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3. Horizontal Directional Boring Tectu~ology is used extensively to install "small <br />utilities" (telephone, cable television; gas and electric). These small utilities range <br />in depth from 6" for cable television to 42" for electric. Utility companies like <br />Elk River Municipal Utilities do not ~~~ant cable deeper than the required depth <br />due to maintenance issues. If horizontal directional boring is used to install these <br />small utilities, there is no legitimate need to be deeper than 42" and if they are, <br />they are probably not in construction compliance. <br />4. Current rules require the contractor to pot hole or hand dig utilities and verify <br />location, or if the}~ suspect a utility is present; marked or miss-marked, stop and <br />verify location by pot holing before proceeding. Iy~lany contractors do not want <br />to take the time to do this. Recently developed automated high pressure water <br />system and vacuums make pot holing easier; quicker and safer. Do not abandon <br />the current rule of requiring contractors to expose existing utilities ti~hen the~~ <br />cross these utilities. <br />~ y~lany utilities, including the Elk River 1v~~Iunicipal Utilities, are not alwa}'s sure <br />where the physical limit of easement are in the field are without doing an <br />expensive and time conswning surve}~. Including easement in the right-of-way <br />definition is not reasonable. <br />6 Man}' municipals and utilities including the City of Elk River and Elk River <br />Municipal Utilities are just beginning to utilize Global Positioning System <br />~hechnologies (GPS), to locate and document at surface or below surface items. <br />The GPS system established a X and Y coordinate based off a county or <br />latitude/longitude coordinate system. This information is then stored in a <br />Geographic Information System (GIS). These technologies may ultimately be a <br />better physical solution than tracer ~~-ire and current locating technology. <br />Unfortunately this technology is in its infancy in many communities and non- <br />existent in other communities. It is expensive to imitate and more expensive to <br />maintain. This is not a fool proof system because it is information and computer <br />based and not actual physical based like actual locating. <br />Also marry communities, but not all, keep as built drawings of water and se~~er <br />main and lateral installations. These dra~~ings can possibly be made available to <br />the contractors. Unfortunately this is not fool proof because dimensions and <br />transposing numbers, errors ~~~ill occur. <br />7. This rule appears to be in response to the horizontal directional boring industries <br />desire to shift liability to local units of government. This is not making anybody <br />safer, just shifting liability. We would also encourage a cost benefit analysis be <br />completed to determine if the added cost (regardless of who pays), results in an <br />acceptable benefit. This proposed rule will require, on an average, each city to <br />add a person with equip~r~ent, vehicle and on going training. <br />