Dear Neighbor,

Thank you for reaching out regarding BGE’s ongoing gas infrastructure upgrades throughout Baltimore City. We understand and share your apprehension regarding the placement of external gas regulators. We wholeheartedly agree with your concerns that they are unsightly and do not match the historic aesthetic of neighborhoods in the City.

For nearly two years, our offices have heard from similarly frustrated constituents. Over that time, we have spent countless hours in communication with BGE, the Maryland Public Service Commission (PSC) responsible for overseeing utility companies in the State, the Office of People’s Counsel (OPC) and impacted neighbors. We have advocated that BGE find an alternative to the external regulators that take the community’s justified concerns into account while enhancing safety. Further, the replacement process recently concluded in some of our own streets, to which all our direct neighbors share these concerns.

At the same time, we have sought to improve communication and operational processes as BGE completes these projects in our neighborhoods. Far too often, BGE has fallen short of providing timely and accurate information regarding the timeline and justification for these projects. When notified of these issues, we have facilitated numerous community meetings with BGE, the PSC, and relevant neighborhood associations as quickly as possible.

Again, there is no doubt that the communication, process, and execution of this upgrade has been problematic, at best. However, it is also clear that both BGE and the PSC are erring on the side of safety and the prevention of catastrophic events like the Flower Branch apartment explosion in 2016.

In 2019, an investigation conducted by the National Transportation Safety Board (NTSB) following that incident concluded that a disconnected regulator led to that explosion. Following their findings, the NTSB ordered that Washington Gas install all new service regulators outside occupied structures. Further, the NTSB mandated that all existing interior service regulators be moved outside occupied structures whenever the gas service line, meter, or regulator is replaced.

As you are aware, the gas delivery system in Baltimore is one of the oldest in the country. The more that we have dug into this issue, it is increasingly clear that both BGE and the PSC are operating with one goal in mind - the safer transmission of natural gas. The external placement of regulators was precipitated by the aforementioned NTSB investigation and ruling in the nearby area serviced by Washington Gas.

Unfortunately, the timing of that NTSB decision came after BGE had already started their upgrade project in Baltimore City. Earlier iterations of the project included internal regulators in some parts of the City, but moved to external installation following the conclusion of the NTSB’s investigation of the Flower Branch apartment explosion. That inconsistency, based on the timing of when projects were started, has understandably led to confusion and consternation.

We know that for many homeowners, it has been a top priority to see if there would be an opportunity for them to seek an exemption from this project for a number of reasons. Our offices have flagged the ongoing concerns from community members for the PSC and BGE and have received some clarification.

The PSC may only accept requests for exemptions from entities that it regulates, not from the public. This leaves it to BGE to request the exemption. After the last two years, we are certain that BGE will not request for an exemption for an entire neighborhood or selected area.

BGE would only ask for exemptions on a case-by-case basis and only for extremely rare circumstances, such as an ADA compliance issue. Age of the homes, unless on a national registry for historic homes, would likely not make a property eligible for exemption.  The risk of tampering or vehicular accidents would not warrant an exemption given the safety concerns of a new regulator and the higher pressure gas system. Instead, BGE would address those concerns through covering the regulator, or blocking it using devices like bollards.

Although there is limited recourse that we, as State legislators, can take regarding BGE’s installation of new regulators outside of homes, we remain a resource throughout the upgrade process. Examples of issues we can assist with include if:

• BGE or its contractors are inadequately communicating with customers;
• BGE has not met with your community association to brief residents on the project, steps involved, and timeline; or
• The quality of the repair work to sidewalks and roadways is insufficient or does not meet historical standards (e.g. unique material like bricks or cobblestones are not replaced with the same materials).

A breakdown of BGE’s answers to many other questions regarding the project can be found in the following pages. Please do not hesitate to reach out to our offices if you have any further questions or if we can be of further assistance. We remain actively engaged in advocating on residents’ behalf for BGE to identify a solution that takes into account concerns around both safety and aesthetics.

Best,

Bill Ferguson                        Robbyn Lewis        Luke Clippinger                Mark Edelson

Senate President                Delegate                Delegate                        Delegate

FAQ from Previous Community Meetings

1. What discussions have there been related to historic structures and new installations?  It was stated that there have been discussions with CHAP for other projects.

CHAP representatives have been present for discussions related to certain gas meter and regulator relocation projects, the most recent of which involved a concern from a customer in Bolton Hill.  In  that particular case, a gas regulator was installed on the outside of a property along with a newly trenched gas service line to upgrade the customer’s gas service.  Due to industry regulations, trends, and best practices to move natural gas regulators outdoors for safety, maintenance, and access purposes, BGE is transitioning to a standard to move regulators outdoors when possible.  BGE does not have currently a policy or standard related to historic properties that dictates the particular placement of gas equipment, however BGE is working to define specific cases where an exception to moving the regulator outside would be necessary, such as properties with Americans with Disability Act-required ramps or other improvements, or properties formally designated as a National Historic Landmark.

2. What is the contact information – both email and phone – to report issues with project contractors?  What is the process?

Currently, letters are mailed to customers in a designated work area in an attempt to inform customers of the pending gas equipment upgrade work.  Each letter contains the following BGE contact information so that customers can ask questions or express concerns: e-mail at OperationPipeline@bge.com or by phone at 410-470-7700.  Prior to field changes, contractor service schedulers will assess each location and speak with the affected homeowner or resident.   BGE Communications and project management personnel are working to enhance communications and awareness for this work, and future gas system upgrades.   These teams are working to potentially implement customer phone calls, door hangers, web updates, and other enhanced communications methods to ensure that BGE customers are informed about and prepared for all scheduled work.

3. Please provide specific details about the expectations of homeowners for interior access (for what is the owner responsible).

BGE has sent a series of letters to customers about the project.  We advise customers that our contractors will need unobstructed access to both the inside and outside of the property to assess the current gas equipment location, prepare for the service transfer and install any necessary piping to connect the property to the upgraded equipment. We advise customers that unobstructed access to its equipment includes all piping up to and including the gas meter, walls, cabinets, etc.  The following  BGE.com link  provides a good background on meter obstructions-- https://www.bge.com/MyAccount/MyBillUsage/Documents/Meter-Obstruction.pdf. Prior to field changes, contractor service schedulers will assess each location and speak with the homeowner about what, if any, obstructions need to be removed prior to the service upgrade occurring.  Customers are also advised that BGE’s gas service tariff, approved by the Maryland Public Service Commission and available at https://www.bge.com/MyAccount/MyBillUsage/Documents/Gas/GasPart1and%20Part2.pdf, requires customers to provide BGE access to all of BGE’s gas equipment inside homes and businesses as a condition of receiving gas service.

BGE covers any costs for accidental damage or work that is initiated by us. If work is necessitated by the customer’s failure to abide by our standards or the gas service tariff (such as providing adequate space around the meter for maintenance/replacement work) these costs are covered by the customer. Once it is determined the existing equipment is inaccessible, we advise the customer that they have the option to hire a contractor to provide access or alternatively our contractor will modify as necessary (at no cost to the customer). Any follow-on repairs are the customers’ responsibility.  There are rare occasions where we have hired a contractor and paid for the modifications/repairs, but these are reviewed/approved on a case-by-case basis.

4. What model of regulators are approved?   Are there other models that may be utilized for this project?
   

• BGE primarily uses Itron B42-R for 275 class meters. We also have Fisher HSR regulators approved due to recent supply chain issues, but they are not typical.
  
• Higher load service (415 class) uses Fisher CS400 type regulators
  
• There are also larger sizes for 800+ CF rated meters, but they are very unlikely to be applied during this project.
  

5. What is the relationship between the current project and the STRIDE project?

STRIDE projects address natural gas system upgrades, primarily eliminating cast iron and bare steel piping, to entire neighborhoods in defined geographic sections of the gas system, while Optimain projects target specific sections of main and connected gas services that are aging and underperforming.  Ultimately, the goal of both programs is similar, which is to upgrade the gas distribution system with modern materials to improve safety and reliability.

6. Is BGE installing external gas regulators because it’s the cheapest option available to them?

Although we don’t know the price differential between an internal versus external regulator, it’s worth noting that cost is not a major factor. BGE and other utilities are reimbursed for infrastructure upgrades through their Multi-Year Rate Plan Orders that are approved by the PSC. Ratepayers ultimately reimburse BGE for infrastructure upgrades regardless of whether the utility chooses the most or least expensive option, so long as the PSC determines the cost to be reasonable.

7. Is BGE responsible for demolition and repairs to sidewalks and roadways? How long should repairs take after installation?

Yes, BGE is responsible for demolition and repairs to sidewalks and roadways for gas infrastructure upgrades. The timeline for repairs is dependent on how long it takes for all homeowners in a specific area to schedule the upgrade to their home’s gas line. BGE only begins repair work after the upgrade project has been completed in an entire area, not on a home-by-home basis.

8. What about the Pipeline and Hazardous Materials Safety Administration (PHMSA) data referenced by the OPC in a recent news article?

The PHMSA data noted by the OPC was the first time such information was referenced to the Delegation. In follow up between our offices and the OPC, it was clarified that the PHMSA recommends a “fact-specific inquiry” as to the placement of gas regulators depending on the likelihood of various scenarios that could lead to an explosion. The “fact-specific inquiry” standard is relatively nebulous and simply requires a reasoned decision for a given conclusion.

As mentioned above, BGE has offered the installation of a regulator cover or bollards to protect from vehicular collision. That response has provided sufficient justification for the PSC to reiterate its findings that the outdoor installation of gas regulators is the safest option as delivery pressure increases. Further, the OPC also clarified in recent correspondence, “...we have been clear in explaining that BGE's outdoor replacement of the regulators is consistent with its tariff and the law.”

9. Please provide the citation for space requirements for around meters.  Are the space requirements part of the inspection process?
   

• BGE’s gas service tariff, which is reviewed and approved by the Maryland Public Service Commission and available at https://www.bge.com/MyAccount/MyBillUsage/Documents/Gas/GasPart1and%20Part2.pdf, states in part in Section 6.1 that customers “shall maintain at least three (3) feet of unobstructed space in front of the meter”.
  
• The existing standards require 3 feet in front of the meters. There is also a requirement for indoor meters to have a 3 foot clearance to any possible sources of ignition (water heaters, AC units, etc.). There are not strict requirements for side clearance to non-ignition sources. The standards does call for a minimum working space of 37" W x 46" H x 56" D (for compact configurations which is similar to indoor meters). These dimensions include the size of the meter within that space.
  
• Additional guidance can be found in the BGE Metering Manual 105-2 (which is available to the public via BGE.com): "An acceptable meter location shall be free of any conditions detrimental to the metering equipment, and such location shall not create a hazard or inconvenience. The customer shall maintain at least three (3) feet of unobstructed space in front of the meter, and such space shall be free of any source of ignition or heat which may damage the meter or related equipment. The sole exception to the three (3) feet of unobstructed space in front of the meter is the use of bollards for protection from vehicular traffic where required; see Meter Protection Section of this manual. The space provided for meters, regulators and service risers shall be clear of all obstructions, such as shutters, doors, and rainspouts, and the placement of obstructions such as concrete equipment pads, shrubbery, porches, patios, decks and gardens shall not interfere with the installation and servicing of the metering equipment or reading of the meter. Meters shall not normally be located over porches or patios."