White Lining
New Arizona 811 Requirements Effective September 12, 2026: What Excavators Need to Know
Page summary
Effective Sept. 12, 2026, Arizona's updated underground facilities law introduces new requirements aimed at improving safety, communication and damage prevention during excavation projects. One key change requires excavators to physically "white line" the proposed excavation area with white paint, flags or chalk before submitting an Arizona 811 locate request, as electronic mapping alone will not satisfy the requirement. The law also requires utility operators to provide electronic status updates on locate requests and establishes new coordination procedures for large-scale projects beginning in 2027. A limited exception applies to homeowners performing excavation on their own single-family residential property.
The state Legislature updated the state's underground facilities laws with new requirements for excavators, utility operators and large projects, effective Sept. 12, 2026.
The law is designed to improve communication between excavators and underground facility operators, enhance damage prevention efforts and support safer excavation practices across Arizona.
White Lining Is Now Required Before Submitting a Locate Request
Under the new law, excavators must clearly and carefully mark the proposed excavation area with white lining before submitting a location request to Arizona 811.
White lining may include white paint, white flags or white chalk. The key takeaway is that the markings must clearly show the area, route or limits of the proposed excavation so underground facilities can be accurately located and marked.
White Line First. Submit Your Ticket Second.
The sequence is important:
- White line the proposed excavation area.
- Submit the Arizona 811 locate request.
- Wait for responses from affected facility operators.
- Begin excavation only after required responses have been received.
Electronic Mapping Alone Is Not Enough
Drawing the excavation area on the Arizona 811 electronic map remains an important part of the ticket process. However, electronic mapping does not replace the requirement to physically white line the proposed excavation area on the ground.
Residential Property Exception
The white-lining requirement does not apply when a person performs excavation on a single-family residential property that the person owns or occupies. This exception is limited and does not extend to contractors or others performing excavation work on behalf of the homeowner.
Electronic Positive Response Requirements
SB 1137 also requires underground facility operators to provide electronic positive responses through Arizona 811 systems. Operators are required to enter locate status information, including:
- Marked
- No Conflict
- Delayed
These responses help excavators understand the status of their locate requests and support more efficient communication between all parties.
Changes for Large Projects
The law establishes new coordination requirements for qualifying large projects. A large project generally includes excavation work that:
- Exceeds one linear mile,
- Covers one-quarter square mile or more, or
- Is expected to continue longer than 90 calendar days.
The law provides for coordination meetings, phased marking schedules and the future use of an interactive positive response system to support communication and project planning. These requirements are scheduled to be implemented no later than September 12, 2027.
Questions?
For additional information about Arizona's underground facilities laws and safe digging requirements:
Call 811 before you dig.
Questions regarding the new law may also be directed to Arizona 811 at NewLawSupport@Arizona811.com using the subject line "NEW LAW question."
