Guidance notes for the NUAR Consultation

Our view on this project is well documented and recent articles are available on the LSBUD website here:  lsbud.co.uk/linesearchbeforeudig-news/. The key issues with the project are that: 

• The Business Case is erroneous and will not deliver the benefits promised. The NUAR Team have even used data that we have collected, misunderstood it and then used it as justification to spend tens of millions of taxpayer money. 
• The NUAR Team have had a solution in mind from the inception of the project and have consistently worked to find justification for this solution, rather than properly understand why current processes work, and build on that for the good of all working across the industry. 

• Despite us at LSBUD having an unrivalled position as the nation’s safe digging platform, with over 1 million kilometres of utilities protected, hundreds of thousands of users and over 3.5 million enquiries per annum, our knowledge, experience and understanding has been consistently shunned and our existence ignored. 

We would therefore recommend extreme caution when responding to this consultation request, as it appears to have been designed to ensure support for a pre-empted solution of what the NUAR Team believe is needed, rather than what works for the industry and all stakeholders.  For example, they already admit that they are planning to force participation through legislation but ask a seemingly innocuous question to gather support for that. 

We strongly recommend that you respond to the consultation but urge you to do so with full knowledge of the scope of NUAR, so that your views are known and properly informed. With this in mind, we hope the below is helpful for you.  

If you have any questions or concerns, please do not hesitate to contact us via enquiries@lsbud.co.uk.

Questions 

Q1: Approximately how much does it cost your organisation to provide data on the location of underground assets each month 

Please provide any further detail to your answer, including time requirements, number and type of staff involved, and any other impacts. 

This can be answered from either perspective;  

• those undertaking works and needing to collate information to provide to their teams; and/or  
• those who own assets and provide information to third parties.   

In the NUAR scope we believe the latter is what is meant. 

It is therefore extremely important to solely focus on the “base cost” of providing data without including costs for other processes and services such as: 

• the customer support behind it to help third parties understand the information provided 
• escalation processes 
• any site supervision or support
• the updating of information 
• industry engagement and awareness campaigns. 

We suspect that information provided here will be used to justify the costs that NUAR will charge asset owners and users.   

We strongly suspect that quoting high values here could lead to high costs of NUAR in the future. 

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Q2: Approximately how many organisations do you contact in order to get access to a complete dataset of underground infrastructure on average per project? 

Please provide any further detail to your answer including the number and type of staff involved. 

The answers to this will vary significantly.  LSBUD gives everyone in the country free to use easy access to over 100 asset owners’ information.   

We know that many people just use the LSBUD search results and then cherry-pick the other key asset owners such as BT/Virgin Media etc. that are likely to have assets in the vicinity but not yet Members of LSBUD. Very few ‘complete the search’ for every project (although the NUAR Business Case assumes that they do). 

We suspect that the information provided here is designed to help justify the potential efficiency savings that NUAR is supposed to bring.  By saying that users only have to contact one point rather than tens or hundreds, it will help justify significant project costs and charges to those using the service in future.   

We strongly recommend that people state what actually happens rather than what happens in an ideal world. 

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Q3: Approximately how long (in hours or days) on average does it take to receive all the data on the location of underground infrastructure you require from asset owners following the initial request? 

Please provide any further detail to your answer. 

This will be entirely dependent on your processes as to how many asset owners you contact before works commence as discussed in Q2. Also, the reason for the request and the type of work planned to be carried out will have an impact on the timescales. 

Whilst 90%+ of LSBUD responses are delivered within minutes, we would strongly recommend that you consider that, for LSBUD Members at least, a response is not just the asset plan.  All our Members have risk assessment processes that consider the nature of your work (criticality, work category, type, location, date, proximity to assets, etc.) which is a two-way data exchange.  Having the asset location information available is not the end of the process.  You must always be confident that the asset owners have fully considered your works, which includes the safe digging advice, procedural reviews and, if relevant, supervision on site. 

The NUAR Team will want to see long periods here so that they can justify the efficiency of having instant access to the asset data.  Please consider this when replying in that it is NOT a like for like comparison with current high performing risk mitigation processes.  Such a comparison could threaten users undertaking the highest risk works as well as the assets themselves. 

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Q4: Once received, approximately how long (in hours or days) does it take you to process the data from the various sources into a useful standardised format or information pack for use on a job? 

Please provide any further detail to your answer, including the method you use, and the number and type of staff involved. 

It is important to classify what processing means in practice.  We suspect that the Project Team envisage that everyone transposes/manipulates the asset records into one plan and that this is the extent of the processing.  

Something to consider is whether you always combine the records or do you locate them on site on an asset-by-asset basis? 

The issue here is that many asset owners supply a lot of supplementary information with the asset records to help make sure people can work safely.  Some of this is seen as lengthy but is included as there are international examples of strikes (with fatalities) that justify the inclusion of this information.   

It is not just the asset plan that is important; “data” is far broader than just the asset plan. This will vary from asset owner to asset owner and also within each asset owner, depending on the type/criticality/risk profile of the asset, the type of job (maintenance/ emergency/ upgrade/ major scheme) and experience of previous utility strike events; one size does not fit all. 

We suspect that the NUAR Team will be looking for long times here to justify the efficiencies from combining them on a platform in a similar format.  One to remember is that large savings in time here will justify a higher charge for the use of NUAR. 

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Q5: Do you believe 100% participation is achievable without legislation? 

Yes/No 

Please provide any further detail to your answer, including how you think full participation could be achieved through other means. 

The Geospatial Commission intends to use legislation for NUAR.  How that is drafted is incredibly important. 

It is important to understand what “participation” means. 100% of what?  

Does it mean: 

• only NUAR should be used to find out where assets are; or  
• that all utility assets must be in the same format and on the NUAR platform; or 

• that all assets will be properly mapped on NUAR and genuinely managed by all operators; or   
• that EVERYONE putting a spade in the ground for ANY purpose will use NUAR? 

Do you think legislation should and/or would achieve all these things in reality? 

As an industry, we need to be incredibly careful here.  Legislation can be many things.  What behaviours do we expect from people who are forced to do things versus people that believe in something and want to make it work for the greater good?  We’d always promote people (asset owners and users) doing the right thing for the right reasons rather than because they are forced to. 

Is it best to get 100% participation to include EVERY asset owner BUT with limited engagement?  Or perhaps 80% or 90% with engaged asset owners that have useful asset data and the supporting resources behind them. This comes down to what is the core purpose of NUAR? 

Should we not concentrate on improving the accuracy and/or completeness of the records?  Would excavators (and asset owners in the long run) not value having service pipes mapped instead for example?  Would legislation not help that instead? 

Any legislation should be on the outcome (e.g., asset owners to be measured on sharing information with the broadest range of excavators through the way they see best) rather than the proposed solution (e.g. everyone must use a Government system to achieve it). By focusing on the outcome, the future of the industry is future proofed as industry will continue to innovate. 

We believe that the NUAR Team will anticipate you saying NO so that it helps them justify the legislation that they have planned to force everyone to use the system and have no choice.  Do you want to be legislated either as an excavator or asset owner?  Is it not a failure that there is even mention of legislation before any asset owner has voluntarily shared their data via NUAR (like 100+ do already via LSBUD)? 

IMPORTANT NOTE: EXTRACT FROM GOVERNMENT STATEMENT ON REGULATORY REFORMS: (Available from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1018386/Brexit_opportunities-_regulatory_reforms.pdf  Date accessed 22 April 2022) 

Specification for the Sharing of Underground Asset Data – The National Underground Asset Register (NUAR) programme is working to build a secure, interactive data-sharing platform that public and private sector organisations can use to view a digital map of underground infrastructure, such as pipes and cables. Implementing the NUAR will provide planners and excavators with data on the location of underground infrastructure; substantially improve the safety and efficiency of construction and development and deliver economic benefits for industry and local communities. To make sure that planners and excavators have full access to the data they need, when they need it, the government intends to legislate to prescribe that data is shared through the platform. 

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Q6: To what extent do you agree that the government should require data ingested into the platform to be consistent with the data model? 

Strongly Agree/ Agree/ Neutral/ Disagree/ Strongly Disagree 

Please provide any further detail to your answer. 

Strongly disagree. 

Asset data has been constructed over decades to suit the industry and the asset owner for a multitude of reasons by experts. 

At LSBUD, we have never enforced any change of data for any asset owners but have achieved significant efficiencies for over a million km of assets and over 180,000 users.  

Non-compliance of data should not be a barrier to participation.  We believe that sharing what is available now (and working in the background to improve it) is the right option for industry.  

Investment should be made to improve accuracy and completeness rather than changing formats. 

Should the likes of the fibre companies divert resources from achieving aggressive broadband coverage to this project without any discernible benefit?  Should the DNOs reduce investment in electrification of heat and transport?  Should the gas networks reduce efforts on decarbonisation?  Across all sectors, this would harm the general public. 

Even if you do not hold any asset data, bear in mind that there are significant costs changing the structure of data.  This will divert costs from more important areas and the consumer will pay. 

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Q7. Do you agree that it could be beneficial to expand the prescribed use cases for NUAR in the future? 

Yes/No 

Please provide any further detail on your response including what these could be, as well as how asset owners should be informed of an expansion of use cases. 

The key suggested benefit from the current use case is savings from utility strikes but it is only planned to be available to a selected group of users rather than the full spectrum (which includes the highest risk users) as we do at LSBUD.  

The people with (generally) the least knowledge about pipes and cables, and therefore at the highest risk, will NOT have access to the NUAR platform.  

We would therefore argue that its current use case fails to achieve its objective so there seems little point considering other use cases. 

It would be far more effective if NUAR built on existing proven solutions across industry to properly address the safe digging challenge for EVERYONE rather than just for selected parties. 

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Q8. Do you have any views about how NUAR should be run once it is fully operational including the status and remit of the responsible body? 

Please provide any further detail on your response. 

Based on our achievements over two decades in this specialist field, we do not subscribe to the theory that Government needs to be involved in this type of project to make them successful. 

Our technological solutions have evolved, and the use cases developed, over those years to serve the whole industry, all at no cost to the taxpayer. 

In terms of any safe digging platform, some of the measures of success include: 

• It should be available to all 
• It should be free to use 
• It should not preclude competition in the long term 
• It should prioritise safety over commerciality 
• There should be a governance body formed from key stakeholders to oversee any future operation and development. 

There must be no exclusivity for this system in any way; otherwise, the industry will be held to ransom in terms of development, access and functionality. 

We believe that we have proven that a SME can do more than do the role justice, with a collaborative community that are fully bought into the objective of helping people work safely.  Any team needs to properly understand the end user for the most effective service delivery rather than just having technical expertise. 

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Q9. To what extent do you agree that NUAR should charge;

• Asset owners Strongly Agree/ Agree/ Neutral/ Disagree/ Strongly Disagree

How can this be answered without detail of how much it is going to cost? 

Clearly, LSBUD charges asset owners so we believe this is the correct model.  All charges are based on performance and there is always choice for asset owners to share their data in a different way. 

If you answer “Strongly Agree/Agree” and legislation is passed, then there will be no option for asset owners, even if the system is expensive and wholly useless.  This is entirely unreasonable regardless of what side of the fence you sit on. 

•  Statutory undertakers Strongly Agree/ Agree/ Neutral/ Disagree/ Strongly Disagree

The same point above rings true.  An asset owner is likely to be both an asset owner for the protection of their assets and a statutory undertaker in terms of working near others so could face double charges. 

If you answer “Strongly Agree/Agree” and legislation is passed then there will be no option for statutory undertakers (and their supply chain), even if the system is expensive and wholly useless.  This is entirely unreasonable regardless of what side of the fence you sit on. 

•  Users for non-statutory purposes Strongly Agree/ Agree/ Neutral/ Disagree/ Strongly Disagree

Please provide any further detail on your response. 

As above but we understand that those working for non-statutory purposes can often know least about utility assets.  Accordingly, they may also be more likely to work without a search to avoid a charge. 

Consider also that this group includes the supply chains- from a primary contractor to the landscaper or fencing contractor in the latter stages of a project.  Should a fencing contractor working on behalf a utility one day get the data but then not get access the following day when working for a housing developer?  Should we not protect all users regardless of who they are working for? 

The system should be free and available for all.  Anything less is a derogation of responsibility.