First, thanks for continuing to follow this issue, one so very critical to the integrity of German Village Historic District. We are caretakers of a legacy dating back to 1840, recognized as a nationally significant cultural asset since 1974.
What is our goal?
Our goal is very simple: We are requesting that Columbia Gas of Ohio retain gas meters indoors or, in cases where they physically cannot be located indoors, that they be placed on the rear façade, out of public view. Such practices are supported by the State Historic Preservation Office of Ohio and the National Trust for Historic Preservation. We think Columbia Gas should abide by the very same standards you as a property owner must adhere to whenever you are considering a change to the exterior of your home or commercial building. As a public utility, they are immune to Historic District Commission jurisdiction.
Let us be very clear to all: we are not asking Columbia Gas to do anything they are not already doing in other areas of Ohio and in other states in which they operate. We are also not asking them to do anything they are not currently allowed to do with regard to meter location under their tariff with the Public Utilities Commission of Ohio (PUCO), under federal regulations or any local, state or federal law.
Further, each and every standard we are asking them to abide by (retain meters indoors, or in cases where they cannot be located indoors, on a façade not visible from the public right-of-way) is deemed ‘safe’ by the PUCO and federal regulators.
Are gas meters safer indoors or out in urban environments?
We have been in communication with advocates and pipeline safety specialist across the country, including at the PUCO, as we research this issue. One thing is clear: there is no independent study verifying exterior placement of meters is safer than interior placement of meters. Columbia Gas is placing meters outside based on assumptions about the safety of the environment in which they are being placed, rather than quantifiable data and the independent analysis of that data. We consider this simply appalling. Our own research on data collected between the years 2010 and 2017, and that conducted by consultants to the industry based on data collected prior to 2007, indicates that in an urban environment such as ours, gas meters located indoors (German Village currently has approximately 1,000 of the 1,600 estimated meters located in interior locations) have historically suffered up to 90% fewer catastrophic incidents.
The interior placement of gas meters has proven safe in German Village for over a century. Federal statistics call into question the safety of exterior placement of gas meters in urban environments, where exposure to vehicular traffic and vandalism is higher. Why are we being asked to risk what will no doubt be a catastrophic outcome should a meter be struck by a vehicle in the Village?
Here is our action to date:
- The German Village Society filed a Complaint and Motion for a Temporary Injunction (5/22).
- Columbia Gas of Ohio filed a Memorandum Contra (5/30) A Memorandum Contra is an opposing party’s explanation to the court of why the other party’s motion should be denied. The rules and time periods that apply to filing a memorandum contra vary by the court rules of the particular jurisdiction.
- Columbia Gas of Ohio filed an Answer and Motion to Dismiss our case (6/12)
- GVS filed a Request to Prevent Disconnection for those threatened to lose service if they don’t comply with having their meter moved outdoors (6/23)
- GVS filed a Memorandum Contra (6-27)
- Columbia Gas of Ohio filed a “response” to the GVS Request to Prevent Disconnection (6/27)
- Columbia Gas of Ohio filed a Reply to our Memo Contra (7/5)
- GVS filed a revised Attachment H (154 persons signing on the Complaint (7/6) Instead of filing tens if not hundreds of individual Formal Complaints on the same issue, we have ‘joined’ residents to our Formal Complaint. To date 154 district residents have joined our complaint with more being added daily.
Filings that are still pending:
- Motion for Temporary Injunction We have filed a motion to stop Columbia Gas’ activities in the district until the Formal Complaint has been resolved.
- Motion to Dismiss (Filed by Columbia Gas)
- Request to Prevent Disconnection of at least 9 meters where customers of the gas company are resisting the meter move
Next steps (by the PUCO)
- Provide a procedural schedule for the case
- Schedule a mediation conference
In the complaint case rules, the next step in the PUCO case is for a settlement conference to be scheduled: “The legal director, deputy legal director, or an attorney examiner assigned to a complaint case shall schedule a settlement conference to attempt to resolve the issues in the case prior to hearing. The settlement conference will be conducted pursuant to the Uniform Mediation Act found in Chapter 2710 of the Revised Code.” This mediation is performed by an Attorney-Examiner not assigned to the case. We should be hearing from them next week.
What is a Tariff and why did we try to intervene?
The tariff is the agreement between Columbia Gas of Ohio and the PUCO that outlines the duties and rates Columbia must abide by. Whenever Columbia Gas seeks permission from the PUCO to raise rates, meaning a change in the tariff, the tariff becomes ‘open’. While the tariff is open, others may file motions to intervene in the tariff. Preservationists in the state of Pennsylvania were successful in amending the tariff agreement between gas service providers and the utility commission in that state to include language requiring service providers to consider interior placement of meters in both locally and nationally designated historic districts.
The tariff happened to be open when we filed our Formal Complaint, so we, in consultation with the State Historic Preservation Office, filed a Motion to Intervene in the tariff between Columbia and the PUCO with a request to add language addressing our issue, language similar to that which was accepted in the Pennsylvania tariff. The Commission approved Columbia’s tariff, but did not entertain our tariff changes. They did approve us as a party, which is a significant ruling. Further, they noted that infrastructure upgrades in historic districts are the subject of a pending complaint (our case against Columbia) and that: “GVS’s concerns with Columbia’s tariffs should be addressed through the resolution of the complaint in that case.” So the Commission here has given a nod to the Complaint we filed.
What you can do now:
We continue to encourage property owners within the district to join our complaint. It is as simple as filling out a short form. There is no cost and no further obligation. Forms are available in our offices. We will also have canvassers on site during Art Crawl for your convenience.
We also encourage you to submit a letter of support to the Docket for our case at the PUCO. Sample templates and form letters will also be available from our canvassers during Art Crawl.
Please send your letters to:
Public Utilities Commission of Ohio
180 East Broad St.
Columbus, OH 43215
ATTN: Case 17-1298-GA-CSS
If you are approached by Columbia Gas and asked to discuss relocation of your meter from indoors to outdoors and you do not wish to have it relocated, inform them that you are declining their offer and that you are being represented as a property owner in the district by the German Village Society in a formal complaint against them.
You might also remind them that relocating meters to building exteriors not only threatens the integrity of the district but may in fact expose the public and property owners to an increased risk of potentially catastrophic damage or even death should an exterior meter be vandalized, struck by a vehicle, or experience damage due to ice fall, snow pack or extreme temperatures….all risks virtually non-existent with interior meter placement.
And one more request – if you really are a true believer: support us financially. If you already renewed your membership or gave in another way, consider another gift. If you are about to renew your membership gift, consider increasing that gift. Because Columbia isn’t the only advocacy we need to do for the neighborhood.
Call German Village Historic Preservation Advocate Nancy Kotting: 614-221-8888