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Interpretation Response #PI-11-0014 ([Bose McKinney & Evans LLP] [Ms. Nikki Gray Shoultz, Esq.])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Bose McKinney & Evans LLP

Individual Name: Ms. Nikki Gray Shoultz, Esq.

Location State: IN Country: US

View the Interpretation Document

Response text:

Ms. Nikki Gray Shoultz, Esq.
Bose McKinney & Evans LLP
111 Monument Circle, Suite 2700
Indianapolis, IN  46204

Dear Ms. Shoultz:

On April 24, 2012, after you became aware of an interpretation of 49 CFR § 191.3 issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to the Indian Utility Regulatory Commission's Pipeline Safety Division (IPSD), you informed me by email that you sent a letter to PHMSA dated September 27, 2011, requesting an interpretation of this regulation as it relates to "master meter" systems.  In your request, you informed PHMSA that you represent the Indiana Apartment Association (IAA) and that the IPSD has indicated its intent to regulate one of IAA's members, Grand Oak Community, an apartment complex located in Evansville, Indiana.  We confirm that we did not receive your initial interpretation request letter and thank you for resending your request.

In your request, you state that you do not believe that the piping configuration at Grand Oak constitutes a master meter system.  You believe that under the definition of a "master meter" in 49 CFR 191.3, the piping at Grand Oak downstream from the local distribution company (LDC) meter should not be regulated by the IPSD because the term master meter system does not apply to piping that runs within a single building.  In your request, you stated the following:

...The utility supplies gas to each building within Grand Oak's complex and each building has its own gas meter.  Grand Oak owns the underground piping that runs between the building's meter to each unit inside the building.  The tenants' consumption is not individually metered, and their natural gas usage is included in rent.

After carefully reviewing your request letter, both your and the IPSD requests lead us to the same conclusion regarding the applicability of the gas pipeline safety regulations to the Grand Oak complex.  Based on the maps and descriptions of the Grand Oak complex that were provided to PHMSA, the pipelines downstream of the LDC's meter travel underground around the buildings before they come above ground to enter into each building.

In this case, the LDC's responsibility ends at the LDC's meter, but the complex owner/operator becomes responsible for the underground pipelines it owns that transport gas between the LDC meter and the various buildings.  The pipeline downstream from the LDC meter is a gas distribution system that is subject to the gas pipeline safety regulations in 49 CFR Parts 191 and 192 as adopted by the State of Indiana and enforced by the IPSD for a master meter operator.

I hope that this information is helpful to you.  If I can be of further assistance, please contact me at 202-366-4046.



John A. Gale
Director, Office of Standards
and Rulemaking


cc: Mr. Robert Veneck, Executive Director
Indiana Utility Regulatory Commission

T:/PHP-30/Interps/Open/Indiana URC=

Regulation Sections

Section Subject
191.3 Definitions