Tennessee’s Underground Utility Damage Prevention Act (UUDPA) is being reviewed for targeted updates that reflect today’s realities in the field. A set of proposed legislative amendments aim to reduce delays, improve clarity, and strengthen public safety without weakening core damage prevention principles. Here’s a practical look at what’s being proposed for 2026 and why it matters:
Vacuum Excavation: Clarifying a Common Practice
Vacuum excavation is widely used by utility operators to safely locate untonable lines or verify clearance at high-risk crossings. Today, it is classified as “hand digging,” which triggers a notice requirement under TCA § 65-31-106, meaning a utility needs to submit a locate request before using this technique to assist an excavator, even when the excavator already has a valid locate ticket. The proposed amendment would exempt utility operators (or their contractors) from submitting an additional notice when vacuum excavation is performed after proper notification by an excavator, strictly for locating or protecting their own facilities. This change would eliminate unnecessary delays while preserving accountability.
Digital Locating: What It Is and When It Can Be Used
Improved GIS data and ticket management tools now allow some utilities to easily identify potential conflicts and share relevant imagery. The proposal formally defines “digital locating” in TCA § 65-31-102 and recognizes it as an acceptable response method for design tickets under TCA § 65-31-118. This would give excavators clearer, more visual information while acknowledging modern locating workflows. There is no intent to allow digital locating as an alternative to traditional markings on other ticket types.
Submerged Excavation: Closing a Safety Gap
Following a fatal underwater pipeline incident in Texas, PHMSA has urged states to ensure their laws clearly address marine (underwater) excavation. While Tennessee’s current definition of excavation likely already covers submerged work, the proposal would explicitly add “dredging” to TCA § 65-31-102. This small clarification strengthens the state’s legal footing and reinforces the importance of coordination between dredging contractors and pipeline operators.
White Lining: Reducing Ambiguity
White lining helps locators identify the correct work area and avoid wasted effort. Current law allows several exemptions where pre-marking or white-lining is not required by an excavator, but vague language has led to confusion and inconsistent enforcement. The proposal removes three ambiguous exemptions from TCA § 65-31-106(b) while retaining the option to waive white lining when excavators meet directly with affected utilities. Electronic white lining remains an approved alternative.
Ticket Life: Balancing Demand and Resources
With locate requests increasing sharply over the last decade, a final proposal would extend ticket life from 15 to 20 calendar days. This change aligns with evolving Common Ground Alliance best practices, moves Tennessee’s ticket life closer to the ticket life in neighboring states, and reflects PHMSA data which provides no indication that utility damages would increase due to a change at this scale. The update would revise TCA § 65-31-106(a)(1) accordingly.
Together, these proposals aim to modernize the law while keeping safety and communication at the center of Tennessee’s damage-prevention system. As the proposal works its way through the legislative process, some of these elements may be modified or dropped entirely. You can track house bill 2024 and senate bill 2152 if you’d like to stay on top of the latest developments, and we’ll keep you updated in subsequent issues of this publication.