Master Meter System Conversion by a Gas Distribution Utility Process Explained

Master meter with sub-meters

Here’s a high-level overview of how a natural gas public utility (NGDU) typically converts and eliminates a master-meter system, such as in a mobile home park, apartment complex or housing authority property, transitioning to direct utility service.

Master Meter System Conversion

1. Regulatory Authorization & Program Eligibility

• Some jurisdictions (e.g., California via the CPUC) establish formal conversion programs—often for mobile home parks—authorized under Public Utilities Codes (e.g., CPUC §§ 2791–2799).

• These programs are voluntary, prioritizing installations based on gas safety risk, infrastructure reliability, and capacity.

• Note: There is not a formal utility conversion program established in Pennsylvania and most states at this time.

  
  

2. Application & Pre-Selection

• Master meter operators submit an initial Form of Intent or equivalent to express interest to the appropriate gas distribution utility (NGDU).

• The NGDU conducts an assessment of the master meter system, examining age, condition, leak history, and capacity of the existing infrastructure.

• Selected sites are placed in the conversion program queue; others may remain on a waiting list.

  
  

3. Detailed Application & Agreement

• Upon pre-selection, utility representatives engage with the master meter operator to:

  • Complete a detailed application covering construction, cost assumptions, and planning.

  • Execute an agreement committing to the conversion scope, responsibilities, and costs coverage.

    
    

4. Planning & Permitting

• Utility and master meter operator coordinate to:

  • Plan engineering and construction logistics.

  • Conduct on-site informational meetings for residents.

  • Obtain local permits (e.g., trenching, construction) from municipalities.

    
    

5. Construction & Utility System Conversion

• Utility installs new gas infrastructure:

  • From the main distribution line to each building on the property with individual meters at each building or housing unity.

  • Optionally replacing old gas and/or electric systems in a joint trench for efficiency.

• New piping is modern, meets current standards, and is maintained by the utility.

  
  

6. Decommissioning the Master Meter System

• Responsibility for the “beyond the meter” piping (between private meter and dwelling) often falls to the park, though utilities may provide oversight or guidance.

• The former master meter system is abandoned, deactivated, or physically removed.

  
  

7. Service Transition & Resident Impact

• Post-construction, the public utility begins providing direct metered gas service to each unit and eligible common areas.

• Residents now receive bills directly from the utility; park owners no longer handle billing or maintenance.

  
  

8. Benefits & Responsibilities

• For the Public Utility: Maintains modern infrastructure, ensures compliance with Gas Distribution Integrity Management Program (DIMP) standards, and reduces master-meter operator responsibilities.

• For Master Meter System Operators: They are relieved of system upkeep, liability, and billing duties.

  
  

9. Regulatory Compliance & Integrity Management

• Converting the system means shifting responsibility from a master-meter operator—subject to 49 CFR Parts 191 & 192 and smaller system DIMP guidance—to a regulated public utility.

• Utility must establish and maintain an integrity plan, including:

  • System mapping

  • Leak detection

  • Cathodic protection

  • Valve and regulator testing

  • Emergency response planning.

    
    

10. Ongoing Oversight

• The utility's newly installed infrastructure is subject to standard state and federal pipeline safety regulations, including routine inspections and leak surveys, ensuring long-term safety and compliance.

  
  

✅ Process Summary

Stage	Primary Actions
Program Eligibility	Regulatory approval, safety risk assessment
Application	Filing Form of Intent; detailed application & agreement with utility
Planning & Permitting	Engineering design, resident engagement, local permits
Construction & Conversion	Install utility infrastructure “to the meter”; optional joint trenching
Decommission Old System	Shut down private piping; park assists beyond meter
Direct Utility Service	Transition residents to individual service and billing
Integrity Management	Utility assumes system mapping, leak detection, maintenance, emergency planning
Ongoing Oversight	Conformity with PHMSA and state pipeline safety standards

This blog post outlines the typical public-utility-led elimination of a master-meter system through a conversion program. If your company owns/operates a master meter system —such as in Pennsylvania, The Oak Tree Group can help walk your company through the process, engaging with the gas utility. Note, that each gas public utility has its own process for conversion and each master meter conversion has unique details that are handled on a case-by-case basis by the utility. The conversion process is not a quick process and can take years to complete. In the meantime, The Oak Tree Group, can help the master meter operator to be in compliance with federal (49 CFR 191 & 192) and state gas pipeline safety regulations. Please reach out to us, to see how we can help your company!