Posted by Ben Klopp on Thursday, February 19, 2026
Across Pennsylvania and the nation, owners and operators of master-metered natural gas systems are facing increased regulatory scrutiny driven largely by a rise in system failures that have resulted in significant property damage, serious injuries, and, in some cases, loss of life. While these systems are often described as newly regulated, the reality is more nuanced. The term “master meter” first appeared in federal pipeline safety regulations in 49 CFR Part 191 in 1984, meaning many of these systems have technically been jurisdictional for more than 40 years. Historically, however, regulatory focus was often directed elsewhere, and many systems were still new and had not yet demonstrated the level of risk that recent incidents have made impossible to ignore.
For property managers, housing authorities, universities, mobile home communities, and municipalities, this shift has meaningful implications for safety, liability, and long-term cost planning.
Why Master Meter Operators Are Hearing More from Regulators
Recent actions by gas utilities and regulators reflect a broader trend toward formal oversight of master meter systems. System owners and operators are being notified that they may fall under the definition of a Master Meter System, triggering responsibilities under PHMSA regulations (49 CFR Part 192) and Pennsylvania Act 127.
These responsibilities can include:
- Operator identification and registration
- Written operation and maintenance (O&M) plans
- Emergency response procedures
- Routine inspections and leak surveys
- Incident reporting and recordkeeping
- Ongoing training and qualification requirements
At the same time, Public Utility Commissions are expanding how master meter and submetered systems are interpreted. Property owners who distribute gas beyond a single meter are increasingly classified as operators, fully responsible for system safety, compliance, and ongoing integrity.
The Compliance Gap Many Operators Face
The compliance challenges facing many master meter operators are less about neglect and more about evolution. Many systems were originally installed and operated under different ownership structures, regulatory interpretations, and risk profiles. Over time, assets have been merged, sold, repurposed, or transferred often resulting in the loss of institutional knowledge, incomplete documentation, and unclear system boundaries.
Compounding this challenge, many operators have understandably struggled with uncertainty around which regulations apply to their systems and who is ultimately responsible for ongoing operation, maintenance, and safety. Aging natural gas infrastructure, coupled with misunderstandings of applicable federal and state requirements and confusion over operating roles, has created a high-risk combination, one that recent system failures have brought into sharp focus.
Common gaps now identified by regulators and utilities include:
- Incomplete or outdated system mapping and records
- Loss of historical operating knowledge following ownership changes or asset transfers
- Unclear assignment of operator responsibility
- Aging infrastructure with limited condition data
- Informal or undocumented inspection, training, and emergency response practices
These gaps are rarely the result of a single decision. Rather, they reflect decades of incremental change, changes that now require deliberate correction as regulatory expectations and safety risks converge.
Addressing the Cost Question: Funding Support as a Value-Add
One of the most common concerns we hear is cost. Compliance efforts and infrastructure improvements can represent a significant financial burden, especially for housing providers, public entities, and organizations serving fixed-income populations.
There is good news, depending on system type, ownership structure, location, and project scope, certain projects may align with public infrastructure, housing, utility, or safety-focused funding programs at the federal, state, utility, or private level.
As part of our master meter support services, we assist clients in evaluating potential funding and cost-offset opportunities that may be available. Rather than offering generic recommendations, we work with operators early in the process to assess eligibility considerations, timing, and documentation needs, helping align compliance planning with capital improvement strategies to reduce financial strain where possible.
Proactive Compliance Is the Lowest-Risk Option
Regulatory expectations for master meter systems are not easing, they are expanding. Operators who act proactively are best positioned to:
- Reduce safety and liability exposure
- Avoid enforcement-driven timelines
- Make informed repair-versus-replacement decisions
- Coordinate compliance investments with broader capital planning
If you own, operate, or manage a master-metered natural gas system and are unsure how current regulations apply to you, we can help you determine whether your system qualifies as a master meter system, understand your regulatory responsibilities, identify compliance gaps and prioritize next steps, evaluate system risks, upgrade options, and potential funding pathways.
Reach out to me or learn more about our master meter support services today!
Categories: Oil & Gas Infrastructure
Tagged: Natural Gas | Regulations | Health & Safety