Questions
1. Should utility companies be required to produce quality plans for proposed road works?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Vodafone would embrace and get behind any process that helps us get it right first time.
Introducing and Quality Plan should improve reinstatements and reduce remedial works. Things to consider are: Utilities independent Coring Programmes, adequate refresher training to high level to assess materials, compaction process, edge & base cleanliness and sealing, material temperature controls & testing, downtime for tool box workshops for innovation, new materials safety issues etc.
It is important that we have consistency and parity across the Roadworks Industry to raise standards. Vodafone sees Quality Plans, for both Utility and Road Authority works as a way to achieve this.
Introducing and Quality Plan should improve reinstatements and reduce remedial works. Things to consider are: Utilities independent Coring Programmes, adequate refresher training to high level to assess materials, compaction process, edge & base cleanliness and sealing, material temperature controls & testing, downtime for tool box workshops for innovation, new materials safety issues etc.
It is important that we have consistency and parity across the Roadworks Industry to raise standards. Vodafone sees Quality Plans, for both Utility and Road Authority works as a way to achieve this.
2. Should there be a single guarantee period offered on utility reinstatements of 6 years regardless of the depth of excavation?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain your answer to this question:
- Reinstatement failures normally emanate within the to 2/3 years guarantee period and are due to lack of compaction and edge/layer bonding problems, so an enhanced guarantee period would not add value. Extra Costs will be incurred as below:
For Road Authorities - if the proposed 6-year period is agreed a new inspection regime will be needed to ensure inspections are available throughout the new period and at the end of the guarantee.
For Utilities - Our contractors normally have 2 or 3 year contracts, leading to retainers or bonds to cater for legacy defects. For new contracts, the costs will ultimately rise with no guarantee of improved reinstatement without the proposed Quality Plans in place as proposed in Question 1.
The state of existing road is an issue if past life expectancy. Roads authority should meet a similar specification and performance monitored.
For Road Authorities - if the proposed 6-year period is agreed a new inspection regime will be needed to ensure inspections are available throughout the new period and at the end of the guarantee.
For Utilities - Our contractors normally have 2 or 3 year contracts, leading to retainers or bonds to cater for legacy defects. For new contracts, the costs will ultimately rise with no guarantee of improved reinstatement without the proposed Quality Plans in place as proposed in Question 1.
The state of existing road is an issue if past life expectancy. Roads authority should meet a similar specification and performance monitored.
3. If introduced, should the impact of quality plans be reviewed after a suitable period (perhaps 6 years), and the necessity of the latent defect process be assessed?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
New material testing might mean we get more quality confidence in quality plans in the future.
4. Should we clarify that the scope for a code of practice on reinstatement (currently the Specification for the Reinstatement of Openings in Roads) includes all activity relating to the execution of road works e.g. signing lighting guarding, excavation, reinstatement, and guarantee period?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain your answer to this question:
There is no need for clarification. The SROR is explicit concerning reinstatement of the road to comply with prescribed materials, standards of workmanship and that it conforms to prescribed performance standards throughout its guarantee period.
Elsewhere in NRSWA there is a Code of Practice for Safety – “Safety at Street Works and Road Works”. The Red Book thoroughly covers Signing, Lighting and Guarding. There is no reason to change it.
Elsewhere in NRSWA there is a Code of Practice for Safety – “Safety at Street Works and Road Works”. The Red Book thoroughly covers Signing, Lighting and Guarding. There is no reason to change it.
5(a). Should start actual starts, works completed, works cleared, and works closed notices be notified within 2 hours, or within 2 hours of the start of the next business day if outwith office hours?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
However there will be cost implications with this proposal:
Information for the SRWR must be accurate and therefore Supervisors/Operatives will have use smart PDA Location applications to clear/close works on site OR have a reliable process for information upload to the NRSWA Administration Team for onward transmission before the 2 hours’ deadline expires. Cost of new PDA’s/Integrated Software, Licences, Training for all Supply Chain Contractors Operatives/Administrative staff. Also resulting in more FPN’s for non-compliance? Current noticing process is sufficient for Roads authority to carry out network management duty. Could create a back log of information at peak times for Symology
Information for the SRWR must be accurate and therefore Supervisors/Operatives will have use smart PDA Location applications to clear/close works on site OR have a reliable process for information upload to the NRSWA Administration Team for onward transmission before the 2 hours’ deadline expires. Cost of new PDA’s/Integrated Software, Licences, Training for all Supply Chain Contractors Operatives/Administrative staff. Also resulting in more FPN’s for non-compliance? Current noticing process is sufficient for Roads authority to carry out network management duty. Could create a back log of information at peak times for Symology
5(b). Should the validity period for notices placed onto the Scottish Road Works Register in relation to planned works be reduced, the proposal being that they be set at 4 days or 2 days depending on the traffic sensitivity of the road?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
No cost implications other than retraining of Administration/Operative Teams.
6. Should the provision of plant information to the Scottish Road Works Register should be made mandatory?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Although duct and chamber information is Mandatory. The cable and customer information must be left to the Undertaker to decide whether to give this extra detail based on commercial sensitivity or security.
7(a). Should the obligation on the Scottish Road Works Commissioner to make the Scottish Road Works Register available for inspection be repealed?
Please explain your answer to this question:
This would alleviate anxiety expressed by some undertakers as their apparatus would be visible to the general public and therefore encourage undertaker to participate in the VAULT programme.
7(b). Should the duty to make the Scottish Road Works Register available for inspection be replaced with a duty on the Scottish Road Works Commissioner to actively publish information relating to the location of planned and actual road works?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Having a public accessible portal on the internet would allow only limited prescribed noticing information to be shared.
8. Should “the Safety at Street Works and Road Works A Code of Practice” apply equally to roads authority and utility road work sites?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
It’s important all promoters working on public roads are subject to the same safety regime. We all know that there is a cross-pollination of Supervisors/Operatives and other key personnel have and will continue to transfer between Road Authorities and Undertakers organisations so it’s vital that same rules apply. Generally, the public, who we have a duty to safeguard, would not distinguish between types of works but need to know they are safe when around works, whoever promotes these.
9. Should utility and roads authority workers be required to be qualified in the “Signing Lighting and Guarding” of a site, and also in the “Location and Avoidance of Underground Apparatus”?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
All Vodafone employees and their contractors already have qualifications to Signing, Lighting and Guarding. Also Location & Avoidance of Underground Apparatus to work on public roads.
10. Should the minimum legal requirement for at least ‘one’ operative to be qualified be increased to ensure that more operatives at each road work site hold formal qualifications for the particular work they are undertaking?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
It makes sense to have more than one worker qualified on site to cover for any eventualities for instance sickness, injury or accident of one worker allows management of the site by another.
11. Do you agree with our policy proposals to revise and improve the enforcement of road works in Scotland by the Scottish Road Works Commissioner?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Perhaps Roads authorities should be subject to “Policing”, however Vodafone is nervous of creating new offences under NRSWA. A more realistic avenue would be to replicate current NRSWA’ s offences with offences for Roads Authorities. Yes, a level playing field would add maturity to the roadworks community and its ability the deliver schemes across the industry for the general public.
12. Do you agree with our policy proposals to reform the use of Fixed Penalty Notices for the enforcement of road works in Scotland?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain your answer to this question:
Current legislation is sufficient. There is merit in developing FPN Regime which gets away from merely punitive aspects and encourages promoters (Utilities and Road Authorities alike) to improve compliance by working together. There is much to consider to setting a regime:
At what stage would a formal warning be appropriate; for example, the first offence or sliding range with ultimately a FPN determined by seriousness?
Who would serve the FPN, Roads authority as present or left to SRWC?
At what stage would a formal warning be appropriate; for example, the first offence or sliding range with ultimately a FPN determined by seriousness?
Who would serve the FPN, Roads authority as present or left to SRWC?
13. Do you agree with our policy proposals to enhance the role of the Scottish Road Works Commissioner?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
There is merit in enhancing the SRWC’s role to support an inspection function, however the scope must be regulated to ensure its powers are not exceeded when introduced. A dispute resolution process should be introduced to resolve issues before reaching the SRWC.
A more balanced approach to road works compliance needs to be developed throughout the industry, not just on utility works. It must be considered that the cost of an inspection function is to be paid out of the SWRC prescribed amounts & fees and therefore likely to increase by some margin. Therefore, due diligence is required to ensure value for money in any new proposal which improves the standard for all. We expect this function to have parity across all promoters and to be designed as an exception service for the SRWC, not a “run of the mill inspection” regime.
A more balanced approach to road works compliance needs to be developed throughout the industry, not just on utility works. It must be considered that the cost of an inspection function is to be paid out of the SWRC prescribed amounts & fees and therefore likely to increase by some margin. Therefore, due diligence is required to ensure value for money in any new proposal which improves the standard for all. We expect this function to have parity across all promoters and to be designed as an exception service for the SRWC, not a “run of the mill inspection” regime.
14. Should there be flexibility to prescribe the restricted period following substantial works through secondary legislation?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain your answer to this question:
The amendment in TSA (2005) now defines the restricted period as “such period as may be prescribed” giving flexibility through the CoP for Co-ordination as described in S117(9).
Therefore, a review the CoP to a more pragmatic approach perhaps based on a Matrix Score (traffic/disruption caused by works/location/local needs), is certainly possible.
Therefore, a review the CoP to a more pragmatic approach perhaps based on a Matrix Score (traffic/disruption caused by works/location/local needs), is certainly possible.
15. Should we clarify that a roads authority is included within those to be notified under Section 114 of the New Roads and Street Works Act 1991?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Foolish not to as the Authority needs to know.
16. Should roads authorities be one of the parties that must be notified under statute to help formalise the use of early and late start consents?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
Foolish not to as the Authority needs to know.
17. Should Section 132 of NRSWA be repealed?”
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Please explain your answer to this question:
S132 provides that a new reinstatement at the same position as an existing reinstatement will take on ownership to the extent of the original works. This NRSWA Section has not created issues for utilities in the past and therefore should remain.
18. Should noticing requirements for roads authorities and utility companies be exactly the same in order to facilitate coordination and cooperation?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
It is important that all road works are notifiable to ensure that the SRWR is up to date so that co-ordination can take place effectively. Roads Authorities Teams should be separate to Road Maintenance Teams so that equal status is placed on information from all promoters to ensure the general public is best served by the roadworks community.
19. Should Section 61 of the Roads (Scotland) Act 1984 be revoked with savings provisions for existing agreements?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer to this question:
It makes absolute sense to require road works, whether promoted by a Utility or Developer to record road openings and reinstatement details in the SRWR to ensure co-ordination can take place and for safety issues.
About You
What is your name?
Name
Vodafone Limited
Are you responding as an individual or an organisation?
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Individual
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Organisation
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Organisation
Vodafone Limited