The Problem with Reclassifying Single-Address Locates

Across Ontario, excavators, contractors, and locators are encountering a growing administrative obstacle: locate requests tied to a single civic address are increasingly being reclassified as "Advanced Locate Requests" not due to complexity or scope of utility infrastructure, but because the dig area either crosses into the public right-of-way (ROW) (such as a sidewalk, boulevard, or municipal roadway) or is deemed too large by Ontario One Call’s internal processing system.

This seemingly minor distinction carries significant operational and financial consequences:

• A standard 5-business day locate window is now subject to a 10-business day timeline,
• Projects are delayed without any change in risk profile,
• Administrative burden increases without clarity or consistency,
• And contractors are penalized for trying to identify all utility conflicts within a practical work area.

Most concerning is that this reclassification is not clearly required under the Ontario Underground Infrastructure Notification System Act, 2012—raising questions about whether Ontario One Call is exceeding its statutory authority through internal procedural rules.

The Act defines what qualifies as an Advanced Locate Request:
(a) at least two properties or parts of properties, each having its own municipal address, or
(b) one or more properties or parts of properties, at least one of which has no municipal address.

Ontario One Call appears to be interpreting clause (b) to include situations where the mapped dig area includes the adjacent public right-of-way, on the premise that such land is not assigned a municipal address and is therefore considered a "part of a property" without one.

They may also argue that arbitrarily large dig areas, even those limited to a single civic address, introduce complexities better suited to the "advanced" category.

But here’s why both interpretations are flawed.

The public ROW in front of a civic address is not a separate or independent property. It is:

• Contiguous with and subordinate to the serviced property,
• Owned and maintained by the municipality for common use,
• Used for essential infrastructure that directly serves the civic address (e.g., hydro laterals, gas mains, telecom drops, water and sewer connections).

In practice, utility connections regularly extend from the home or building into this ROW. Including it in the locate area is not an expansion into a new site, it is part of understanding and documenting the true path of subsurface infrastructure tied to a single address.

If Ontario One Call treats any incursion into public ROW as grounds to reclassify a request, then almost every locate request in Ontario would qualify as "advanced". This not only contradicts common practice it renders the “single address” category essentially meaningless.

Another frequent justification is that requests covering a "large area" (e.g., a commercial parking lot, campus, or condo frontage) introduce scope or coordination issues. While that may be operationally true in some cases, it does not automatically invoke the legal conditions set out in clause (a) or (b).

A large area within a single property boundary, tied to a single municipal address, remains a single-site request under the legislation. The law does not impose size thresholds or geospatial coverage limits as part of the definition of a standard request.

If Ontario One Call has created internal rules that define “too large” without legislative support or published policy guidelines, then excavators are being penalized based on subjective or unpublished standards, which undermines fairness, transparency, and due process.

One of the more concerning developments is Ontario One Call’s selective and inconsistent interpretation of public vs. private property. Currently, the system treats a locate request as a standard "single address" ticket only if the dig area does not cross the curb line in front of the property. Once the dig box extends beyond that curb line the request is flagged as "advanced."

To justify this, Ontario One Call has introduced a concept referred to as the "public part of private property"—essentially suggesting that the boulevard or space between the property line and the curb is a grey zone that allows the request to remain single-address.

This is a legal fiction.

There is no such classification in the Ontario Underground Infrastructure Notification System Act, nor in property law. The land between the property line and the curb is clearly public right-of-way under municipal ownership and is treated as such in all other contexts: zoning, utility permits, municipal maintenance, etc.

This arbitrary distinction creates an invisible and unenforceable boundary, and forces excavators to play a guessing game as to where the acceptable limit lies. Worse still, it means that identical locate requests may be treated differently based solely on how precisely a dig box is drawn or whether it touches the curb.

If the goal of the legislation is clarity, fairness, and consistency, this policy undermines it entirely.

These re-classifications don’t improve locate accuracy or reduce utility strikes. Instead, they:

• Force requesters to wait longer for what are often routine, low-risk locates,
• Penalize those who proactively include all potential utility conflicts in a request,
• Add unnecessary back-and-forth when tickets are rejected or returned,
• Undermine confidence in Ontario One Call’s role as a neutral facilitator of safe digging.

This is not just a policy issue—it’s a damage prevention issue. When the locate system becomes slow, confusing, or inconsistent, work may proceed without complete locates, or site staff may segment tickets in awkward and inefficient ways just to comply.

Ontario One Call operates as a statutory not-for-profit mandated by legislation. It has a responsibility to follow the law—not reinterpret it.

If reclassification of requests based on ROW inclusion or arbitrary area size is not explicitly supported by the Act or Ministry regulation, then Ontario One Call must:

• Clarify whether these policies are internal,
• Explain the rationale and thresholds, and
• Be transparent with requesters about how and why their tickets are being handled differently.

Anything less risks undermining the credibility of the entire system.

4D Locate Solutions Inc. intends to submit a formal compliance objection to Ontario One Call’s leadership. We are requesting:

1. A written explanation of the legal foundation for reclassifying ROW-inclusive or large-area single-address requests;
2. Clarification on whether this practice has been approved by Ontario One Call’s Board of Directors or directed by the Ministry of Public and Business Service Delivery and Procurement;
3. Confirmation of how Ontario One Call defines "part of a property" in clause (b), and whether public ROW meets that standard.

If we ultimately do not receive a legislatively grounded response, we intend to escalate the matter to the Ministry and pursue policy review through industry associations and relevant regulatory bodies.

Have you had a locate request reclassified as advanced due to size or ROW boundaries even though it was clearly associated with a single address? Was the decision explained to you? Did it cause delays?

If so, we encourage you to speak up. Share your experience. Challenge interpretations that don't align with the law and advocate for a locate system that is:

• Grounded in legislation,
• Operationally fair,
• And designed to protect, not obstruct, the people doing the work.