Grant Piraine,
Feb 2, 2026
For more than three decades, I have worked in the private locate lane of the underground utility industry. Over that time, I have stood on countless sites where contractors were prepared to break ground, looked at me, and asked a simple question: Are we clear to dig?
In many of those cases, this was before Subsurface Utility Engineering (SUE) was widely understood, and even after it became established, it had not been performed. Records were incomplete, outdated, or unavailable. Public locates addressed only utility-owned public infrastructure and stopped at the demarcation point on private property. Yet drilling or excavation was scheduled for that same morning, and the expectation was that my private locate company would “clear the area” and make it safe.
It did not take long in my career to recognize a pattern. The issue was rarely incompetence in the field. The issue was structural. By the time a private locator is engaged, critical upstream decisions have already been made. In the vast majority of projects, a SUE study had not been commissioned. Sometimes our clients gathered reliable utility records. More often they did not. When those early ground disturbance lifecycle steps are skipped, the uncertainty created at the design stage does not disappear. It is carried forward and ultimately encountered during ground disturbance, where the physical risk is highest.
The Three Operational Lanes
Across North America, subsurface utility risk management operates within three distinct lanes.
Subsurface Utility Engineering manages underground uncertainty during design. Through structured quality levels, SUE provides increasing confidence in subsurface information, allowing design teams to reduce risk before construction begins. When used appropriately, it is one of the most effective risk management tools available. Every time we were handed a proper SUE study before mobilizing to site, our reaction in the office was the same: Hallelujah! It meant the project had been structured correctly at the beginning instead of leaving uncertainty to be sorted out in the field.
Public locate systems manage notification and response for publicly owned buried utility infrastructure. There are regulatory systems designed for One Call and 811 centers to facilitate communication between excavators and public utility owners. They are not design-phase investigation tools, and in most regions they not comprehensive subsurface verification systems.
Locating privately owned facilities typically occurs shortly before ground disturbance on private property and across projects of all sizes. Large scale projects rarely have SUE studies to rely on, and on small and mid sized projects, which represent the majority of real world ground disturbance activity, SUE is virtually nonexistent. In these circumstances, private locating becomes the dominant operational control mechanism. Private locate contractors are also used by ground disturbance professionals to verify public locates that have been marked within the work area. This is the lane I have worked in for over thirty years, and it is the lane where uncertainty is either managed responsibly or encountered physically.
These lanes are not competitors. They serve different functions. The problem is that they are rarely integrated within a coherent lifecycle framework.
The Lifecycle Gap
Every project begins with a decision, whether deliberate or implied, about how subsurface risk will be managed. When a SUE study is performed, uncertainty is investigated early, design can adapt, and residual risk is better understood before construction contracts are executed.
When SUE is not performed, that uncertainty remains embedded in the project. It progresses into procurement, where contract language often attempts to allocate liability downstream. It surfaces in clauses assigning responsibility for unknown conditions to contractors or drillers. It becomes an operational issue during construction, where those same parties are expected to execute work within compressed timelines and incomplete information.
These lanes are not competitors. They serve different functions within the same project lifecycle. The problem is not that they exist separately. The problem is that they are rarely integrated within a coherent and deliberate lifecycle framework, which is where risk begins to shift instead of being properly managed.
Private Locators as the Final Risk Control Checkpoint
On most projects have not had a proper SUE study performed, private locators effectively perform a form of lifecycle gap analysis. We assess what investigative steps were taken and, just as importantly, which were omitted. We verify public locates where applicable. We request and review available records, recognizing their limitations. We perform field detection and correlation using appropriate technologies. We document constraints, define scope boundaries, and communicate residual uncertainty before ground disturbance begins.
In many cases, we assign a structured level of risk based on the information available and the complexity of the site. That risk is not theoretical. It reveals itself through the limitations encountered during the locate process. Those limitations can include incomplete records, inaccessible areas, signal interference, unknown private infrastructure, site conditions that restrict detection, or design information that was never developed. Most contractors assume our equipment can simply “find everything” beneath the surface. The reality is far more methodical. Locating is a process of investigation, correlation, interpretation, and documentation. It produces a defined level of confidence, not absolute certainty.
For years, those risk levels existed in practice but were never formally defined. They were implied through experience and communicated informally through conversations and disclaimers. Yet they directly influence decisions about excavation methods, verification requirements, scheduling, and the allocation of responsibility between project owner and contractor. SUE formalized this concept through engineering standards that defined structured quality levels for subsurface utility information, bringing clarity and consistency to design phase risk management.
Despite operating at the highest exposure phase of any project, the lane that private locators have worked in has lacked any unified standards. Practices vary significantly between firms. Some private locators rigorously document limitations and clearly communicate risk. Others operate informally, relying on habit rather than structure. Some accept liability beyond what is reasonable given the information available. Some project owners assume that a locate provides certainty, when in reality it provides a defined and measurable level of confidence. Private locate contractor marketing claims that suggest a private locate will “show everything that is buried” reinforce this misunderstanding. Statements of absolute certainty not only create unrealistic expectations, they also expand liability exposure and contribute to a false sense of security among ground disturbance contractors and project owners.
The excavation community responds to utility infrastructure uncertainty in different ways. Some contractors attempt to transfer responsibility back onto the private locator, and when a dispute arises, simply move on to the next firm willing to accept broader risk. Others begin to understand that effective locating requires more than a same-day mobilization. They recognize the need for records, site access, interviews with knowledgeable personnel, and adequate time to investigate properly. Still others, often after experiencing a significant damage event or claim, default to conservative excavation practices such as extensive hand digging or vacuum excavation because they no longer trust that upstream risk has been properly managed.
In many cases, this shift toward risk aversion happens reactively. It occurs after a serious incident, a costly claim, or internal scrutiny from insurers or senior management. Larger organizations with established health and safety structures tend to arrive at this realization sooner, but even then, the mitigation often occurs at the ground disturbance phase rather than at the design or planning stage where risk is least expensive to address.
The pattern is consistent. When subsurface risk is not structured early, it is either disputed, transferred, or mitigated at the last possible moment.
Without standards, risk allocation becomes inconsistent and often unfair. The same level of subsurface uncertainty can be treated very differently depending on who is involved, and that inconsistency is precisely what NAPUA was created to address.
Why NAPUA Is Necessary
NAPUA was not created to replace Subsurface Utility Engineering, nor was it created to compete with public utility locate systems. It was created to formalize the operational lane that exists regardless of project size, budget, or jurisdiction.
NAPUA establishes a standardized lifecycle gap analysis before ground disturbance begins. It defines how subsurface risk should be identified, classified, documented, communicated, and appropriately assigned when earlier lifecycle steps are incomplete or absent. It recognizes that most ground disturbance projects proceed without SUE and that in those cases, structured governance at the operational phase is not optional. It is essential.
For too long, private locating has been treated as a form of insurance rather than as a defined professional service operating within clear scope boundaries. A locate does not eliminate risk. It identifies and classifies it based on available information, site conditions, and investigative methods. When uncertainty exists, it must be acknowledged, documented, and assigned appropriately. The private locator is not a backstop for upstream decisions, nor an indemnity layer for incomplete design or inadequate coordination.
By formalizing best practices for private property ground disturbance, NAPUA levels the field for private locators, clarifies responsibility for asset owners, and provides contractors with a defensible framework grounded in due diligence rather than assumption. It integrates public locate systems, SUE, and private locating into a coherent lifecycle model instead of treating them as isolated silos.
Ground disturbance is the only phase of a project where buried utility infrastructure can be physically contacted or damaged. It deserves governance and standards equal in seriousness to design-phase engineering.
After thirty-six years in this industry, the need for this structure has become impossible to ignore. NAPUA exists to provide it.
Official Release: NAPUA Lifecycle Model Foundation Framework 1.0
To formalize this structure, NAPUA has published the NAPUA Lifecycle Model Foundation Framework 1.0 – 2026 Edition.
This document establishes:
The three sequential lanes of subsurface risk management
The definition and implications of lifecycle gaps
The structural requirement to identify and document limitations
The obligation to translate unresolved limitations into structured risk classification prior to ground disturbance
Operational responsibility principles at the point of highest physical exposure
The Foundation Framework serves as the governing document for NAPUA Best Practices and companion Guidelines.
The full document is now available. Click this link to download the file.
© North American Private Utility Association, 2026. This framework may not be reproduced without written permission.