury depths.
10. Digital location collection and tracking software.
11. Documenting and tracking what is placed out of service. Keep track of location (i.e., as-built of x, y, and z), ownership, size, material, transmittant, time frame, and verification that it was properly purged (if applicable). It would also be helpful if there was something to help better locate the facility from the field, like a RFID marker or other identifiers.
12. Early identification, detailed location information, tracking, enforcement of removal by facility owner.
13. GIS locations.
14. GIS mapping of facilities, tracking of permits allowing OOS facilities to remain in place, agreements with facility owners for future cost responsibilities when an OOS facility is encountered during construction.
15. GIS positioning of all facilities with proper identification on a map.
16. Hiring a person to follow the utility negotiations from planning through design to construction.
17. Holding utilities more accountable for costs associated with their OOS facilities.
18. If utilities were held accountable even a little, it would incentive them to do a better job instead of relying on active construction projects to bump into their facility.
19. Maintain solid working relationship with utilities so that you are both always on the same page. Communication.
20. Owner and location incorporated in local and state GIS.
21. Practicing newer ASCE SUE standards.
22. Remove all utilities within a 6-foot depth when utilities are not in service.
23. Require all retired in place communication lines to be removed from site.
24. Require new utilities to have tracer wires. Require utility companies to provide tighter survey data and final review of installation with DOT personnel. Implement tighter restrictions and rules on the installation process. Have company pay for DOT inspector to be on project during installation on major projects.
25. Require x, y, and z and as-built data for utility facilities that are placed in the right-of-way.
26. South Dakota does not currently track OOS facilities in the public right-of-way.
27. The utility companies could provide the Kentucky Transportation Cabinet with information on OOS utilities.
28. Tools and software to track them.
29. Unknown.
30. Unsure.
31. We need to improve our permitting system to be able to update a permit record to show the facility to be out of service.
32. We need to manage the OOS utilities similar to the One Call system. The DOT could record and make available to the designers detailed information about abandoned utilities.

Question 23. Please describe your department’s practice or policy for preventing unauthorized abandonment of utilities in the right-of-way.

Responses from nine participants include the following:

1. Fines and permit restrictions are probably the best ones.

2. https://www.ardot.gov/wp-content/uploads/2020/09/Utility-Accommodation-Policy-effective-1-1-2012.pdf.
3. I do not know what the policy is, but I do believe we have one. This policy is managed by our utility section.
4. Kind of. If the municipality dictates that the utilities cannot abandon their facilities in place, they must remove them, but we do not often exercise this authority.
5. Permit restriction. This must be agreed upon by the department to allow it.
6. Permit restrictions.
7. See the previous link.
8. They are issued permits.
9. We require permits to install and abandon utilities on the right-of-way.

Question 24. Please describe how federal laws or regulations should be updated to improve the management of OOS utilities in the public right-of-way.

Responses from nine participants include the following:

1. Agencies need the ability to fine utility companies that do not remove or identify lines within a certain time frame. We also need the ability to charge delay claims when utilities provide false or bad information regarding location of utility.
2. Enforce that the utilities remove old underground lines that are no longer in service or, at the very least, be required to keep accurate records of the location and depth of these lines.
3. Have all retired in place lines be removed from sites.
4. Mandates and fines.
5. State DOTs may need help to encourage data sharing between utility owners and the DOT. Having accurate and up-to-date data would keep project costs down and allow for utility conflict resolution to begin at the initiation of the planning phase.
6. Stronger requirements and consequences would open the door to potential federal money to allow states to update their mapping, which would save FHWA funds during construction due to the unknowns that are currently being faced.
7. The utility lobbyists are tricky, so this would not be an easy feat. The laws/regulations would have to find the sweet spot between timeliness, approved utility costs, and approved municipal costs, and the utilities should be able to recover their approved relocation costs to accommodate public projects with adequate notice. Otherwise, the municipalities waste public funds waiting for the utilities to relocate their facilities. There is at least one state that already has similar legislation.
8. The utility section needs to update the requirements to meet any federal law changes.
9. Yes and no. Many states have state laws around utilities in the right-of-way that can complicate any federal action. As an industry, utilities are one of the most frustrating and complicated issues we experience in construction, which does add a layer of complication that should be simplified. It is the state’s right-of-way—utilities are there at their discretion (i.e., permit) and should be able to identify, move, or update as plans require.

Contractors and Consultants

Question 26. Please describe the constructability or other issues you experienced due to finding OOS utilities within the project limits of a highway project.

Responses from three participants include the following:

1. Just about every interaction with excavation and design professionals during both education and enforcement processes I am involved in turns into a gripe session on abandoned (OOS) and mismarked facilities by these stakeholders. Much, if not most, of these issues could be mitigated by the planning and design communities using the appropriate SUE processes in the preliminary and final design phases. The project engineer has the responsibility to perform the due diligence of accurately determining the existence of and accurate position (including elevation) of utilities and designing around those obstacles or making arrangements to reroute or remove those facilities. Doing this in the design phases minimizes the issues listed above for the project construction phase.
2. In one instance, we had a high-voltage line that was found to be out of service. The project impacted was a major bridge project and the high-voltage line presented a major safety concern with the sheet piles, which resulted in a month of roadway contractor downtime while working with the utility. After several on-site investigations, as well as permitting research, the line was found to be out of service. OOS fiber lines show up on projects throughout the state of Florida.
3. We had a special stormwater management facility that was being constructed that absolutely could not have any utility within its footprint.

Question 27. Please describe the issues you experienced with the removal of OOS utilities during highway project construction.

Responses from three participants include the following:

1. My role in the Pennsylvania One Call law enforcement hearings involves reviewing 40–80 cases where OOS and mismarked utilities are alleged each month as part of most cases. Damage reporting is mandatory in Pennsylvania. Each stakeholder is required to file a report when damage is done.
2. Same as previous response. The project was a design-build job.
3. This issue is common when multiple owners of facilities are using the same pole and/or conduit.

Question 28. What are successful strategies or practices to manage and resolve issues related to OOS utilities?

Responses from seven participants include the following:

1. Breakout projects to move utilities prior to the main contract, including relocations as part of the contract.
2. Early engagement with all stakeholders and using SUE investigations early to find OOS lines. Also, in Florida we have used services that combine public records research for

2. utilities along with satellite imagery and AI to find trench lines, which has uncovered OOS utilities on a major project.
3. Following the SUE processes that include four levels—D, C, B, and A—during the planning and design phases from the preliminary design and using the data collected to ensure the safe conclusion of the project.
4. If the One Call system has not determined an owner or a third party with maps to stake them, the contractor should be free to remove, cut, bypass, or do whatever is needed not to delay the schedule.
5. Involving right-of-way and utilities during predesign and preconstruction phases to identify, prioritize, and manage risk factors. Develop a partnership with utility entities in the early phases to ensure better project coordination within the right-of-way.
6. Not applicable.
7. When facilities are abandoned, the pipe needs to be removed from the ground as well.

Question 29. How are OOS utilities found during a highway project? Please describe.

Responses from seven participants include the following:

1. Collect data using the available observations of the intended route, requesting available records of facilities. Once that information is plotted and investigated, use nondestructive hydrovac excavation as the situation dictates and other available GPR technology to zero in on the facilities in the path of planned construction (exposing the obstacles in the proposed construction area) and plan accordingly to mitigate the utility conflicts. Then place the exact information on the construction drawings to allow for a more accurate bid and safe completion of the project.
2. Dig ticket responses.
3. GPR and calling 811 (call before digging). While working in the right-of-way, discovered OOS utilities that were not on current plans/drawings.
4. It is part of the early (pre–0 percent) utility coordination and through SUE investigations.
5. Most of the time in the excavation or boring stages.
6. Typically, during construction.
7. When digging.

Question 30. Please describe the technologies, practices, or tools that your company uses to aid in the identification and management of OOS utilities.

Responses from six participants include the following:

1. GPS (we used GPS at a construction site for Arkansas DOT during a bridge project).
2. Nondestructive excavation.
3. Previous response included AI and satellite images.
4. Pre–0 percent utility coordination process and SUE investigations.
5. Previous maps, or, if any, paperwork stating the abandonment.
6. Use ASCE 38-22 and record everything following the practices of 75-22. Pennsylvania law has required that sufficient SUE processes be followed, and that the data collected is supplied to the One Call system by the project owner at completion of their project since 2006 (update to Act 287 of 1974).

Question 31. How do you deal with an OOS utility that is found during a highway project?

Responses from six participants include the following:

1. Avoid, minimize, mitigate.
2. Remove, cut, or bypass.
3. Search historical permits. In Florida, our utility permits do not expire, and this step could have been missed. Also, our utility coordinators have local knowledge along with a constantly updated contact list to reach out to all utilities who are in a particular area.
4. Start asking questions as to what it is, when it was abandoned, and who did not remove the pipe.
5. Stop work for safety issues. Schedule a meeting with relevant staff/contractors to determine the next steps. Find a solution that minimizes the overall impact of the construction project.
6. SUE data collected can be used along with the as-built information in future projects.

Question 32. Please describe the standard or symbology that your company uses to depict OOS utilities in plans.

Responses from four participants include the following:

1. ASCE 38-02 (now 38-22) and 75-22 will improve. The One Call center has provided training on the use of SUE since the 2006 legislation. PUC Enforcement has issued violations for insufficient use of SUE engineering processes on several projects where failure has resulted in damage to facilities involved. The One Call center provides an online service called Coordinate PA that facilitates coordination, collaboration, notification/communication, cooperation, and documentation of the projects. Over 45,000 projects have made use of Coordinate PA since its inception in 2018. In April of 2023, the One Call board required all complex projects and designs to be entered online through Coordinate PA.
2. In Florida, our line types are provided by our CAD offices to ensure design plan consistency.
3. See Maryland DOT State Highway Administration’s CAD and drafting standards on the roads.maryland.gov website.
4. We use a colored marker not presently used by utility owners.

Question 34. Please describe how you have repurposed an OOS utility for use with an active utility.

The response from one participant includes the following:

1. Not yet, but it is part of our policy.

Question 35. What improvements or additional measures could be implemented to enhance the management of OOS utilities in the right-of-way?

Responses from six participants include the following:

1. Ensure the utilities remove any OOS facilities they abandon.
2. GPR along the right-of-way before any construction plans are drawn.
3. Involving right-of-way and utilities during predesign and preconstruction phases.
4. More utilities should be located in a GIS format.
5. Use all tools available to you.
6. Use of Coordinate PA in other states. Full coordination, collaboration, communication, and cooperation by all stakeholders on every project.

Utility Owners

Question 37. What regulations, policies, standards, manuals, practices, or procedure do you follow to manage abandoned facilities?

Responses from eight participants include the following:

1. 49 CFR 192.727.
2. American Petroleum Institute, Michigan codes, and Miss Dig. In Michigan, Miss Dig (811) keeps records of all OOS pipelines. Cannot rely on businesses as they change hands frequently and drawings of OOS utilities often get pitched, lost, or are poorly archived.
3. BICSI and Utah DOT.
4. PHMSA and digger laws.
5. Some states require abandoned facilities to be in One Call systems; we follow those state laws. We usually keep abandoned facilities in One Call even when not required by the state, but that is only for recently abandoned assets. Assets abandoned prior to 2000 are not well mapped and not generally included. We also follow the requirements of right-of-way holders (slurry fill, remove pipe, etc.).
6. State and federal hazardous liquid regulations and associated standards.
7. Texas Administrative Code Title 16, Chapter 8 and CFR 192, 195.
8. We have no abandoned pipelines.

Question 38. What are common causes or circumstances to place a utility out of service?

Responses from nine participants include the following:

1. I have yet to do so.
2. Installation of a new service line.
3. Lack of use, production facility abandoned, cost of upkeep, pipeline in poor condition due to age or if what was transported had been corrosive (i.e., water, bacteria, H₂S, wet CO₂, etc.).
4. No longer in use.
5. Nonfunctional. Again, we have no abandoned pipelines.
6. Pipeline is too costly to repair.
7. Placement of new utility to replace the old.
8. Plugging and abandonment of producing natural gas wells and facilities that supply gas to those pipelines.
9. Poor prior maintenance or installation practices that cause integrity issues where it is easier to abandon and replace the line than to continue to operate it. End of production

1. at a well or closure of a refinery where oil/gas transport from/to those areas is no longer required. Change in business climate where operating the pipeline becomes unprofitable.

Question 39. Please describe the dedicated team or personnel responsible for dealing with OOS utilities.

Responses from two participants include the following:

1. Two-man team for installation and removal, or we contract it out for bigger jobs.
2. It is one of the responsibilities of our compliance team.

Question 40. Please describe how you transferred ownership of the OOS utility.

The response from one participant includes the following:

1. Sold unused flow line to a company that wanted it for other purposes so they could consolidate multiple production facilities.

Question 42. Please describe how you track the information about OOS utilities.

Responses from four participants include the following:

1. In Michigan, the location of the retired assets must be filed with the state. We also retain the shape file in our GIS database.
2. Mapping system.
3. We keep the asset data in our GIS mapping system and keep the centerlines in the One Call system. Our land department also keeps copies of easements and other related agreements.
4. You cannot use out of service and abandoned interchangeably. In Texas, there is no such thing as out of service. Anything that is out of service or idle is treated the same as in service. Abandoned means it is permanently out of service and will never be used again. For OOS utilities, we track just like we do in service lines. They are in our GIS. For abandoned lines, we go over the right-of-way agreements for each piece of property the line crosses and we either remove it from the ground or completely clean it and let it rot in place. Abandoned lines are reported to the state each year just like all other pipelines. Other than reporting to the state, once a line is abandoned it no longer belongs to us.

Question 43. Please describe how you have repurposed an OOS utility for use with an active utility.

The response from one participant includes the following:

1. We have put abandoned natural gas gathering lines back into service as production lines or to transport different products, such as CO₂.

All Survey Respondents

Question 45. What is a best practice or lesson learned when dealing with OOS utilities in the right-of-way?

Responses from 39 participants are summarized in Table B-1.

Table B-1. Survey Responses to Question 45 by Stakeholder Type.

Question 48. Would you like to provide any additional comments regarding OOS utilities in the right-of-way?

Responses from 16 participants include the following:

1. A lot of OOS utilities in the right-of-way were abandoned many, many years ago without good documentation. Getting a good industry practice on how to properly abandon lines and how to manage abandoned lines going forward will be a good start, but we will always have to deal with legacy lines that were left in the ground and the operator/owner walked away so project managers also need a good playbook for how to deal with the unexpected line at any stage of the project.
2. APWA and CGA Best Practices Committees have been wrestling with this issue for many years. The owners and governments stakeholders must cooperate and fund the process of collecting and sharing the OOS data with project owners and their design and construction professionals for the betterment of all.
3. I do not have any additional comments at this time. Thank you!
4. Not applicable.
5. No.
6. No additional comments.
7. No thanks.
8. No.
9. No.
10. None at this time.
11. None at this time.
12. The survey was thorough but direct. One of the downfalls of surveys is they tend to get lengthy, so respondents either do not finish or rush to finish, which could skew your data. I liked how you provided respondents with the opportunity to provide comments and the ability to respond unsure. Not every answer is a yes/no response. For me, I appreciated how some questions allowed for interpretation (for me anyway). Everyone has a unique perspective when it comes to this topic.
13. This is becoming a growing problem. The power company is now installing distribution lines underground. They will age out in 30 years and start to become the next abandoned utility issue. Currently the right-of-way is littered with abandoned fiber. This is interfering with new builds.
14. Use Miss Dig (811) as the central resource of all underground facilities. Implement that buried utilities status/mapping be updated yearly. Encourage state and federal

14. government agencies to abide by the same rules and regulations as the private sector when soil disturbances will take place.
15. We have less than half a mile of pipeline that is in service. We have no OOS pipelines.
16. We need a lot of direction and help. We also need a specific set of laws that pertain to all agencies regarding all utilities in the right-of-way.