Page 17 - West Virgina 811 Magazine 2022 Issue 3
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Standardize the ticket size, distance, duration, and life to the described char- acteristics. A national standard supports and vastly improve efficiency through- out the utility locate and damage prevention process. Standardizing four basic elements of a notification request opens the possibility to complete robust analysis, build continuous improve- ment into the system, and simplify training and education programs. The four elements of notification and ticket standardization:
1. 3 working day notification time (addressed in Standardize Minimum Notification Time recommendation above)
2. 30 calendar day ticket duration
3. Ticket type: a. Standard* b. Complex* c. Design
4. Ticket size limit:
a. Standard urban = 1,000 LF
b. Standard rural = 2,500 LF
c. Complex = joint meet, 5 working days clear
d. Design = joint meet, 10 working days clear
* Standard and Complex tickets are limited to one (1) refresh before a new notification is required.
Solution Summary – Brings consis- tency to the notification process and ticket elements, balancing reasonable notification time for locators with ticket size and ticket life preferences. Creates an opportunity for locators to plan
and resource level effectively, raising the likelihood of successful damage prevention and profit generation. In addition, the standardization stream- lines locator, excavator and stakeholder education and training.
West Virginia Summary Conclusions Overall, West Virginia is ranked in the 2nd Quartile of states in the design and implementation of its utility locate and damage prevention process and achieves adequate performance as measured by CGA’s DIRT Report, IPC, and stakeholders. Areas highlighted
and contributing to this performance include:
1. Adjudication Process Well De- fined:
a. The damage adjudication process through the West Virginia Under- ground Facilities Damage Prevention Board (WVDPB) is robust specifically due to its inclusion of excavator, utili- ty, and regulatory representation and its independence from the PUC.
b. The West Virginia damage adjudi- cation process is consistent with the industry average in terms of days and the number of steps required in the process.
2. Mediocre Dig Law:
a. Positive response is required to the excavator, but not the 811 center.
b. Not all system operators are re- quired to be members of 811 in West Virginia, creating opportunity for unmarked facilities and damages.
c. Ticket life is undefined in WV as long as excavation begins within 10 days and the marks remain visible.
d. The 2018 dig law revision im- proved the nature and structure of the dig law through the creation of the Underground Damage Prevention Fund, the Underground Facilities Damage Prevention Board (WVDPB), expanding required membership of the one-call system, among other improvements.
3. Stakeholder Satisfaction with 811 System
a. West Virginia stakeholders are sat- isfied with enforcement, regulation & law, and the 811 notification process structure. The 811-performance met- rics was the lone characteristic where dissatisfaction was described.
b. The WV 811 process is 2 steps lon- ger than the average across states and is likely less efficient than the indus- try average in terms of the number of days required.
c. The frequency of unneeded locate requests and extensive contractor wait time are rated as occurring daily and fall into the 4th Quartile.
4. Unknown 811 Board Composition:
a. The 811 board is made up of 19 elected members originating from three groups, 1) seven (7) at-large Directors; 2) 11 Charter Member Directors; and one (1) Associate Member Director. The composition of this group by firm type is unknown.
5. 2014, 2019, and 2020 PHMSA As- sessments:
a. 2014 PHMSA Statewide Damage Prevention Programs Assessment
– some elements were rated as “Program Element Partially Imple- mented/Not Fully Developed.”, and Elements 6 and 7 were rates as “Pro- gram Element Not Implemented”.
b. 2019 PHMSA Gas State Program Evaluation – rating of 93.6 out of
100. Points deducted from “Program Performance” section.
c. 2020 PHMSA State Damage Prevention Enforcement Program Assessment - rating of “qualified adequate.” The following topics were highlighted:
i. No enforcement occurred in 2019 because the newly formed enforce- ment program was not yet in effect. There was a total of five enforcement actions taken in all of 2020 (three civil penalties and two warning letters). PHMSA also noted that of the 278 damages reported by gas distribution operators for CY 2019 in the PHM- SA annual reports, 70 (25%) were attributed to operators for not having complied with their responsibilities in accordance with West Virginia’s one-call law. PHMSA encouraged the Board to work closely with the West Virginia Public Service Commission to continuously improve the State’s one-call enforcement program.
Publisher’s observation: A consider- able amount of progress has been made in West Virginia and the PHMSA audit reflects the progress with the rating of “adequate.” Stakeholders should be proud of the accomplishments made over the past few years. In the spirit of continuous improvement, any pro- gram can become stronger and more effective. Certainly, that is the case in West Virginia. As stakeholders look
at the recommendations, it is possible that these are some of the same ideas you’ve had in the past. So how do we go about making those changes?
The changes don’t happen because of the recommendations. The changes occur because we decide to make the changes and that requires coming to- gether in the spirit of trust and respect. What’s next, West Virginia?
2022, Issue 3
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