In the world of underground utility detection, a troubling trend is emerging. The line between private utility locating and Subsurface Utility Engineering (SUE) is being blurred, potentially compromising public safety and professional integrity.

The Core Issue

An increasing number of firms in the U.S. are providing utility locating, mapping, and modeling services without proper engineering or surveying licenses. While they're essentially performing private utility locating, these companies are presenting their services in a manner that closely mimics SUE, without explicitly calling it such.

Education Gap and Accountability Void

One of the most glaring issues is the lack of client education. Often, clients think they understand techniques like Ground Penetrating Radar (GPR), but it’s a nuanced tool that detects only 10-20% of utilities. When companies oversell GPR as a "magic wand" that can find everything, it misleads clients, devalues professional services, and creates a false sense of security. This is especially concerning because GPR's effectiveness can vary dramatically based on soil conditions, utility depth, and other factors.

The lack of a major licensure program for utility locating (beyond NULCA and Mike Parilac’s initiative) creates an accountability vacuum. One of the defining elements of SUE is the verification and documentation process, often done by certified engineers or professionals trained in civil or geotechnical engineering. Private locators mimicking SUE do not have this independent verification process , making the data they provide less reliable. The question of who is legally responsible for the utility drawings, and deliverables is at the core of this issue and I think it’s worth pausing to think about how you present your data to your client and how transparent you are about the limits of the technology used to make it.

Technology: A Double-Edged Sword

Some firms use sub-meter GNSS devices with 3-6 foot tolerances, passing this off as design-grade accuracy. Others employ UAV systems, geophysics for void detection, and surveying equipment, all while claiming they're not conducting professional engineering or surveying practices. This is creating confusion and obfuscating the line between locators and engineers. Customers who believe they're receiving a SUE-level survey, are being misled by similar technology and terminology, but actually getting a private locate, face potential confusion, legal complications, and heightened risks. Services in this industry should be clearly and accurately labeled for what they truly are. SUE is a rigorous, quality-driven process overseen by certified professional engineers. It involves comprehensive utility identification, including records research, site reconnaissance, and geophysical investigations. Private utility locating, while valuable, doesn't meet the same standards or carry the same legal liabilities. That doesn’t mean that private locating isn’t useful, but it means that we customers should know the difference.

Furthermore, the SUE Association hasn’t done enough to regulate who can perform investigations or to standardize these practices in civil engineering specs. Although the 38-22 standard has been around since 2002, it’s still mainly used for Department of Transportation (DOT) projects. For larger construction sites, a 38-22 investigation should be required to ensure a higher level of diligence. The tendency of civil engineers to focus on potholing rather than a more comprehensive site investigation also limits the depth of analysis.

The CGA and QA/QC Standards

The Common Ground Alliance (CGA) plays a vital role in promoting safety and reducing utility strikes, but there’s an argument to be made that the CGA should push for higher QA/QC standards among both private and public locating firms. Too often, contractors opt for cheaper, lower-quality investigations, undermining long-term value and increasing risks. Higher industry standards and more stringent QA/QC programs would not only improve safety but also elevate the credibility of the utility locating industry as a whole. I haven’t seen a good argument against adopting a standard practice that has an ROI other than the economics of it.

The Risks

When companies misrepresent private locating as SUE-equivalent work, they risk:

1. Providing incomplete or inaccurate utility information

2. Increasing the likelihood of utility strikes

3. Causing project delays and cost overruns

4. Creating potential legal liabilities

Moreover, this practice undermines the value of genuine SUE services and the professionals who provide them.

The Way Forward

Addressing this issue requires:

1. Better client education about the differences between private locating and SUE

2. Clearer, enforceable industry standards

3. More active regulatory oversight by state engineering boards

4. Higher standards of transparency from utility locating service providers

While there's sympathy for companies seeking competitive advantages, when it comes to critical infrastructure and public safety, we must operate on solid ground. The utility locating industry needs to find a balance between innovation and maintaining professional standards and accountability.

In the end, whether you're a project manager, a contractor, or a concerned citizen, this issue matters. We all have a vested interest in ensuring that utility locating is done right - keeping our infrastructure intact and our communities safe.