City of Phoenix Insurance Requirements
for Contractors Working in the ROW

The City of Phoenix Street Transportation Department's insurance requirements apply to any contractor performing work in the City's right-of-way (ROW) or public utility easements (PUE) on behalf of a Licensee. In the fiber and telecom world, that Licensee is typically the ISP, utility company, or municipality holding the permit or franchise agreement with the City.

If you are the crew on the ground — the fiber contractor, the boring sub, the splice tech, the restoration contractor — these requirements apply to you regardless of whether you have a direct contract with the City or are working as a subcontractor under someone who does. Your client (the Licensee) is responsible for ensuring you are compliant, and most Licensees will not authorize you to start work without a compliant certificate of insurance in hand.

The requirements are stated as minimums. Your Licensee's contract with you may stack additional requirements on top. Always compare what the City requires against what your client's subcontract specifies — if they differ, carry the higher of the two.

A commercial general liability policy written on an occurrence form — not claims-made — is required. The minimum limits are:

The City of Phoenix must be named as an additional insured for bodily injury, property damage, and personal and advertising injury — covering both ongoing operations and completed operations. Your coverage must be primary and non-contributory, and the policy must include a waiver of subrogation in favor of the City.

If the "project" aggregate box is checked on the ACORD COI, include this exact language in the description of operations: "Covers all projects and locations within City of Phoenix." This Phoenix-specific requirement is easy to miss if your broker is generating a generic certificate.

Any vehicle used in the performance of work in the City — owned, hired, or non-owned — must be covered under a commercial auto policy with a combined single limit of $1,000,000. This applies to work trucks, bore rigs, bucket trucks, trailers, and any other vehicle involved in the operation.

The auto policy must be endorsed to include the City of Phoenix as an additional insured. Coverage must be primary and non-contributory, and a waiver of subrogation in favor of the City is required.

Fiber crews often use a mix of owned and rented equipment — a company-owned directional drill, a rented compressor, employees driving personal trucks to access vaults. Make sure your commercial auto policy includes hired and non-owned auto (HNOA) coverage so those rented and personally-owned vehicles used for work purposes are not creating a gap in your Phoenix coverage.

Workers' compensation at statutory Arizona limits is required. The employers' liability sub-limits were revised effective January 9, 2025 and are now set at $1,000,000 across all three categories — a significant increase from the default limits many policies carry:

A waiver of subrogation in favor of the City is required on the WC policy. The sole proprietor exemption applies under Arizona Revised Statute §23-902(E) — if you are a sole proprietor with no employees and you execute the required waiver form, the WC requirement does not apply to you. But if you have any employees performing ROW work in Phoenix, full WC coverage is mandatory regardless of their employment classification.

This is the requirement that catches most fiber and telecom contractors off guard. Contractor's Pollution Liability (CPL) is mandatory for all ROW and PUE work in the City of Phoenix — there are no exceptions for trade type or project size. Even if you are only pulling cable through existing conduit, the City requires it.

The policy should be written on an occurrence basis with no sunset clause. If claims-made, you must maintain the policy for at least nine years after project completion with the retroactive date held constant at or before the contract start date. That nine-year tail requirement makes occurrence-form CPL the practical choice for most contractors.

The City of Phoenix — including its subsidiaries and affiliates — must be named as an additional insured on the CPL policy. The scope of required coverage is detailed and specific. The following must all be included with no exclusions:

• Bodily injury, sickness, and disease — including death and medical monitoring costs
• Property damage — including cleanup costs, loss of use, and diminution in value
• Environmental damage — soil, surface water, groundwater, plant and animal life, and cleanup costs
• Defense costs — investigation, adjustment, and defense of covered claims
• Asbestos and lead — no exclusion permitted
• Mold and Legionella — must be covered
• Transportation cargo — covering materials in transit
• Non-owned disposal site coverage
• Sediments — must be included in the definition of pollution conditions

The City of Phoenix requires additional insured status on three of the four coverages: General Liability, Automotive Liability, and Contractor's Pollution Liability. Workers' Compensation does not require AI status but does require a waiver of subrogation.

Completed Operations Coverage

For the GL policy, the AI endorsement must cover both ongoing operations (ISO CG 20 10 or equivalent) and completed operations (ISO CG 20 37 or equivalent). A GL policy with an AI endorsement covering only ongoing operations is non-compliant — the City's exposure from your work does not end when your crew leaves the site.

Primary and Non-Contributory

Your GL and Auto policies must respond as primary and non-contributory — meaning your policy pays first and does not ask the City's insurer to share in any loss. This must be backed by an actual endorsement (ISO CG 20 01 or equivalent), not just stated in the description box of the ACORD certificate. Many contractors carry certificates that say "primary and non-contributory" but do not have the underlying endorsement — a problem that only surfaces when a claim is filed.

Waiver of Subrogation

Waivers of subrogation are required on all four policies. These must be added by endorsement and cannot be added retroactively on most carriers. If you are setting up insurance for your first Phoenix ROW project, confirm with your broker that blanket waiver of subrogation endorsements are in place on all four policies before your start date — not after.

Insurer Financial Standards

All insurers must be licensed or authorized to do business in Arizona and hold an A.M. Best rating of B+ VI or better. Most major admitted commercial carriers qualify, but specialty markets commonly used for CPL policies should be verified. If your pollution carrier is a non-admitted surplus lines company, confirm their Arizona authorization and A.M. Best rating before submitting the certificate.

All certificates of insurance and required endorsements must be received and approved by the City before any work commences. Do not start mobilizing until your COI has been submitted and accepted — working in the ROW without an approved COI on file is a material breach of the license agreement.

Certificates must be issued on the ACORD 25 form and signed by a person authorized by the insurer to bind coverage. Submit directly to:

Upon request, the City may ask you to provide declaration pages, applicable endorsements, and relevant exclusions. Keep organized policy documentation so that if Utility Inspections follows up, you can respond same-day without chasing your broker for paperwork.

If any required policy is suspended, voided, or cancelled for any reason, you must notify the City within 30 business days of receiving that notice from your insurer. Notice must be mailed or hand-delivered — not emailed — to the Utility Inspections Administrator at the address above.

Failure to maintain required insurance is a material breach of the license agreement. The City can prohibit you from working in the ROW until compliant coverage is reinstated and a new COI is submitted and approved. On an active fiber project with tight completion timelines, an insurance lapse is not just a compliance issue — it is a project-stopping operational crisis.

If your insurer sends a non-renewal notice, treat it with the same urgency as a cancellation notice. Lining up replacement coverage takes time, particularly for CPL policies that require underwriter review of your operations and loss history. Start the renewal process at least 60 days before expiration on any Phoenix ROW project.

Based on the Phoenix requirements, here are the coverage gaps that fiber and telecom subcontractors most commonly encounter when bidding Phoenix ROW work for the first time:

1. No Contractor's Pollution Liability at all. Many fiber subs carry GL, auto, and WC, but no CPL — because most non-Phoenix markets do not require it for telecom work. Phoenix requires it for everyone. Getting a new CPL policy in place takes time, especially with an underwriter who is unfamiliar with fiber operations. Budget 2–3 weeks minimum for a new CPL placement.
2. CPL policy excludes asbestos or lead. A significant percentage of CPL policies on the market exclude asbestos and lead by default. Phoenix expressly requires no such exclusion. If your existing CPL has these exclusions, you need either a new policy or endorsements removing them — and not every carrier will add them mid-term.
3. Employers' liability limits at $100K instead of $1M. Standard WC policies in most states default to $100,000/$100,000/$100,000 employers' liability sub-limits. Phoenix now requires $1,000,000/$1,000,000/$1,000,000 across all three. A mid-term increase requires insurer approval and an additional premium, so address this before you bid.
4. No HNOA coverage on commercial auto. Hired and non-owned auto coverage is often excluded from basic commercial auto policies or added only by endorsement. If your crew uses rented equipment vehicles or personal trucks for any aspect of Phoenix ROW work, you need HNOA coverage on your commercial auto policy.
5. AI endorsement covers only ongoing operations. The City requires additional insured status for completed operations as well. Many standard blanket AI endorsements cover only ongoing operations (CG 20 10). Confirm your policy also carries CG 20 37 or equivalent for completed operations coverage.
6. Claims-made CPL without a 9-year tail arrangement. If your CPL is written on a claims-made basis, the City requires coverage to be maintained for nine years post-completion. That is an unusual requirement — most contractors are not accustomed to managing tail coverage obligations for nearly a decade. Occurrence-form CPL eliminates this administrative burden and is the preferred structure for Phoenix ROW projects.