Like many major metropolitan cities across the nation, Chicago has no shortage of underground infrastructure. Natural gas, electric, communication, water, sewage, stormwater systems and historical remains of developments create a dense subsurface puzzle. Wetland and waterway hydrology, critical habitats, and cultural and historic artifacts may also add to below-ground complexity.

Such obstacles require consideration when planning new subterranean installations or maintenance. For underground electric utilities, particularly in urban settings, permitting processes put in place to protect existing assets can seem daunting. However, a team versed in navigating intricate regulations can strategically influence projects and positively impact schedules and budgets, from design through construction.

Managing the Permitting Process

Several permits may be needed for underground infrastructure projects spanning federal, state and local jurisdictions. It’s important to find a consultant who understands triggers and thresholds and can help a design team identify what is needed early. Best practices for navigating the process include:

  • Developing a comprehensive plan before beginning the project.
  • Working with local officials and stakeholders.
  • Staying up to date on regulations and requirements.
  • Utilizing technology and innovation to streamline the process.

Completing desktop reviews, site assessments, field investigations, and leveraging the latest data enables siting, routing and soil management teams to identify subsurface challenges upfront and contribute valuable details toward a comprehensive design strategy. Overlaying environmental and jurisdictional details with design concepts, along with evaluating engineering decisions with a permitting team, allows project stakeholders to optimize alignments.

Beyond the technical aspects of the design, understanding processes, people and requirements is key to a successful project. A strong management approach should involve identifying required permits, developing a permitting matrix and project-specific permitting plan, and proactively conducting oversight throughout the entire process.

Underground permitting can be a complex undertaking and can take time to complete. If not done properly, consequences could include unplanned mitigation requirements, notices of noncompliance, violations, fines and negative public perception. Keys to the process include maintaining good relationships with regulators, agencies and other utilities. Pre-application meetings can also set the stage for opportunities to negotiate design and constructability requirements, and to resolve issues on topics in a way that will reduce scrutiny and promote progress.

Permit Types

Permit varieties can fall into two categories: environmental and non-environmental. Some permits may require field studies to support submittals, while other permits may rely on plans for temporary conditions during construction and final in-place design. Common authorizations include:

  • Site development, land use, zoning, special use permits and ordinance approval
  • Engineering or building permits
  • ROW grants, encroachment agreements, and railroad permitting or easements
  • Local DOT authorizations, including traffic detours and pavement restoration
  • Stormwater management approval involving grading and drainage
  • Floodplain/floodway permits
  • Coordination with conservation districts, park districts and forest preserves
  • USACE or state level authorization for wetland and waterbody impacts
  • Cultural resource review
  • Federal and/or state level threatened or endangered species and habitat reviews
  • NPDES authorization, including SWPPP development
  • Water discharge permits during construction
  • Spill Prevention Control and Countermeasure (SPCC) Plans

Timing of a project can be everything. In some cities, such as Chicago, there are moratoriums against disturbing newly paved intersections or stretches of road. Being unfamiliar with a stipulation like this can result in significant project delays. In other cases, execution of a project can be impeded based on other construction. Decisions such as placement on one side of a roadway versus another, depth of installation, separation from other utilities or assets, and installation methodology can impact authorizations.

CDOT OUC Process and Coordination

In some cities, existing utilities in the area have an opportunity to review proposed utility plans and to provide input. In Chicago, for example, this process is formalized through the Office of Underground Coordination (OUC), which must issue approval prior to the issuance of permits. The OUC is an agency within the Chicago Department of Transportation (CDOT) comprised of city agencies and private entities tasked with protecting city infrastructure.

The OUC review is a two-phase process that includes Information Retrieval (IR) and Existing Facility Protection (EFP) approval. An IR request must be submitted to obtain atlases from utilities. Routing design is then completed to avoid existing below grade facilities, recent paving/ADA ramps, or other conflicts, and to maintain sufficient separation from existing facilities. Projects requiring excavation 12 or more feet below existing grade require an additional Deep Excavation/Foundation review. After a design completion meeting, sealed engineering drawings are submitted for EFP review. Proactive coordination with conflicting utilities supports timely conflict resolution. During the EFP process, agreements can be considered with other utilities to maximize restoration cost savings for projects with overlapping limits. Once design conflicts are resolved, projects can obtain OUC Permit Issuance Authorized (PIA) status, which allows permits to be issued.

Underground Drivers

Expansion of urban areas and development within them will continue driving demand for power reliability and resiliency, pressing the need for grid modernization and infrastructure expansion amid incentive offerings and regulations. A permitting team involved from project inception through design and construction can identify and manage cost and schedule risks to positively influence the success of underground utility projects.


While underground distribution networks offer many benefits, utilities need to consider a
number of factors when upgrading, updating and expanding subterranean assets.

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Thomas Konopka leads infrastructure permitting programs and project teams for utility clients throughout the Midwest.