RCCAO proposes solutions to late locates


Residential and civil contractors propose six-point plan to speed up utility locates in Ontario

The Residential and Civil Construction Alliance of Ontario (RCCAO) and its stakeholders are calling on the province of Ontario to ensure utility locates are completed within a reasonable timeframe.

The RCCAO recently published a brief that outlines six measures to improve the Ontario One Call system. The brief was delivered to the offices of Premier Doug Ford and to the Minister of Government and Consumer Services, as well as 19 other Members of Provincial Parliament who are on the Standing Committee on Finance and Economic Affairs.

“Contractors across the province are trying to catch-up with the backlog caused by COVID-19 and this heightened activity has resulted in an increase in demand for utility locates in many municipalities,” said Andy Manahan, executive director of the RCCAO. 

“But this has been a chronic issue as contractors have complained for years that there are long delays for utilities such as gas companies and telecommunications firms to provide markings of where their underground services are located. In fact, a recent article in Ear to the Ground estimated that 85 per cent of all locate requests are late.”

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The brief, called Late Utility Locates: Ontario Construction Industry’s Priority Solutions, notes that most jurisdictions have a deadline of three days to respond to utility locate requests. In Ontario, however, the province has a legislated deadline of five business days. Over the years, the delivery of locates has been persistently late, with responses up to several weeks after the deadline has passed.

For example, From January to August in 2019, Ontario One Call received more than 800 formal late locate complaints. The previous year, more than 400 formal complaints were received in the same time period. These numbers do not include informal complaints received by Ontario One Call.  

The One Call system is mandatory through the Ontario Underground Infrastructure Notification System Act, 2012. To minimize the risk of severing a natural gas line, a water main and other underground infrastructure, it allows homeowners, construction contractors and other excavators to make one locate request to a call centre instead of separate calls to each utility. 

The RCCAO brief explains that governments recognize delivering infrastructure projects is an important element for the economic recovery, but contractors are still facing long delays waiting for utilities to provide locates. For larger projects where there are up to 10 different companies responding to a request, some of the locates expire by the time all the locates are received, necessitating a frustrating relocate request process.

“RCCAO, its member organizations and their respective unions and contractors are exercising their best efforts to deliver timely and cost-effective construction services,” the brief states. “Ontario needs significant improvement in the delivery of utility locate responses.”

Restructuring One Call 

The brief’s first recommendation calls upon the province to restructure the board of directors of Ontario One Call so that half of the 12 members are non-utility representatives such as excavators, municipalities and the provincial government. Currently, nine of the board members represent utility members. According to the RCCAO, this has created concerns that directors representing utilities are unwilling to prosecute their fellow utility companies. 

As the Ontario One Call board is comprised of a majority of utility company representatives, there is no incentive for these companies to levy fines against themselves for not following the legislated timelines, RCCAO claims.

Collaborative approach

RCCAO is also requesting that stakeholders and Ontario One Call work together to maximize the sharing of locate responses among contractors and subcontractors working on the same construction site. As it stands, multiple contractors bidding or working on a common construction project must each request their own locates.

Sharing locate information will likely reduce the workload of One Call members and the locating industry, which would reduce locate response backlogs. 

Extended validity 

All utilities, not solely gas distributors, should be encouraged to maximize the validity period of their locate tickets to at least 60 days, without impairing the health and safety of workers and the public, according to the RCCAO. 

Longer locate ticket validity periods will reduce the number of locate requests and likely the number or severity of late locates.


As well, the brief ask the province to consider allowing locate service providers to be prequalified to locate all utilities in order to prevent companies from contracting their locates to a single company. 

The existing model creates artificial market scarcity by limiting a particular utility locate to a single company over a wide geographic area.

Furthermore, a restructured One Call Board should establish a uniform rate schedule for providing locates, where the variance in rates is based on level of risk and difficulty and perhaps geographic region. 

Non-linear excavation 

The RCCAO also recommends the elimination of the need for further locates once a stationary vertical excavation has been dug below the depth of the lowest buried utility. This will lessen the burden on locate services and free up additional system capacity.

“Once a stationary excavation has dug below the depth of the lowest buried utility, there should be no further requirement for relocates,” the RCCAO brief states. “This reduction in demand will lessen the burden on locate services and free up additional system capacity.” 

Modified reporting

Finally, One Call and utilities should also be required to differentiate between single-address and multi-address locates, according to the brief. By modifying the reporting and record-keeping process, One Call could more easily identify problem areas related to the late delivery of locates and focus enforcement efforts.

“Ontario needs significant improvement in response times for the delivery of utility markings, especially if we are depending on construction to be a leading sector in our recovery efforts,” Manahan said. “Implementing our six-point plan will reduce locate wait times for contractors and have a substantial and positive impact on helping them deliver timely and cost-effective construction services.”

The brief isn’t the first report issued by RCCAO. In 2015, the association issued a report urging the provincial government to take action, but nothing was done. A major focus of the report was on the enforcement regime used in other jurisdictions so that there is greater compliance with the legislated timelines. RCCAO is also a member of the Ontario Regional Common Ground Alliance