In Pennsylvania, an Alleged Violation Report, commonly called an AVR, is filed through the PA One Call System and submitted to the Pennsylvania Public Utility Commission. PA One Call explains that excavators, designers, project owners, and facility owners must submit an AVR when they believe a person or company failed to meet its responsibilities under the PA One Call Law.

You can file an AVR by going to the PA One Call enforcement page and selecting the option to Submit Alleged Violation. The report should include the One Call ticket number, date of the incident, location, parties involved, description of the alleged violation, and supporting documentation such as photos, correspondence, KARL responses, maps, damage reports, or repair information.

If a line is hit or damaged, the excavator should first stop work, address safety concerns, call 911 if gas is escaping or there is an emergency, and notify PA One Call or the facility owner. PA One Call’s Excavator Handbook states that an AVR must be submitted not more than 30 days after the damage occurred.

An AVR is not limited to damages. It may also be filed for other alleged violations, such as failure to mark, late or inaccurate marks, failure to submit a locate request, digging outside the scope of a ticket, failure to respond through KARL, or other conduct connected to excavation or demolition work. The PA One Call Law states that excavators must submit an AVR through the One Call System within 30 days after damaging a facility owner’s line or if they believe a violation occurred in connection with excavation or demolition.

After the AVR is filed, the matter may be reviewed through the PUC’s enforcement process, which can include an investigation, a violation notice, and possible review by the Damage Prevention Committee. The attached AVR and Violation Notice Process Flowchart also shows that the AVR begins the review process that can lead to an informal determination, hearing request, corrective action, penalty, or closure of the case.

Before filing, gather as much evidence as possible. Helpful documentation includes photos before and after excavation, the One Call ticket, response records, names of witnesses, facility owner communications, repair invoices, damage reports, and any proof that the locate marks were missing, late, faded, unclear, or inaccurate. An AVR should be factual, specific, and supported by documentation because it becomes part of the record reviewed by the PUC.Description text goes here

If you receive an Alleged Violation Report (AVR), do not ignore it. An AVR means someone has alleged that you violated the PA One Call law, but it is not automatically proof that you did something wrong.

You should immediately:

1. Read the AVR carefully to identify the alleged violation, date, ticket number, location, and reporting party.

2. Preserve all records related to the job.

3. Review your One Call ticket, facility owner responses, job photos, notes, emails, texts, and any damage reports.

4. Determine whether the facts support or dispute the allegation.

5. Respond within the required deadline and consider whether you should request a DPC hearing.

The most important thing is to build a clear, documented timeline of what happened before, during, and after excavation.

You should consider requesting a Damage Prevention Committee (DPC) hearing if :

• You disagree with the AVR.

• The facility was mismarked or unmarked.

• The facility owner response was late, incomplete, or inaccurate.

• The AVR does not tell the full story.

• You have photos, ticket records, field notes, or witnesses that support your position.

• The proposed penalty or corrective action seems unfair.

• You are concerned that accepting the violation could affect your company’s record.

A DPC hearing gives you the opportunity to explain your side and present evidence. However, if the facts clearly show a violation and the penalty is minor, some contractors may decide not to contest it. That decision should be made carefully, especially if there are repeat violation concerns or potential legal consequences.

Yes. A facility owner can be wrong if the utility was mismarked, unmarked, marked outside the tolerance zone, inaccurately identified, or not marked according to required standards.

Contractors are often accused after a damage occurs, but many damages begin with inaccurate or incomplete facility owner information. If the line was not marked correctly, the contractor should gather evidence showing:

• Where the marks were placed.

• Where the facility was actually located.

• Whether the marks included proper color, facility owner identification, line count, width, and facility description.

• Whether the markings were faded, confusing, missing, or inconsistent.

• Whether the excavator relied on the ticket response and visible markings in good faith.

A mismark does not automatically excuse every contractor action, but it can be a major defense or mitigating factor.

Before responding to an AVR, gather as much documentation as possible, including:

• PA One Call ticket and serial number.

• Full ticket text and work scope.

• Facility owner responses from KARL or the One Call system.

• Photos of locate marks before excavation.

• Wide-angle photos showing landmarks, curbs, poles, hydrants, meters, buildings, or pavement edges.

• Close-up photos of paint, flags, stakes, or markings.

• Photos of the damage location.

• Measurements from the marks to the damaged facility.

• Jobsite notes, daily reports, foreman notes, and crew statements.

• Emails, texts, or calls with the facility owner, locator, general contractor, or project owner.

• Renotify records, if applicable.

• Emergency ticket documentation, if applicable.

• Repair invoices or damage reports.

• Any maps, plans, utility drawings, as-builts, or SUE information.

• Weather or site condition notes if markings were faded, washed away, or disturbed.

The goal is to show what your crew knew, what was marked, what was not marked, and whether your company acted reasonably under the circumstances.

Mandatory PUC excavator education is training that may be required as part of a PUC/DPC enforcement outcome for a PA One Call violation. It is intended to educate excavators on their responsibilities under the PA One Call law, safe excavation practices, ticket requirements, tolerance zone obligations, renotification, emergency procedures, and damage prevention responsibilities.

In practical terms, the PUC may require an excavator or company employees to complete approved education after a violation. Failure to complete required education by the deadline can create additional enforcement problems and possible penalties.

Contractors should keep proof of completion, including attendee names, test results if applicable, training date, trainer information, and confirmation that the PUC received the documentation.

No.DPC-Pro cannot provide legal advice or act as your attorney.

DPC-Pro can provide practical damage prevention guidance, help review documentation, explain the PA One Call process, help organize facts, identify possible issues with markings or ticket responses, and help contractors understand what information may be important.

Only an attorney can provide legal advice or legal representation.

You should strongly consider involving an attorney when:

• There was injury, death, fire, explosion, evacuation, or major property damage.

• The damage involved gas, electric, hazardous liquids, or other high-risk facilities.

• The penalty is significant.

• The AVR could affect your company’s record or future enforcement exposure.

• You believe the facility owner, locator, designer, or project owner contributed to the incident.

• You are being asked to admit fault.

• You receive formal legal papers, a demand letter, insurance claim, or lawsuit.

• You are unsure whether to request or waive a DPC hearing.

• The case involves complex facts, multiple parties, or disputed markings.

Even if you do not need an attorney for every AVR, it is wise to involve one early when the facts are serious or the consequences could grow beyond the initial penalty.

DPC-Pro gets asked this question more often than not. That’s why we have a referral service to top law firms across Pennsylvania that specializes in the PA One Call law. Give us a call for a referral for your One Call issue.

SUE stands for Subsurface Utility Engineering. It is a process used during project planning and design to identify, map, and manage underground utilities before construction begins.

SUE matters to contractors because poor utility information during design often becomes a field problem during excavation. If plans are inaccurate, incomplete, or based only on old records, contractors may face increased risk of damages, delays, change orders, redesign, safety issues, and enforcement exposure.

SUE helps by improving the quality of utility information before the job is bid and built. It can include:

• Reviewing utility records.

• Surveying visible utility features.

• Using geophysical methods to designate utilities.

• Test holes or vacuum excavation to physically confirm utility locations.

• Creating better utility maps for design and construction.

For contractors, SUE can reduce surprises in the field, improve bid accuracy, lower damage risk, and help show that underground utility risk should be addressed during design — not dumped entirely on the excavator after something goes wrong.

Pennsylvania One Call System, Inc. dba Pennsylvania 811 is the one call center you contact when you are digging anywhere within the Commonwealth of Pennsylvania. They are a majority directed facility owner non-profit Pennsylvania Corporation. Their purpose is to prevent damage to underground facilities by providing an efficient and effective communications network among project owners, designers, excavators, and facility owners.

The PA One Call System training provides basic One Call information, while DIG Prevention Consulting offers practical, real-world training based on actual field issues, AVR examples, and DPC hearing experience — all at one flat rate.

The 811 law is known as the Pennsylvania Underground Utility Line Protection Law: PA Act 287 of 1974, as amended by Act 127 of 2024.

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