A remarkable initiative within the Federal government in Canada to improve mapping of Federally regulated underground infrastructure and infrastructure on Federal lands was presented at the Ontario Regional Common Ground Alliance (ORCGA) 2020 Symposium in Ottawa. This initiative is being driven by Public Services and Procurement Canada (PSPC). It is intended to become a model for Federal agencies with real property assets such as PSPC, National Defense and Parks Canada, to implement damage prevention programs and Federal regulatory agencies including Transport Canada, Canada Energy Regulator and Innovation, and Science and Economic Development (ISED) to develop a damage prevention mandates.
Background
At the Ontario Regional Common Ground Alliance (ORCGA) 2020 meeting in Ottawa Mike Sullivan, President of the Canadian Common Ground Alliance (CCGA), provided an overview of the efforts at the federal level to implement federal damage prevention mandates. In 2012 the CCGA released a white paper, Damage Prevention Legislation Elements Required for Canada, articulating a series of principles and specific elements for effective legislation that would result in greater protection of underground infrastructure and community safety. In the same year Bill 8, the Ontario Underground Infrastructure Notification System Act 2012, was passed in the Ontario Legislature. In 2015 CSA Z247 the first Damage Prevention Standard in Canada was released. It describes the damage prevention process and elements would reduce damages to Canada's underground infrastructure improving public, worker and community safety and preserving the environment, It was sponsored by the National Energy Board, Natural Resources Canada, the Canadian Energy Pipeline Association and the Canadian Gas Association. In 2014 the Senate Standing Committee on Energy, the Environment, and Natural Resources completed two studies; Moving Energy Safely: A Study of the Safe Transport of Hydrocarbons by Pipelines, Takers and Railcars and Digging Safely - One Call Notification Systems and the Prevention of Damage to Canada's Buried Infrastructure. The Senate Standing Committee followed this with specific recommendations;
1 That the federal government reference the CSA Z247 standard for protection and prevention of damage to buried infrastructure and encourage provinces and territories to reference the standard in legislation.
2 That buried facilities on federal land be registered with a provincial or territorial one-call services and that the federal government require anyone undertaking excavation on federal land to call the local one-call centre.
3 That the federal government require all owners of federally regulated buried infrastructure to become members of a provincial or territorial one-call service.
In its 2016 report on the state of our knowledge about the location of underground infrastructure in Canada, the Professional Surveyors Canada working group concluded that underground infrastructure in Canada is often not surveyed or mapped accurately, if at all. Currently the systems in Canada dealing with underground infrastructure are a patchwork of regulatory and voluntary regimes. They range from the City of Edmonton which maintains a database of underground infrastructure and the City of Calgary that mandates that information about underground infrastructure be shared among utilities and communications firms operating within city limits, through to one-call centres operating in the provinces of British Columbia, Alberta, Saskatchewan, Ontario and Quebec, and others.
The Professional Surveyors Canada working group is very clear about the problems with the current regulatory regimes and business practices in Canada; creates loss of use situations to critical infrastructure such as telecommunications; creates hazards for workers; creates inefficiencies in locates for customers; reduces efficiencies and productivity of one call systems; increases cost for new development; increases cost for each new installation of underground infrastructure; greatly increases the amount of redundant locates being done; increases risk to the public; and increases risk to the environment.
Several provinces have on call centres similar to many states in the U.S. Howerer, there are some significant differences. In Ontario a utility operator is required to mark on the ground the location of its underground infrastructure and provide a written document containing information describing the location of the underground infrastructure. This differs from many state one-call centres in the U.S. where a written document is not required.
British Columbia is the only jurisdiction in North America that I know of where it is not mandatory for each member (network operator) identified by the one call centre to visit the site of a proposed excavation. In response to a request from British Columbia One Call, within three business days each network operator is required either (1) provide plans (paper or digitally, typically a PDF or paper) of their underground services showing the location of their facilities on or near the excavation site or (2) visit the site to physically mark the location of their facilities, or (3) provide digging instructions and other safety information. This can be very efficient for network operators because, similar to the Flanders KLIP and Dutch KLIC systems, it is not mandatory for each network operator maintain a large fleet of locate vans to visit the sites of all proposed excavations. On the other hand, it puts the onus on the excavator for validating the information provided on paper or digitally by network operators by an onsite locate.
At the federal level Senate Bill S-229, which was introduced in 2015 and passed third reading in the Senate in May 2017, aimed to create a notification mechanism for underground infrastructure on federal lands and for federally regulated underground infrastructure. It would have required that federal agencies register with provincial or territorial one-call centres and develop the capacity to respond to requests for information from one-call centres. Furthermore it would have required that federal regulators of buried infrastructure to develop a damage prevention mandate. But at the time, there was not an appetite in the Government to act on this bill and it died on the order sheet in the House of Commons and never became law.
Initiative to implement the spirit of S-229 in the Federal government
However, it turns out that the objectives of S-229 did not die there. At the Ontario Regional Common Ground Alliance (ORCGA) meeting Ravi Sundararaj, who is leading a Protection of Underground Infrastructure initiative in the Public Services and Procurement Canada (PSPC), provided an overview of many of the provisions of S-229 are actually being implemented by PSPC. Two years ago the Minister of Public Services and Procurement (PSPC) decided to implement the provisions of S-229. PSPC is responsible for all infrastructure on Federal land and saw this as a way of doing a better job at what it is mandated to do.
The plan was for the PSPC implementation to become a model for other government departments which would see the benefits of this approach to reducing damage to underground utilities and implements similar measures. There are about a hundred departments and agencies in the Federal government, of which 23 are custodians of real property assets. PSPC, National Defense and Parks Canada are the largest.
Under this initiative implementing protection for buried assets through the existing operational framework for federal custodial assets requires that buried assets on federal land be registered with a provincial or territorial one-call services; and that the federal government require anyone undertaking construction or excavation on federal land to call the local one-call or damage prevention service. Secondly, the federal government requires all owners of federally regulated buried infrastructure become members of a provincial or territorial one-call or damage prevention service.
To be able to respond to request for information requires the Federal government to develop and maintain maps of its underground infrastructure through its Geomatics capacity. To do that requires determining what information it intends to share taking into consideration Government of Canada security requirements.
The first stage of the PSPC initiative is the National Capital Area (NCA). It requires first of all compiling maps of existing Federal underground infrastructure enabling the government to respond to information requests. Secondly it requires that Federal agencies and owners of Federally regulated infrastructure to register with provincial and territorial one-call centres. In the case of the initial NCA project this means registering with Ontario One Call.
When Ontario One Call receives a request for information about underground utilities for a proposed excavation, PSPC as the custodian is notified. In the case of a proposed excavation PSPC then does one of the following
- Provides a digital or paper map of underground infrastructure in the area of the proposed excavation
- Carries out a subsurface survey and marks the ground
- Confirms that there is no infrastructure in the area
In the case of a request relating to a planning activity PSPC sprovide a digital or paper map of underground infrastructure in the area of the proposed excavation or confirms that there is no known infrastructure in the area. It is interesting that this process requires that if information about the underground infrastructure in the area is missing or incomplete, the PSPC is required to conduct a subsurface survey of the area with the resulting map provided to the Federal Geomatics site. This enables PSPC to respond with accurate maps of the area the next time an information request as received. Over time this process would lead to comprehensive geospatial data on underground infrastructure on the Federal Geospatial site.
The immediate goal is to develop a PSPC Directive, Standard and Guidelines for the protection of underground infrastructure. This requires engaging with provincial and territorial one call centres, developing the capability to respond to requests for information, and developing business processes to improve the accuracy, timeliness, and comprehensiveness of the data about underground infrastructure that is maintained by the Federal Geomatics group.
The longer term goal is for Treasury Board to encourage custodians of real property asets assets such as National Defense and Parks Canada, as well as regulatory agencies including Transport Canada, Canada Energy Regulator and Innovation, Science and Economic Development (ISED) to adopt similar policies so that this approach to damage prevention becomes pervasive in the Federal government.
This is an important initiative that provides a model for other Federal departments, agencies, and regulatory bodies. As a federal initiative it also provides a model for provincial, territorial and municipal governments, and regulatory agencies and network operators. Perhaps more importantly it signals just how important this is for public safety and for the Canadian economy.
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