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What part of a natural gas pipeline is a master meter operator responsible for?

Oak Tree Group

49 CFR 191.3 defines a master meter system as: pipeline system for distributing gas within, but not limited to, a definable area, such as a mobile home park, housing project, or apartment complex, where the operator purchases metered gas from an outside source for resale through a gas distribution pipeline system. The gas distribution pipeline system supplies the ultimate consumer who either purchases the gas directly through a meter or by other means, such as by rents.


To determine whether the operator meets the definition of a master meter system under 49 CFR § 191.3 and, therefore, is subject to the requirements of 49 CFR Parts 191 and 192, we must determine if the pipeline facilities are delivering gas to the ultimate consumer who pays for the gas directly, via a bill, or pays for the gas indirectly through other means, such as rents. In previous interpretations, PHMSA (Pipeline and Hazardous Materials Safety Administration) has stated that an entity would not meet the definition of a master meter system if it were only "using the gas delivered through its pipeline to provide heat or hot water to its buildings." In that instance, the entity would be the consumer of the gas. PHMSA went on to say that if the entity provides gas to consumers, such as concessionaires, tenants, or others, it is engaged in the distribution of gas, and the persons to whom it is providing gas would be considered customers even though they may not be individually metered (PHMSA interpretation letter).


Pipeline facility is defined in the pipeline safety regulations at 49 CFR § 192.3: …new and existing pipelines, rights-of-way, and any equipment, facility, or building used in the transportation of gas or in the treatment of gas during the course of transportation.


Definitions:


Operator. A corporation, government entity (municipality, county, utility district, etc.) or an individual that operates a natural gas utility or a housing project, apartment complex, condominium, or mobile home park served by a master meter. The operator is ultimately responsible for complying with the pipeline safety regulations.


Master Meter System. A natural gas pipeline system for distributing natural gas for resale within, but not limited to, a distinct area, such as a mobile home park, housing project, or apartment complex, where the operator purchases metered gas from an outside source. The natural gas distribution pipeline system supplies the ultimate consumer who either purchases the gas directly through a meter or by other means such as by rent.




If your company would like to discuss further how PHMSA defines a master meter system and what if any part of your facilities might be considered a master meter system according to PHMSA, please contact The Oak Tree Group.

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