A collaboration between Lewis McLain & AI

It’s not if, but when!

Natural gas infrastructure is the most invisible—and therefore the most misunderstood—critical system in modern cities. Power lines are visible. Water mains announce themselves through pressure and flow. Roads crack and bridges age in plain sight. But gas lines remain buried, silent, and largely forgotten—until something goes wrong.

That invisibility is not benign. It creates a governance gap where responsibility is fragmented, risk is assumed rather than measured, and accountability is episodic instead of continuous. As cities grow denser, older, and more complex, that gap widens.

This essay makes a simple but demanding case: cities should require annual, technical accountability briefings from gas utilities and structured gas-safety evaluations for high-occupancy buildings—public and private—because safety is no longer assured by age, ownership boundaries, or regulatory compliance alone.

The ultimate question is not whether gas systems are regulated. They are.
The question is whether, at the local level, we are actually safer than we were a year ago.

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I. The Aging Gas Network: A Technical Reality, Not a Hypothetical

Much of the U.S. gas distribution network was installed decades ago. While significant modernization has occurred, legacy materials—particularly cast iron and bare steel—still exist in pockets, often in the very neighborhoods where density, redevelopment, and consequence are highest.

These systems age in predictable ways:

• Material degradation such as corrosion, joint failure, and metal fatigue
• Ground movement from expansive soils, drought cycles, and freeze–thaw conditions
• Pressure cycling driven by modern load variability
• Construction interaction, including third-party damage during roadway, utility, and redevelopment projects

Technically speaking, aging is not a binary condition. It is a curve. Systems do not fail all at once; they fail where stress, material fatigue, and external disturbance intersect. Cities that approve redevelopment without understanding where those intersections lie are not managing risk—they are inheriting it.

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II. Monitoring Is Better Than Ever—But It Is Not Replacement

Modern gas utilities deploy advanced leak detection technologies that did not exist a generation ago: mobile survey vehicles, high-sensitivity handheld sensors, aerial detection, and in some cases continuous monitoring.

Regulatory standards have improved as well. Leak surveys are more frequent, detection thresholds are lower, and repair timelines are clearer. From a technical standpoint, the industry is better at finding leaks than it was even a few years ago.

But monitoring is inherently reactive. It detects deterioration after it has begun. It does not restore structural integrity. It does not change the age profile of the system. It does not eliminate brittle joints or corrosion-prone materials.

Replacement is the only permanent risk reduction. And replacement is expensive, disruptive, and largely invisible unless cities require it to be discussed openly.

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III. Why Annual Gas Utility Accountability Briefings Are Essential

Gas utilities operate under long-range capital replacement programs driven by regulatory approval, rate recovery, and internal prioritization models. Cities operate under land-use approvals, zoning changes, density increases, and redevelopment pressures that can change risk far faster than infrastructure plans adjust.

An annual gas utility accountability briefing is how those two worlds reconnect.

Not a promotional update. Not a general safety overview. But a technical, decision-grade briefing that allows city leadership to understand:

• What materials remain in the ground
• Where risk is concentrated
• How fast legacy systems are being retired
• Whether replacement is keeping pace with growth
• Where development decisions may be increasing consequence

Without this, cities are effectively approving new intensity above ground while assuming adequacy below it.

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IV. The Forgotten Segment: From the Meter to the Building

Most gas incidents that injure people do not originate in transmission pipelines or deep mains. They occur closest to occupied space—often in the short stretch between the gas meter and the building structure.

Legally, responsibility is clear:

• The utility owns and maintains the system up to the meter.
• The property owner owns everything downstream.

Assessment, however, is not.

Post-meter gas piping is frequently:

• Older steel without modern corrosion protection
• Stressed by foundation movement
• Altered during remodels and additions
• Poorly documented
• Rarely inspected after initial construction

Utilities generally do not inspect customer-owned piping. Building departments see it only during permitted work. Fire departments respond after leaks are reported. Property owners often do not realize they own it.

This creates a true orphaned asset class: high-consequence infrastructure with no lifecycle oversight.

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V. Responsibility Alone Is Not Safety

Cities often take comfort in the legal distinction: “That’s private property.” Legally, that is correct. Practically, it is insufficient.

Gas does not respect ownership boundaries. A failure inside a school, apartment building, restaurant, or nursing home becomes a public emergency immediately.

Risk governance does not require cities to assume liability. It requires them to ensure that someone is actually evaluating risk in places where failure would have severe consequences.

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VI. Required Gas-Safety Evaluations for High-Occupancy Properties

This is the missing pillar of modern gas safety.

Just as elevators, fire suppression systems, and boilers undergo periodic inspection, gas piping systems in high-occupancy buildings should be subject to structured evaluation—regardless of whether the building is publicly or privately owned.

Facilities warranting mandatory evaluation include:

• Schools (public and private)
• Daycares
• Nursing homes and assisted-living facilities
• Hospitals and clinics
• Large multifamily buildings
• Assembly venues (churches, theaters, gyms)
• Restaurants and food-service establishments
• High-load commercial and industrial users

These are places where evacuation is difficult, ignition sources are common, and consequences are magnified.

A gas-safety evaluation should assess:

• Condition and material of post-meter piping
• Corrosion, support, and anchoring
• Stress at building entry points
• Evidence of undocumented modifications or abandoned lines
• Accessibility and labeling of shutoff valves

These evaluations need not be frequent. They need to be periodic, triggered, and credible.

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VII. Triggers That Make the System Work

Cities can implement this framework without blanket inspections by tying evaluations to specific events:

• Change of occupancy or use
• Major remodels or additions
• Buildings reaching certain age thresholds when work is permitted
• Repeated gas odor or leak responses
• Sale or transfer of high-occupancy properties

This approach focuses effort where risk is most likely to have changed.

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VIII. Public vs. Private: One Standard of Care

A gas explosion in a public school is not meaningfully different from one in a private daycare or restaurant. The victims do not care who owned the pipe.

A city that limits safety evaluation requirements to public buildings is acknowledging risk—but only partially. The standard should be risk-based, not ownership-based.

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IX. Are We Better or Worse Off Than a Year Ago?

Technically, the answer is nuanced.

We are better off nationally in detection capability and regulatory clarity. Technology has improved. Survey frequency has increased. Reporting is stronger.

But many cities are likely worse off locally in exposure:

• Buildings are older
• Density is higher
• Construction activity is heavier
• Post-meter piping remains largely unassessed
• High-occupancy facilities rely on outdated assumptions

So the honest answer is this:

We are better at finding problems—but not necessarily better at eliminating risk where people live, work, and gather.

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X. Governance Is the Missing Link

Gas safety is no longer only an engineering problem. It is a governance problem.

Cities already regulate:

• Land use and density
• Building permits and occupancy
• Business licensing
• Emergency response coordination

Requiring annual gas utility accountability briefings and targeted gas-safety evaluations does not expand government arbitrarily. It closes a blind spot that modern urban conditions have exposed.

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Conclusion: Asking the Right Question, Every Year

The most important question cities should ask annually is not:

“Did the utility comply with regulations?”

It is:

“Given our growth, our buildings, and our infrastructure, are we actually safer than we were last year?”

If city leaders cannot answer that clearly—above ground and below—it is not because the answer is unknowable.

It is because no one has required it to be known.

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**Appendix A

Model Ordinance: Gas Infrastructure Accountability and High-Occupancy Safety Evaluations**

This model ordinance is designed to improve transparency, situational awareness, and public safety without transferring ownership, operational control, or liability from utilities or property owners to the City.

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Section 1. Purpose and Findings

1.1 Purpose

The purpose of this ordinance is to:

1. Improve transparency regarding the condition, monitoring, and replacement of gas infrastructure;
2. Ensure that risks associated with aging gas systems are identified and reduced over time;
3. Require periodic gas safety evaluations for high-occupancy buildings where consequences of failure are greatest;
4. Strengthen coordination among gas utilities, property owners, and City emergency services; and
5. Establish consistent, decision-grade information for City leadership.

1.2 Findings

The City Council finds that:

1. Natural gas infrastructure is largely underground and not visible to the public.
2. Portions of the gas system—including customer-owned piping—may age without systematic reassessment.
3. Increased density, redevelopment, and construction activity elevate the consequences of gas failures.
4. Existing regulatory frameworks do not provide city-specific visibility into system condition or replacement progress.
5. Periodic reporting and targeted evaluation improve public safety without assuming utility or private ownership responsibilities.

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Section 2. Annual Gas Utility Accountability Briefing

2.1 Requirement

Each gas utility operating within the City shall provide an Annual Gas Infrastructure Accountability Briefing to the City Council or its designated committee.

2.2 Scope

The briefing shall address, at a minimum:

• Pipeline materials and age profile;
• Replacement progress and future plans;
• Leak detection, classification, and repair performance;
• High-consequence areas and impacts of development;
• Construction coordination and damage prevention;
• Emergency response readiness and communication protocols.

2.3 Format and Standards

• Briefings shall include written materials, maps, and data tables.
• Metrics shall be presented in a year-over-year comparable format.
• Information shall be technical, factual, and suitable for governance decision-making.

2.4 No Transfer of Liability

Nothing in this section shall be construed to transfer ownership, maintenance responsibility, or operational control of gas facilities to the City.

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Section 3. High-Occupancy Gas Safety Evaluations

3.1 Covered Facilities

Gas safety evaluations are required for the following facilities, whether publicly or privately owned:

• Schools (public and private)
• Daycare facilities
• Nursing homes and assisted-living facilities
• Hospitals and medical clinics
• Multifamily buildings exceeding [X] dwelling units
• Assembly occupancies exceeding [X] persons
• Restaurants and commercial food-service establishments
• Other facilities designated by the Fire Marshal as high-consequence occupancies

3.2 Scope of Evaluation

Evaluations shall assess:

• Condition and materials of post-meter gas piping
• Corrosion potential and structural support
• Stress at building entry points and foundations
• Evidence of undocumented modifications or abandoned piping
• Accessibility, labeling, and operation of shutoff valves

3.3 Qualified Evaluators

Evaluations shall be conducted by:

• Licensed plumbers,
• Licensed mechanical contractors, or
• Professional engineers with gas system experience.

3.4 Triggers

Evaluations shall be required upon:

• Change of occupancy or use;
• Major remodels or building additions;
• Buildings reaching [X] years of age when permits are issued;
• Repeated gas odor complaints or leak responses;
• Sale or transfer of covered properties, if adopted by the City.

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Section 4. Documentation and Compliance

4.1 Certification

Property owners shall submit documentation certifying completion of required evaluations.

4.2 Corrective Action

Identified hazards shall be corrected within timeframes established by code officials.

4.3 Enforcement

Non-compliance may result in:

• Withholding of permits or certificates of occupancy;
• Temporary suspension of approvals;
• Administrative penalties as authorized by law.

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Section 5. Education and Coordination

The City shall:

• Provide educational materials clarifying ownership and safety responsibilities;
• Coordinate with gas utilities on public outreach;
• Integrate findings into emergency response planning and training.

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**Appendix B

Annual Gas Utility Accountability Briefing — Preparation Checklist**

This checklist ensures annual briefings are consistent, measurable, and focused on risk reduction rather than general compliance.

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I. System Inventory & Condition

☐ Total pipeline miles within city limits (distribution vs. transmission)
☐ Pipeline miles by material type
☐ Pipeline miles by decade installed
☐ Location and extent of remaining legacy materials
☐ Identification of oldest segments still in service

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II. Replacement Progress

☐ Miles replaced in the previous year (by material type)
☐ Five-year replacement plan with schedules
☐ Funded vs. unfunded replacement projects
☐ Year-over-year reduction in legacy materials
☐ Explanation of changes from prior plans

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III. Leak Detection & Repair Performance

☐ Total leaks detected (normalized per mile)
☐ Leak classification breakdown
☐ Average and maximum repair times by class
☐ Repeat leak locations identified and mapped
☐ Root-cause analysis of recurring issues

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IV. Monitoring Technology

☐ Detection technologies currently deployed
☐ Survey frequency achieved vs. required
☐ Use of advanced or emerging detection tools
☐ Known limitations of monitoring methods

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V. High-Consequence Areas

☐ Definition and criteria for high-consequence zones
☐ Updated risk maps
☐ Impact of new development on risk profile
☐ Trunk lines serving rapidly densifying areas

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VI. Construction & Damage Prevention

☐ Third-party damage incidents
☐ 811 ticket response performance
☐ High-risk project types identified
☐ Coordination procedures with City capital projects

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VII. Emergency Response Readiness

☐ Incident response timelines
☐ Coordination with fire, police, and emergency management
☐ Date and scope of last joint exercise or drill
☐ Public communication and notification protocols

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VIII. Customer-Owned (Post-Meter) Piping

☐ Incidents involving post-meter piping
☐ Common failure materials or conditions
☐ Customer education and outreach efforts
☐ Voluntary inspection or assistance programs

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IX. Forward-Looking Risk Assessment

☐ Top unresolved risks
☐ Areas of greatest concern
☐ Commitments for the next 12 months
☐ Clear answer to:
“Are we safer than last year—and why?”

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Closing Note

A briefing that cannot complete this checklist is not incomplete—it is revealing where risk remains unmanaged.

That visibility is the purpose of accountability.