California board releases draft rules to tighten GIS mapping and accuracy for subsurface installations

The California Underground Safety Board on July 15 presented draft regulations to implement the statute requiring operators to map subsurface installations using geographic information system (GIS) records and proposed specific accuracy, attribute and metadata standards for those records. Board staff said the draft would implement the law’s GIS provision by defining which installations qualify as new and by setting minimum horizontal-accuracy and metadata requirements, then open the draft for public comment. "This item builds on direction provided by the board at the April 2025 meeting," staff presenter Brennaman said in opening remarks. Why it matters: Board staff said clearer definitions and minimum accuracy will standardize what operators must collect and keep so excavators and emergency crews have reliable data when exposing or working near underground facilities. The draft ties the requirement to a date-based statute staff described as effective 01/01/2023, and includes a new definition of “new subsurface installation” that would require additions to operators’ GIS records when an installation is a new location or when certain relocation, replacement, rehabilitation, major modification or major repair work occurs. Routine inspections and maintenance would be excluded as "minor." Key elements in the draft: Staff described three main regulatory areas: accuracy of geospatial coordinates, GIS data content and metadata storage. The draft defines geospatial coordinates as longitude and latitude reported to a decimal format and proposes a horizontal conditional accuracy requirement that staff said would require handheld or field geospatial equipment to collect locations to roughly 100 millimeters (about 4 inches). The accuracy requirement was described as applying to all installation methods, including trenchless techniques. On data content, the draft would require facility records when installations include tracer wire/tape, RFID devices or other locating devices, and would require attribute records for items such as pipe wrap, coating and warning tape when present. The metadata requirement would obligate operators to store the date of data collection, the equipment used, the collecting organization’s name and related notes with coordinates. Public comment and stakeholder feedback: Staff reported results of a June email survey of operators (three respondents: a large telecommunications company, a small municipality and a contractor). All three already map certain installations using GIS; only one collects the full range of proposed metadata and the single operator reported a nominal minimum accuracy near 36 inches under current practice. Stakeholders at the meeting urged precision in the regulatory text and clearer, nontechnical titles. James Wingate of USA North 811 recommended changing the decimal-place language to reflect precision needed to reach about 4 inches, and noted a mismatch between “two decimal places” and the intended accuracy. Mike Donlen of MP Safety Service urged simplifying titles and plain-language definitions so that contractors with limited technical background can comply. Board direction: Staff recommended opening a formal public-comment period for the draft regulations. Several board members and industry speakers voiced support for publishing the draft for comment while seeking clarity and practical flexibility on metrics such as the 100-millimeter target and how legacy records will be handled. The board did not take a formal vote on the GIS draft during the session; staff was directed to proceed with public outreach and incorporate stakeholder feedback. What remains open: Stakeholders and board members asked how legacy records, multiple mapping systems and differing operator practices will be reconciled. The draft leaves implementation details — repository responsibilities, who maintains consolidated records and how to treat legacy/as-built drawings — for further public input and staff follow-up.