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HomeMy WebLinkAbout02-21-18-02/CMN-RUS, Inc d/b/a Metronet/+25,000/Memorandum of Understanding for Corrective Action Plan Dealing With Underground Pipeline HitsRESOLUTION NO. BPW 02-21-18-02 RESOLUTION OF THE CITY OF CARMEL BOARD OF PUBLIC WORKS AND SAFETY ACKNOWLEDGING RECEIPT OF CONTRACT WHEREAS, pursuant to Indiana Code 36-1-4-7, the City of Carmel, Indiana ("City"), is authorized to enter into contracts; and WHEREAS, pursuant to Indiana Code 36-4-5-3, the City's mayor may enter into contracts on behalf of the City; and WHEREAS, pursuant to his authority under Indiana law, the City's mayor, the Honorable James C. Brainard, has caused to be signed the City contract attached hereto as Exhibit A (the "Contract"); and WHEREAS, Mayor Brainard now wishes to present the contract to the City's Board of Public Works and Safety for it to be publicly acknowledged, filed in the Clerk -Treasurer's Office, and made available to the public for review. follows: NOW, THEREFORE, BE IT RESOLVED by the City of Carmel Board of Public Works and Safety as 1. The foregoing Recitals are incorporated herein by this reference. 2. The receipt of the Contract is hereby acknowledged. 3. The Contract shall be promptly filed in the office of the Clerk -Treasurer and thereafter made available to the public for review. SO RESOLVED this " I day of f , 2018. CITY OF CARMEL, INDIANA By and through its Board of Public Works and Safety BY: /7 � -Z/4.1_ - J es Brainard, Presidi Of r Date: ,f 000 MarjAnn urke, Mem er Date: Lori S. Wats n, er Date: ori A 7 7 Chnstine Pauley, Clerk -T easu��/�� Date: SAE BassWy Documents\BPW-Resolutions\2018Wcknowledge MOU City and Metronet.docx2/212018 10:26 AM MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY OF CARMEL AND CMN-RUS, INC., D/B/A METRONET THIS MEMORANDUM OF UNDERSTANDING ("MOU"), is hereby entered into this 22nd day of January, 2018, (the "Effective Date") by and between the City of Carmel, an Indiana municipal corporation ("City") and CMN-RUS, Inc., an Indiana Corporation, d/b/a Metronet and its affiliates (collectively "Metronet"), City and Metronet are sometimes hereinafter referred to individually as a "Party", and collectively as the "Parties". WITNESSETH: WHEREAS, the City is a municipality located in Hamilton County, Indiana and Metronet is a communications service provider with headquarters in Evansville, Indiana; WHEREAS, during the installation of Metronet's facilities within the City's municipal boundaries, Metronet's contractors hit underground gas lines on ire (.g separate occasions in 2017 (collectively, the "Underground Pipeline Hits"); n'Y) e. C WHEREAS, in response to the Underground Pipeline Hits, on August 30, 2017, the City issued a stop work order halting all new utility work by Metronet, as a matter of public safety, which continues to be in effect (the "Stop Work Order"); WHEREAS, the Indiana Utility Regulatory Commission ("IURC") conducted an investigation of the Underground Pipeline Hits and found Metronet's contractors at fault for €we fnu r k5} of the hits (collectively the "Contractor Pipeline Hits"), and provided recommendations for � E5 corrective action for Metronet's construction activities ("IURC Recommendation"), which are attached hereto and incorporated herein as Exhibit A; WHEREAS, Metronet has an established internal Underground Construction Safety Plan and has revised it to include extra precautions, which is attached hereto and incorporated herein as Exhibit B ("Metronet's Safety Plan"); WHEREAS, utilizing the IURC Recommendation, and in furtherance of public safety, the City wishes to implement its best practices for excavation within the City's boundaries, including but not limited to the City's right-of-way, as more particularly defined in paragraph 2 herein (the "City's Corrective Action Plan"); WHEREAS, the City intends to codify the City's Corrective Action Plan which will be applicable to all utilities excavating within the City's municipal boundaries in the near future (the "Official Action"), but recognizing that time is of the essence, the Parties wish to enter into this MOU to allow Metronet to begin construction work sooner than the time necessary to enact the Ordinance; WHEREAS, the Parties have agreed that Metronet will implement and abide by both the City's Corrective Action Plan set forth in paragraph 2(b) hereof and Metronet's Safety Plan and MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY OF CARMEL AND CMN-RUS, INC., D/B/A METRONET THIS MEMORANDUM OF UNDERSTANDING ("MOU"), is hereby entered into this 22"d day of January, 2018, (the "Effective Date") by and between the City of Carmel, an Indiana municipal corporation ("City") and CMN-RUS, Inc., an Indiana Corporation, d/b/a Metronet and its affiliates (collectively "Metronet"), City and Metronet are sometimes hereinafter referred to individually as a "Party", and collectively as the "Parties". WITNESSETH: WHEREAS, the City is a municipality located in Hamilton County, Indiana and Metronet is a communications service provider with headquarters in Evansville, Indiana; WHEREAS, during the installation of Metronet's facilities within the City's municipal boundaries, Metronet's contractors hit underground gas lines onfilm (51 se ara asions in 2017 (collectively, the "Underground Pipeline Hits"); ,n f Y) e. ( T) WHEREAS, in response to the Underground Pipeline Hits, on August 30, 2017, the City issued a stop work order halting all new utility work by Metronet, as a matter of public safety, which continues to be in effect (the "Stop Work Order"); WHEREAS, the Indiana Utility Regulatory Commission ("IURC") conducted an investigation of the Underground Pipeline Hits and fowid Metronet's contractors at fault for five .FaQr {.5.} of the hits (collectively the "Contractor Pipeline Hits"), and provided recommendations for corrective action for Metronet's construction activities ("IURC Recommendation"), which are attached hereto and incorporated herein as Exhibit A; WHEREAS, Metronet has an established internal Underground Construction Safety Plan and has revised it to include extra precautions, which is attached hereto and incorporated herein as Exhibit B ("Metronet's Safety Plan"); WHEREAS, utilizing the IURC Recommendation, and in furtherance of public safety, the City wishes to implement its best practices for excavation within the City's boundaries, including but not limited to the City's right-of-way, as more particularly defined in paragraph 2 herein (the "City's Corrective Action !'fail"); WHEREAS, the City intends to codify the City's Corrective Action Plan which will be applicable to all utilities excavating within the City's municipal boundaries in the near future (the "Official Action"), but recognizing that time is of the essence, the Parties wish to enter into this MOU to allow Metronet to begin construction work sooner than the time necessary to enact the Ordinance; WHEREAS, the Parties have agreed that Metronet will implement and abide by both the City's Corrective Action Plan set forth in paragraph 2(b) hereof and Metronet's Safety Plan and the City will terminate the Stop Work Order so that Metronet can continue its new utility work within the City; and WHEREAS, the Parties desire to memorialize their agreement, as more particularly described below, to be in full force and effect during the Tenn of this MOU. NOW, THEREFORE, in consideration of the premises, the terms and conditions hereof, and other good and valuable consideration, City and Metronet express the following understanding: 1. Incorporation of Recitals. The Recitals set forth above are material to this MOU and are incorporated into and form a part of this MOU, as if they were fully set forth hereto. 2. Metronet's Responsibilities. a. Metronet's Safety Plan. Metronet hereby agrees to implement and abide by the Metronet Safety Plan. b. City's Corrective Action Plan. Metronet hereby agrees to abide by the City's Corrective Action Plan, which specifically includes the following: i. Training. Metronet construction personnel assigned to supervise and monitor the work of its contractor shall have completed the IURC Pipeline Safety Division training ("IURC Training") and shall supply the City with proof of its completion prior to excavating within the City. Metronet shall require its contractors to complete IURC Training prior to excavating within the City. ii. Emergency Response & Associated Cost Reimbursement. Metronet shall reimburse City for all reasonable and necessary expenses incurred in taking emergency action when responding to the Contractor Pipeline Hits. Metronet further agrees to pay the City's costs associated with this MOU, which, together with the costs for the Contractor Pipeline Hits shall be Twenty -Five Thousand Dollars ($25,000). iii. Metronet Personnel. Metronet will have a Metronet employee and/or inspector(s) readily available at each dig site that can effectively communicate with property owners, residents and City staff about Metronet's digging, construction and restoration activities. iv. Potholing. Metronet shall pothole every utility crossing. A Metronet inspector will inspect the pothole and construction area and will authorize each boring. Any potholing within roadway pavement shall have an approved City road cut permit prior to potholing. Any pothole within roadway pavement shall be restored in accordance with City of Carmel requirements. V. Restoration and Complaints. Metronet shall visit each property that has an outstanding restoration complaint as of the Effective Date and meet with the property owner to determine how to restore the property to the property owner's reasonable satisfaction. Notwithstanding the foregoing, in no event will Metronet be required to repair, replace or restore any personal property of a property owner 2 that was improperly located in a utility easement. Borings which occur after the Effective Date shall be restored within three (3) business days of the boring and shall be subject to an inspection by the City. Consideration will be given to the amount of restoration needed with each boring and the boring will be conducted in a manner which requires the least amount of restoration (i.e. using streets and sidewalks for equipment rather than lawns, etc.) Directly after any boring under the street / curb and sidewalks, Metronet shall inspect for any heaving that may have occurred from the boring process and advise the City of the damage and put on a high priority list to repair. vi. Handholes, pedestals and flower pots. Handholes, pedestals, and flower pots shall be installed at grade (as applicable), level, and square with sidewalks, curbs, drives, and streets. vii. Notification to Property Owners. Metronet shall notify each property owner and the homeowners association (if one exists) of its presence within the neighborhood or on the property no more than thirty (30) days prior to entering the property for any excavation. Notification shall be sent via letters and yard darts stating at a minimum that (a) Metronet and/or its contractor will be in their area and possibly on their property, (b) what work will be completed on their property, and (c) contact information for Metronet. Signs shall be placed at the entrances of neighborhoods stating that Metronet will be doing work in their neighborhood. Proof of notifications shall be provided to the City upon request of the City. viii. Notification to 911, 811, utility and City. If any further underground facility hits occur after the Effective Date, Metronet will ensure that 911, 811, the underground utility and the City Engineering Department are notified. City Engineering Department can be notified at (317) 595- 3160. ix. Metronet and its contractors will participate in the Indiana Damage Prevention Council for the areas in which Metronet contractors are excavating. X. Metronet shall contact Vectren in advance of excavations so that both Metronet and Vectren know in advance of where Metronet's contractors will be working to ensure adequate location resources are made available Metronet will ensure that its contractors are trained to adhere to the Metronet Safety Plan and the City's Corrective Action Plan. To the extent that the Metronet Safety Plan conflicts with the terms of the City's Corrective Action Plan, the City's Corrective Action Plan will take precedence. 3. City's Responsibilities. In exchange for Metronet's implementation of the Metronet Safety Plan and the City's Corrective Action Plan, City agrees to terminate the Stop Work Order and allow Metronet to begin construction activity within the municipal boundaries of the City, beginning the Effective Date in accordance with the terms of this MOU. The City agrees that the effective date of any permits issued to Metronet that were unexpired prior to the issuance of the Stop Work Order will be extended by the number of days the Stop Work Order was in place. The City further agrees not to unreasonably delay the issuance or denial of future Metronet permit applications. 3 4. Term. This MOU shall remain in effect until the earlier of the effective date of the Official Action or April 15, 2018. 5. Breach. In the event that Metronet has five (5) hits to underground gas lines (each a "Utility Hit" collectively the "Utility Hits") in a one (1) month period or two (2) Utility Hits in one (1) week, or fails to abide by the terms of this MOU, the City may, in its reasonable discretion, declare Metronet in breach of the terms of this MOU and impose one or more of the penalties described in Paragraph 6 below. Metronet shall not be in breach of this MOU for any Utility Hit: a) resulting from the failure of a locating entity to accurately mark the location of the stricken underground facility; or b) to any underground facility, including but not limited to sprinkler heads, that are improperly situated in a utility easement. 6. Penalty. In addition to any other penalty or remedy allowable by Indiana law, the City may take one or a combination of the following actions upon breach of Metronet: a. Stop Work Order. The City may institute one or more temporary or permanent stop work orders, at City's reasonable discretion, and Metronet agrees to stop work immediately upon receipt of the stop work order. The parties shall work together to determine the best course of action in order to correct the breach and lift the stop work order. The City shall not unreasonably delay terminating a stop work order. b. Fines. The City may impose fines consistent with IC 36-1-3-8, without proceeding as it would for enforcement of a violation of Carmel Code of Ordinances. The amount of the fine will be determined by the severity of the breach but shall not exceed five hundred dollars ($500) per each breach. C. Reimbursement of City's costs. City may seek reimbursement of any costs it incurs due to the breach, including but not limited to reasonable and demonstrated inspection fees and emergency response personnel costs. 7. Process for Determining Breach and Penalty. Within ten (10) business days of learning of an alleged breach of this MOU, the City shall notify Metronet in accordance with Section 8, which notice shall also include the City's determination of any breach and any fine or cost associated therewith ("Notice"). Metronet shall remit any payment to the City within ten (10) business days of receiving Notice, unless Metronet requests a conference with the City to exchange information regarding the alleged breach and appropriate penalty ("Conference"), which Conference shall occur within twenty (20) business days after receiving Notice. Within ten (10) business days after the Conference, the City's designated representatives shall inform Metronet of its final determination of a breach and any fine or cost associated therewith (the "Final Determination"). In the event Metronet disputes the Final Determination, it shall notify the City within seven (7) business days after receiving notice of the Final Determination, of its request to appeal the Final Determination ("Appeal"). Any Appeal shall be submitted to the City's Board of Public Works & Safety ("Board"), who shall place the Appeal on its agenda during its regularly scheduled meeting. The Board's decision on the Appeal shall be final appealable order pursuant to IC 36-1-6-9. Notwithstanding the foregoing or anything contained herein to the contrary, the City may take any action consistent with Section 6 herein, including 2 the implementation of a Stop Work Order, as the parties process each breach pursuant to this Section 7. 8. Notice. Any and all notices given under this MOU shall be in writing and sent to the other party at its address set forth below. Notices may be sent via certified mail (return receipt requested) or by nationally -recognized overnight courier (e.g. Federal Express). If to City: City of Carmel Corporation Counsel One Civic Square, 3d Floor Carmel, IN 46032 If to Metronet: Metronet Attn: General Counsel 8837 Bond St. Overland Park, KS 66214 9. Miscellaneous. a. Amendment. This MOU and its exhibits attached hereto, may be amended and/or modified only by the written agreement of both Parties. No waiver, modification or amendment of any term, condition or provision of this Agreement shall be valid or have any force or effect unless made in writing and signed by the Parties. b. Mutual Assistance. The Parties hereto agree, subject to further proceedings required by law, to take such actions, including the execution and delivery of such other documents, as may be reasonably necessary or appropriate, from time to time, to carry out the terms, provisions, and intent of this MOU. C. Governing Law. The MOU shall be governed by and construed under the laws of the State of Indiana. All disputes or proceeding arising in connection with this MOU shall be adjudicated in Hamilton County, Indiana. d. Change of Law. If a change in law occurs during the term of this MOU, then either Party may notify the other to express its opinion on any necessary changes to the terms of the MOU in order to be in compliance with the new law. If the Parties agree on the change to the MOU, then a written amendment specifying the changes shall be executed by the Parties. e. Initial Statement. Upon execution of this MOU, the City shall release a statement in substantially similar form to Exhibit C, attached hereto and incorporated herein. 10. In witness whereof, the Parties, by their respective duly authorized officers, have execute this MOU as of the day and year first written above. 5 CITY OF CARMEL, INDIANA By. 1 3345873_1 CMN-RUS, INC. B Indiana Utility Regulatory Commission Pipeline Safety Division Investigation Summary and Options Regarding MetroNet's Construction Activities As of September 12, 2017 At the request of the City of Fishers ("Fishers"), the City of Carmel ("Carmel"), and the City of Westfield ("Westfield"), the Pipeline Safety Division ("PSD" or "Division") of the Indiana Utility Regulatory Commission ("IURC" or "Commission") is providing this investigation summary and a list of options to improve public safety regarding contractors working on behalf of CMN-RUS, Inc., d/b/a MetroNet ("MetroNet"). All three communities have placed a halt on MetroNet contractors excavating in public rights-of-way. The incident in Westfield that just occurred on Friday, September 8, 2017, is under investigation at this time; therefore, only preliminary information is being provided now, with a final investigation summary to be provided once that investigation is completed. This document contains the following: A. Investigation Summary 1) Specific Case Information for Fishers 2) Specific Case Information for Carmel 3) Preliminary Information for Westfield 4) Failure to Register with Indiana Secretary of State 5) Additional Information Withheld by MetroNet 6) Safe Digging Best Practices B Options for Correction Action Regarding MetroNet's Construction Activities C. Attachments 1) Investigation Reports for each case 2) Letter from Chairman Atterholt to Indiana Attorney General regarding failure to register with Indiana Secretary of State 3) Safe Digging Best Practices Exhibit (o -F3 y A. Investigation Summary: This investigation summary includes a summary of the PSD findings regarding specific cases of damaged gas lines in Fishers and Carmel and preliminary information regarding the recently damaged gas line in Westfield, as well as other information discovered by PSD and Commission staff during the course of the investigation. The Investigation Reports are attached and are in order by case number. Of the 20 cases investigated for Fishers and Carmel, the Division found that ten (10) cases were violations by the excavators (i.e., MetroNet contractors), six (6) cases were violations by the gas utility (i.e., Indiana Gas Company d/b/a Vectren), and four (4) cases involved no violations. 1) Specific Case Information for Fishers: Of the 11 incidents of damage to gas lines in Fishers, six (6) were violations by the MetroNet contractor (for using mechanized equipment within two feet of the marked gas lines and for failure to plan when using hand tools); four (4) were violations by Indiana Gas Company d/b/a Vectren, the operator of the gas lines (for failure to properly mark the lines); and one (1) was no violation (as the excavator was using hand tools and there was no evidence of a failure to plan the excavation); 0 Crosier Lane Consulting, Inc. o Case #16484 — 6/19/2017 — excavator violation (used mechanized equipment within 2 feet of marked line) o Case #16524— 6/20/2017 —excavator violation (used mechanized equipment within 2 feet of marked line) • International, Inc. o Case #16746 — 8/15/2017 — excavator violation (failure to plan in use of hand tools) o Case #16810 — 8/14/2017 — no violation (appropriate use of hand tools) o Case #16811— 8/17/2017 — excavator violation (failure to plan in use of hand tools) o Case #16812 — 8/24/2017 — excavator violation (used mechanized equipment within 2 feet of marked line) • RC Underground, LLC o Case #16008 —4/25/2017 —operator violation (failure to properly mark) o Case #16013 —4/26/2017 —operator violation (failure to properly mark) o Case #16521— 6/29/2017 —operator violation (failure to properly mark) o Case #16694 — 8/1/2017 — excavator violation (failure to plan in use of hand tools) Exhibit • RLM Underground, LLC o Case #16813 — 8/24/2017 — operator violation (failure to properly mark) 2) Specific Case Information for Carmel: Of the nine (9) incidents of damage to gas lines in Carmel, four (4) were violations by the MetroNet contractor (for using mechanized equipment within two feet of the marked gas lines and for failure to plan when using hand tools); two (2) were violations by Indiana Gas Company d/b/a Vectren, the operator of the gas lines (for failure to properly mark the lines); and three (3) were no violation (as the excavator was using hand tools and there was no evidence of a failure to plan the excavation); • International, Inc. o Case #16726 — 8/9/2017 — operator violation (failure to properly mark) • Nexgen Directional, LLC o Case #16392 — 5/30/2017 —excavator violation (used mechanized equipment within 2 feet of marked line) o Case #16480 — 6/16/2017 — no violation (appropriate use of hand tools) o Case #16660 — 7/21/2017 — no violation (appropriate use of hand tools) • Radical Concepts, LLC (d/b/a Palindrome Construction) o Case #16635 — 7/18/2017 — excavator violation (failed to call 811 to renew marks) o Case #16640— 7/18/2017 —excavator violation (digging ticket expired) o Case #16708 — 8/2/2017 — excavator violation (digging in area outside of ticket) • RLM Underground, LLC o Case #16722 — no violation (appropriate use of hand tools) o Case #16727 — operator violation (failure to properly mark) 3) Preliminary Information for Westfield: According to some initial information provided by employees of Citizens Gas of Westfield ("Citizens"), the information indicates that a gas line was damaged at 121 S. Walnut Street in Westfield, Indiana, on Friday, September 8, 2017, by International Inc., a subcontractor for MetroNet. The gas leaking from the damage migrated underground to the sewer system, the Fire Department responded, homes in the vicinity were evacuated, and electricity was turned off by Duke Energy Indiana, LLC, until the gas line was repaired. Citizens promptly reported this incident to the Commission's Pipeline Safety Division, and PSD investigators were at the scene of the event immediately after being notified and they are actively investigating the incident under Case #16872. Exhibit Excavation damages to gas lines that result in the migration of natural gas underground through sewer systems and into basements is extremely dangerous and often leads to explosions, with injuries and loss of life. 4) Failure to Register with Indiana Secretary of State: In order to assure accurate addresses for legal notices, the Commission's Office of General Counsel researched each of the contractors under investigation, reviewing information on the website and on-line services of the Indiana Secretary of State. That review discovered that it appears all six (6) contractors are out-of-state entities and all but one of the contractors has not registered with the Indiana Secretary of State as required under Indiana law. Specifically, it appears that the following MetroNet contractors have not registered as required by Indiana law: • Crosier Lane Consulting, Inc. (Illinois business) • International, Inc. (Michigan business) • Nexgen Directional, LLC (Illinois business) • R C Underground, LLC (Florida business) • R L M Underground, LLC (Kansas business) This failure to comply with Indiana law makes the Pipeline Safety Division's important public safety function more difficult. As a result, the IURC's Chairman is referring this information to the Indiana Office of Attorney General for review and possible fines of up to $10,000 per company. Please see attached letter. Note: Radical Concepts, LLC (d/b/a Palindrome Construction) is a New Jersey company and has registered in Indiana. 5) Additional Information Withheld by MetroNet: The Division requested that MetroNet provide a list of its contractors excavating in Indiana. To date, the Division has not requested information on the company hiring an excavating contractor because the "Call Before You Dig" law only allows enforcement against the person or entity that caused the excavation damage, not the company who hired them. However, in order to have a clearer understanding of what was happening with the damage cases involving MetroNet's contractors throughout the State of Indiana, the Division believed that having such information may be helpful in determining trends or patterns of damages, which may then be corrected. MetroNet's counsel declined to provide the list, stating that it was "competitively sensitive information." F In-blt A AJC, L/ In addition, economic or contract incentives to quickly complete a project involving excavation can affect whether the appropriate safe digging practices are being followed. As a result, the Division requested a copy of a sample contract between MetroNet and its contractors, with any trade secret information appropriately redacted. Even though the Commission is required to protect trade secret information under state law, MetroNet's counsel declined to provide even a redacted sample contract, stating that it was "competitively sensitive information." 6) Safe Digging Best Practices: The Division has attached a list of safe digging best practices from the Common Ground Alliance, a national pipeline safety organization — see attached document. A complete book of best practices is available at: http://commongroundalliance.com/best-practices-guide ) Exhibit 6o T L� B. Options for Corrective Action Regarding MetroNet's Construction Activities: The following are options that each City may want to consider in its determination regarding the conditions under which MetroNet contractors may be allowed to resume the installation of fiber optic cable in the City: 1) Documentation that MetroNet's executive leadership, project managers, and supervisors have taken training regarding safe digging practices and understand the requirements of Indiana's "Call Before You Dig" law (Indiana Code chapter 8-1-26), such as: a) Attendance (with a passing score) at one of the Underground Plant Protection Advisory Committee's ("UPPAC's") mandatory training classes (designed for those previously found in violation of Indiana's "Call Before You Dig" law); and/or b) Completion of the IURC sponsored online excavation damage training at https://www.safedigindiana.com/. 2) Documentation that all of MetroNet's contractor crews are trained and qualified regarding safe digging practices and understand the requirements of Indiana's "Call Before You Dig" law (Indiana Code chapter 8-1-26), such as: a) Attendance (with a passing score) at one of the Underground Plant Protection Advisory Committee's ("UPPAC's") mandatory training classes (designed for those previously found in violation of Indiana's "Call Before You Dig" law); and/or b) Completion of the IURC sponsored on-line excavation damage training at https://www.safedigindiana.com/. 3) Commitment that MetroNet's contractor crews will follow the CGA Best Practices that each City requires — see attached list of possible related best practices. 4) Documentation that all of MetroNet's contractor crews are properly registered (as needed) to do business in Indiana with 1) Indiana's Secretary of State's Office, 2) Hamilton County, or 3) the Towns of Fishers or Carmel. If such contractor crews are exempt from registration, MetroNet should provide proof to the City that their contractors are adequately insured and/or bonded and that accurate contact information (including mailing addresses and telephone numbers) has been provided to the Cities and the IURC PSD. 5) A written plan by MetroNet describing how it will demand public safety over speed of installation of its fiber optic lines by their MetroNet contractor crews, possibly including: a) Regular reporting of MetroNet contractor crew performance; Exhibit C-�q b) Contract incentives and penalties between MetroNet and its contractors designed to avoid further incidents; and/or C) MetroNet showing that it vets its contractor crews and they know they are expected to focus on public safety, not simply footage. 6) A written plan by Indiana Gas Company (dba Vectren Energy Services) ("Vectren") describing how it will provide accurate and timely locates of Vectren's underground facilities, possibly including: a) Regular reporting of Vectren's contract locator performance to each City; and b) Contract incentives and penalties between Vectren and its contract locators designed to avoid further mis-locates. 7) Documentation that Vectren's contract locators are trained and qualified. 8) Commitment that Vectren's contract locating company, USIC, will assign more senior and experienced locators to the jobs where MetroNet contractor crews are working. 9) Commitment that MetroNet contractor crews will request additional information from the underground facility owners that they might need to help them in locating and avoiding damage to underground facilities. 10) Commitment that MetroNet will have company inspectors on-site to monitor each contractor crew to ensure safe digging practices are being followed; OR as an alternative, MetroNet will reimburse the City for the associated costs of having a City inspector on site. 11) Commitment that MetroNet will ensure its contractor crews are using hydro -excavation rather than hand tools to expose gas facilities prior to boring or trenching operations. With hard and dry soil conditions, it is very difficult to use hand tools to expose pipeline facilities. Hydro -excavation essentially uses a combination of high pressure water and a vacuum to remove soil, which is the preferred method to expose buried gas lines. 12) Commitment by MetroNet and Vectren to work together, and with other underground facility owners, to ensure all parties know well in advance of where MetroNet contractor crews will be working to ensure adequate locating resources are made available. This should provide the underground facility owners and their contract locators (if applicable) with sufficient time to adequately plan and staff for the number of notices of excavation received and allow the coordination of resources accordingly. 13) A written plan by MetroNet to achieve improved proactive communications with all of its stakeholders, including, but not limited to, the City, the City's citizens, all underground Exbibit 7d facility owners (and their locators), and MetroNet's own contract crews. This plan should focus on improved coordination of efforts and collaboration to prevent and mitigate the risks associated with any further excavation damages. 14) Commitment by MetroNet and its contractors to participate in the Indiana Damage Prevention Council for the area(s) in which the City is located and where MetroNet contractors are excavating. Information for the Indiana Damage Prevention Council Central Chapter can be found at: https://indiana8ll.org/idpccc. Exhibit STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNIDTANAPOT.N. R%MTANA 46704-3419 Famimile: (3171737-6758 Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16008 Report Date: 8/11/2017 12:00 AM Damage Date: 4/25/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 116th & Ringer Rd, Fishers Excavator: R C Underground Address: 6421 Key Island Ave Apollo Beach, FL 33572 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Distribution Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Service Interruption: No - Facility Depth (inches): 20.0000 Indiana 811 Ticket Number: 1704254341 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line correctly due to locator error. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit i STATE �/ INDIANA INDIANA UTILITY REGULATORY COMIMSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNDTANAPOT.N. INDIANA 467(14-3419 Far,;imilP- (.317)737-6755 Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16013 Report Date: 8/11/2017 12:00 AM Damage Date: 4/26/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 13868 E 116th St, Fishers Excavator: R C Underground Address: 6421 Key Island Ave Apollo Beach, FL 33572 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Distribution Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Service Interruption: Yes - 1 Facility Depth (inches): Indiana 811 Ticket Number: 1703211350 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to correctly mark the facility due to locator error. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit A roofm STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOLTS. TNDTANA 400-3419 F»rcimilP- (317)737-67..99 Pipeline Safety Division Investigation Report Investigation regarding: Nexgen Directional LLC Case Number: 16392 Report Date: 8/29/2017 12:00 AM Damage Date: 5/30/2017 12:00 AM The Parties Investigator: Michael Neal Damage Address: 13034 Abraham Run, Carmel Excavator: Nexgen Directional LLC Address: 1712 S Whittle Ave. Olney, IL 62450 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Distribution Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact Product Release: Yes Service Interruption: Yes -5 Repair Cost (if known): Facility Depth (inches): 36.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1705182041 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Both the Operator and Excavator responded to a request for more information. The Excavator was boring within the tolerance zone when the gas line was damaged. Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment. Exhibit STATE ?/ INDIANA INDIANA UTILITY REGULATORY CONUvIISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPnT.T';. TNT)TANA 46704-3419 Faodmila (3171 ?39-6759 Pipeline Safety Division Investigation Report Investigation regarding: Nexgen Directional LLC Case Number: 16480 Report Date: 9/6/2017 12:00 AM Investigator: Aaron Holeman Damage Date: 6/16/2017 12:00 AM Damage Address: 12788 Double Eagle Dr, Carmel The Parties Excavator: Nexgen Directional LLC Address: 1712 S Whittle Ave. Olney, IL 62450 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Type of Equipment: Hand Tools Type of Work Performed: Other Damage Impact Product Release: Service Interruption: - Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information: Excavator Request Locates: Excavator Notify Operator: Indiana 811 Ticket Number: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. Excavator notes that the ground was hard and there were tree roots in the area. However, neither party has pictures of the damaged line. Without that or some additional information, there is insufficient information to make a finding of IC 8-1-26-20(a)(1), failure to plan. Violation: Insufficient evidence to find violation. Exhibit —A— ljoF3{ STATE �/ INDIANA INDIANA UTILITY REGULATORY CONMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.N. TNT)TANA 400-3419 Fnrcimila! (317) 7.17-67.98 Pipeline Safety Division Investigation Report Investigation regarding: Crosier Lane Consulting, Inc. Case Number: 16484 Report Date: 8/31/2017 12:00 AM Damage Date: 6/19/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 9645 Claymore Dr, Fishers Excavator: Crosier Lane Consulting, Inc. Address: 5325 N Lakewood Road Olney, IL 62450 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): $560.78 Facility Function: Service/Drop Type of Work Performed: Cable TV Service Interruption: Yes -1 Facility Depth (inches): 28.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1706070932 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Excavator damaged an accurately marked service line with a horizontal boring machine. They had a valid request at the time of the incident, but failed to expose the line in the area of the excavation and therefore were using mechanized equipment inside the 2 -foot tolerance zone. Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment. Exhibit [ 3 A STATE 9/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOUS. TNDTANA 467M-3419 Farsimih-- (317)737-67FR Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16521 Report Date: 8/31/2017 12:00 AM Damage Date: 6/29/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 9251 Crossing, Fishers Excavator: R C Underground Address: 6421 Key Island Ave Apollo Beach, FL 33572 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: No Service Interruption: Yes - 1 Facility Depth (inches): 36.0000 Indiana 811 Ticket Number: 1706161192 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to locator error. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit �07'3� STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNDTANAPOT.TS. TNT)TANA 46904-3419 Farcimi1w (.3171737-675A Pipeline Safety Division Investigation Report Investigation regarding: Crosier Lane Consulting, Inc. Case Number: 16524 Report Date: 8/31/2017 12:00 AM Damage Date: 6/30/2017 12:00 AM The Parties Excavator: Crosier Lane Consulting, Inc. Investigator: Aaron Holeman Damage Address: 12630 Longleaf Ln, Fishers Address: 5325 N Lakewood Road Olney, IL 62450 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): $1,502.36 Facility Function: Service/Drop Type of Work Performed: Cable TV Service Interruption: Yes -1 Facility Depth (inches): 21.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1706071418 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Excavator damaged an accurately located service line with a horizontal boring machine. The excavator had a valid locate request at the time of the incident. The excavator made a pot hole and exposed a portion of the line. However, the diameter of the hole was not large enough, so when the bore came through, there was not sufficient time to stop the boring machine before it damaged the line. Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment. Exhibit STATE �/ INDIANA INDIANA UTILITY REGULATORY COh9IISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.N. TNDTANA 46?n4-3419 Farcimila- (317) TV -675A Pipeline Safety Division Investigation Report Investigation regarding: Radical Concepts d/b/a Palindrome Construction Case Number: 16635 Report Date: 9/11/2017 12:00 AM Damage Date: 7/18/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 13580 Brentwood Ln, Carmel Excavator: Radical Concepts d/b/a Palindrome Construction Address: 6623 W 13th St Indianapolis, IN 46214 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Service Interruption: Yes -1 Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1707064305 Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a service line with a horizontal boring machine. Operator properly marked the area to be excavated. The homeowner removed the flags and excavator dug without calling 811 to renew the marks. The damaged line was on the property line between 13580 and 13596. It was damaged closer to 13580 but was the line for 13596. Violation: IC 8-1-26-20(a)(3)(b) Failure to notify IN811 when locate markings have become illegible Bxhibit—A— ra3� STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNl)TANAPnT.TS. TNT)TANA 46704-3419 Farcimila: (.31 71 939-675A Pipeline Safety Division Investigation Report Investigation regarding: Radical Concepts d/b/a Palindrome Construction Case Number: 16640 Report Date: 9/11/2017 12:00 AM Damage Date: 7/18/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 1204 Smokey Row Ln, Carmel Excavator: Radical Concepts d/b/a Palindrome Construction Address: 6623 W 13th St Indianapolis, IN 46214 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Distribution Type of Work Performed: Cable TV Service Interruption: Yes -5 Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1706273510 Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a distribution main with a horizontal boring machine. They allowed their prior ticket to expire and were therefore digging without a valid request. Violation: IC 8-1-26-16(h)(expire) Failure to provide notice of excavation - expired ticket. Exhibit ef� 7 � STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.TS. TNDTANA 4004-3419 Fardmila: (317)739-67SR Pipeline Safety Division Investigation Report Investigation regarding: Nexgen Directional LLC Case Number: 16660 Report Date: 9/1/2017 12:00 AM Damage Date: 7/21/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 14370 Jeremy Dr, Carmel Excavator: Nexgen Directional LLC Address: 1712 S Whittle Ave. Olney, IL 62450 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Service/Drop Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact Product Release: Service Interruption: - Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information: Excavator Request Locates: Excavator Notify Operator: Indiana 811 Ticket Number: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. No additional information was provided by either party that would indicate a violation of IC 8-1-26-20(a)(1). Violation: Insufficient evidence to find violation. Exhibit A (`6W3 STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNDTANAPOT.N. TNDTANA 46704-1419 Far-imilac (317) 937-675R Pipeline Safety Division Investigation Report Investigation regarding: R C Underground Case Number: 16694 Report Date: 9/5/2017 12:00 AM Damage Date: 8/1/2017 12:00 AM The Parties Excavator: R C Underground Investigator: Aaron Holeman Damage Address: 9660 Overcrest Dr, Fishers Address: 6421 Key Island Ave Apollo Beach, FL 33572 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Probing Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Service Interruption: Yes -1 Facility Depth (inches): 25.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1707263022 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged an accurately marked service line with a probe rod. They were attempting to expose the line by potholing with hydro excavation, but used the probe rod when the line was not visible. The line does not appear to be brittle or otherwise have a loss of integrity. Therefore, the excavator would have used the probe rod with force to drive it into the line. Using a probe rod in this manner fails to avoid damage. Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities. Exhibit M ef3� STATE 9/ INDIANA INDIANA UTILITY REGULATORY CONR IISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.TS. TNT)TANA 4004-3419 Farcimila (317) 739-675R Pipeline Safety Division Investigation Report Investigation regarding: Radical Concepts d/b/a Palindrome Construction Case Number: 16708 Report Date: 9/11/2017 12:00 AM Investigator: Aaron Holeman Damage Date: 8/2/2017 12:00 AM Damage Address: 490 Tulip Poplar Crest, Carmel The Parties Excavator: Radical Concepts d/b/a Palindrome Construction Address: 6623 W 13th St Indianapolis, IN 46214 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Hand Tools Damage Impact Product Release: No Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Other Service Interruption: Yes -I Facility Depth (inches): 21.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1707183912 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a service line with a shovel while attempting to expose the line. The area of the damage was outside the requested scope of their ticket, therefore they were digging without a valid request in the area of the incident. Violation: IC 8-1-26-16(h)(out) Failure to provide notice of excavation - damage occurred outside requested locate area. Exhibit 2c) of3� STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.TS_ TNT)TANA 467(14-3419 Farcimila: (317)737-6755 Pipeline Safety Division Investigation Report Investigation regarding: R L M Underground Case Number: 16722 Report Date: 9/8/2017 12:00 AM Damage Date: 8/8/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 513 Chauncy Dr, Carmel Excavator: R L M Underground Address: 4902 W 57th Street Roeland Park, KS 66205 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact Product Release: Service Interruption: - Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information: Excavator Request Locates: Excavator Notify Operator: Indiana 811 Ticket Number: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. No additional information was provided by either party that would indicate a violation of IC 8-1-26-20(a)(1). Violation: Insufficient evidence to find violation. Exhibit..------ --- 2 �r STATE 9/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNJDTANAP0T.TR. TNDTANA 46704-3419 Farsimila (3171937-67.riR Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16726 Report Date: 9/1/2017 12:00 AM Damage Date: 8/9/2017 12:00 AM The Parties Excavator: International, Inc. Investigator: Aaron Holeman Damage Address: 3965 Chadwick, Carmel Address: 9971 Woodbend Dr. Saline, MI 48176 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: No Service Interruption: Yes - I Facility Depth (inches): 24.0000 Indiana 811 Ticket Number: 1707204420 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid request at the time of the incident. The operator failed to mark the line due to locator error. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit 22Ay STATE �/ INDIANA INDIANA UTTLTTY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNDIANAPOT.N. TDIANA 467(14-3419 FarcimilP- (317) 717-67.99 Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16727 Report Date: 9/1/2017 12:00 AM Damage Date: 8/9/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 515 Chauncy Street, Carmel Excavator: R L M Underground Address: 4902 W 57th Street Roeland Park, KS 66205 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: No Service Interruption: Yes - 1 Facility Depth (inches): 28.0000 Indiana 811 Ticket Number: 1707313932 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to operator's incorrect maps/records. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit --'L 230, STATE �/ INDIANA INDIANA UTILITY REGULATORY CONMUSSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOTIS.TNT)TANA 467(14-3419 Farcimiha (3171737-675A Pipeline Safety Division Investigation Report Investigation regarding: International, Inc. Case Number: 16746 Report Date: 9/1/2017 12:00 AM Damage Date: 8/15/2017 12:00 AM The Parties Excavator: International, Inc. Investigator: Aaron Holeman Damage Address: 10328 Woods Edge Dr, Fishers Address: 9971 Woodbend Dr. Saline, MI 48176 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Service/Drop Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact Product Release: Yes Service Interruption: Yes -1 Repair Cost (if known): Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1708090723 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged an accurately marked 1 -inch service line with a shovel. Rather than using the shovel in a standard fashion, the excavator used the shovel to drive through the ground, puncturing the line. Excavator failed to take care and precaution to avoid damage. Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities. Exhibit—A- 2 L(ofW xhibit2L(ofW STATE 9/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.TS. TNDTANA 4004-3419 FaraimilP- (31'A 2.17-675A Pipeline Safety Division Investigation Report Investigation regarding: International Inc. Case Number: 16810 Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman Damage Date: 8/14/2017 12:00 AM Damage Address: 10430 Woodsedge Drive, Fishers The Parties Excavator: International Inc. Address: 5395 Cogswell St Wayne, MI 48184 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact Product Release: Service Interruption: - Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information: Excavator Request Locates Excavator Notify Operator: Indiana 811 Ticket Number: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. Excavator notes that the ground was hard and there were tree roots in the area. However, neither party has pictures of the damaged line. Without that or some additional information, there is insufficient information to make a finding of IC 8-1-26-20(a)(1), failure to plan. Violation: Insufficient evidence to find violation. Exhibit 2,--(- 45o STATE �/ INDIANA INDIANA UTILITY REGULATORY COMhUSSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.TS. TNT)TANA 46704-3419 FamimilP- (317)93? -67..5A Pipeline Safety Division Investigation Report Investigation regarding: International Inc. Case Number: 16811 Report Date: 9/1/2017 12:00 AM Damage Date: 8/17/2017 12:00 AM The Parties Excavator: International Inc. Investigator: Aaron Holeman Damage Address: 10168 Parkway Drive, Fishers Address: 5395 Cogswell St Wayne, MI 48184 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact Product Release: Service Interruption: - Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information: Excavator Request Locates: Excavator Notify Operator: Indiana 811 Ticket Number: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator damaged an accurately marked 1 -inch service line with a shovel. Rather than using the shovel in a standard fashion, the excavator used the shovel to drive through the ground, puncturing the line. Excavator failed to take care and precaution to avoid damage. Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities. Exhibit 26d3� STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOIJq_ TNT)TANA 467(14-3419 Farcimilp: (.317) 732-675R Pipeline Safety Division Investigation Report Investigation regarding: International Inc. Case Number: 16812 Report Date: 9/5/2017 12:00 AM Damage Date: 8/24/2017 12:00 AM The Parties Excavator: International Inc. Investigator: Aaron Holeman Damage Address: 10260 Night Hawk Dr, Fishers Address: 5395 Cogswell St Wayne, MI 48184 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Facility Function: Distribution Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact Product Release: Yes Service Interruption: Yes -3 Repair Cost (if known): Facility Depth (inches): 32.0000 Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Yes Indiana 811 Ticket Number: 1708092473 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid request at the time of the incident. They damaged the line attempting a second pass with the bore head underneath the exposed facility. Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment. fixhbit�Y — ? 7=tr3i STATE �/ INDIANA INDIANA UTILITY REGULATORY COMMISSION 101 WEST WASHINGTON STREET, SUITE 1500 EAST www.in.gov/iurc Office: (317) 232-2701 TNT)TANAPOT.Tci. TNDTANA 467(14-1419 Farcimilac (317)739-67.9R Pipeline Safety Division Investigation Report Investigation regarding: Vectren Energy Delivery Case Number: 16813 Report Date: 9/1/2017 12:00 AM Damage Date: 8/24/2017 12:00 AM The Parties Investigator: Aaron Holeman Damage Address: 10235 Bent Creek Ct, Fishers Excavator: R L M Underground Address: 4902 W 57th Street Roeland Park, KS 66205 Facility Owner: Vectren Energy Delivery Pipeline Facility Facility Type: Natural Gas Type of Equipment: Boring Damage Impact Product Release: Yes Repair Cost (if known): Facility Function: Service/Drop Type of Work Performed: Cable TV Excavator Activities/Cause of Damage Information: Excavator Request Locates: Yes Excavator Notify Operator: Service Interruption: No - Facility Depth (inches): 36.0000 Indiana 811 Ticket Number: 1708093627 Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to incorrect maps/records. Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings. Exhibit 7,13 y STATE?/ INDIANA 1?%M_1 \TA UT:I_rn REGULATORY COtL OSION 101 IATSr 1V"rINGT0.-N STREET, SUM 1500 FAST I1tiTDiANAPOLIS, NDIANA 46204-34I9 Curtis T. Hill, Jr. Indiana Attorney General 200 West Washington St. Room 219 Indianapolis, IN 46204 Dear Attorney General Hill: «js si <�� �� tti'SYtt.3lt.gOt•,%1t3tL Office. (311) 232-2701 Facsimile: (317) 232-6755 September 12, 2017 The Indiana Utility Regulatory Commission's Pipeline Safety Division today completed investigations into twenty (20) recent damages to underground natural gas lines in the City of Carmel and the City of Fishers involving six (6) different companies. In addition, there was an incident in the City of Westfield on Friday, September 8, 2017, involving one of the same companies, that was particularly troubling. The companies excavate in the public right of way to install fiber optic cables on behalf CMN-RUS, Inc., d/b/a MetroNet ("MetroNet"). MetroNet offers broadband internet and other services to customers in Indiana. As part of the investigation, the Pipeline Safety Division found five (5) of the six (6) companies are foreign corporations, meaning they were formed or incorporated in a state other than Indiana. Indiana law requires foreign corporations and limited liability companies transacting business in Indiana to obtain a certificate of authority from the Indiana Secretary of State.' However, in reviewing the Indiana Secretary of State's website, it appears that none of these five companies have obtained the required certificate of authority. A foreign company's certificate of authority is important because it provides basic company information to the public about the companies transacting business in Indiana. The foreign company must also provide the location and address of the company's in-state registered agent. The registered agent facilitates service of legal process in court cases and regulatory proceedings. This failure to comply with Indiana law makes the Pipeline Safety Division's important public safety function more difficult. Specifically, the certificate of authority allows the Pipeline Safety Division to ascertain the identity and address 'Ind. Code § 23-1-49-1(a); Ind. Code § 23-18-11-2(a). Exhibit __2 1/ of the businesses that are excavating and causing pipeline damages in Indiana. The Pipeline Safety Division often needs to find an officer, manager, or other agent or employee authorized by the company and the law to receive and respond to regulatory notices. In some case, penalties for damaging natural gas pipelines may not be assessed because of the inability to locate the company. A foreign business transacting business in Indiana without first obtaining a certificate of authority is liable for a civil penalty of not more than ten thousand dollars ($10,000).2 Because the Indiana Attorney General has the statutory authority to enforce these penalties,3 I am respectfully referring the following companies to your office for review: • Crosier Lane Consulting, Inc. (Illinois business) • International, Inc. (Michigan business) • Nexgen Directional, LLC (Illinois business) • RC Underground, LLC (Florida business) • RLM Underground, LLC (Kansas business) Please contact me if your office needs additional information about the companies or this letter. Sincerely, 7D. (j James D. Atterholt Chairman Indiana Utility Regulatory Commission cc: Beth E. Heline, General Counsel, Indiana Utility Regulatory Commission Betsy Isenberg, Director, Consumer Protection Division, Office of the Indiana Attorney General Jeremy Brilliant, Director of Communications, Office of the Indiana Attorney General 2 Ind. Code § 23-1-49-2(d); Ind. Code § 23-18-11-3(d) 3 Ind. Code § 23-1-49-2(d); Ind. Code § 23-18-11-3(d) Exhibit Common Ground Alliance Best Practice Recommendations 5.10 Locate Verification Practice Statement: Prior to excavation, excavators verify that they are at the correct location, verify locate markings and, to the best of their ability, check for unmarked facilities. Practice Description: Upon arrival at the excavation site and prior to beginning the excavation, an excavator does the following: • Verifies that the dig site matches the one call request and is timely • Verifies that all facilities have been marked and reviews color codes if in doubt • Verifies all service feeds from buildings and homes • Checks for any visible signs of underground facilities, such as pedestals, risers, meters, and new trench lines • Checks for any facilities that are not members of the one call center and contact someone to get them located. Use of a pre -excavation checklist is recommended by insurers and practiced by responsible excavating contractors. 5.12 Work Site Review with Company Personnel Practice Statement: Prior to starting work, the excavator reviews the location of underground facilities with site personnel. Practice Description: Sharing information and safety issues during an on-site meeting between the excavator and the excavating crews helps avoid confusion and needless damage to underground facilities. 5.13 One Call Reference at Site Practice Statement: Except in case of an emergency, the excavator at each job site has available a complete description of the dig site, a list of the facility owner members impacted at that dig site as identified by the one call center, and the one call center ticket number. Practice Description: The availability of locate request details on site is useful because excavators can easily access information about the location and extent of work, the valid start time, and the list of operators notified. The documentation also provides an excavator with appropriate information for daily tailgate meetings for crews; provides quick references for Exhibit excavation equipment operators; and facilitates communications between the excavator and the one call center with respect to that particular locate request, should it become necessary. When multiple crews are working on the same project at separate locations or when different employers have crews working at the same location, each crew has the information. 5.15 Facility Avoidance Practice Statement: The excavator uses reasonable care to avoid damaging underground facilities. The excavator plans the excavation so as to avoid damage or to minimize interference with the underground facilities in or near the work area. Practice Description: Foremost on any construction project is safety. Excavators using caution around underground facilities significantly contribute to safe excavation of existing facilities. 5.17 Marking Preservation Practice Statement: The excavator protects and preserves the staking, marking, or other designation of underground facilities until no longer required for proper and safe excavation. The excavator stops excavating and notifies the one call center for re -marks if any facility mark is removed or is no longer visible. Practice Description: During long, complex projects, the marks for underground facilities may need to be in place far longer than the locating method is durable. Painting, staking, and other marking techniques last only as long as the weather and other variables allow. When a mark is no longer visible, but work continues around the facility, the excavator requests a re -mark to ensure the protection of the facility. 5.18 Excavation Observer Practice Statement: The excavator has an observer to assist the equipment operator when operating excavation equipment around known underground facilities. Practice Description: The excavator designates a worker (an observer) who watches the excavation activity and warns the equipment operator while excavating around a utility to prevent damaging that buried facility. i Exhibit 326f31 5.20 Excavation within Tolerance Zone Practice Statement: When excavation is to take place within the specified tolerance zone, the excavator exercises such reasonable care as may be necessary for the protection of any underground facility in or near the excavation area. Methods to consider, based on certain climate or geographical conditions, include hand digging when practical (pot holing), soft digging, vacuum excavation methods, pneumatic hand tools, other mechanical methods with the approval of the facility owner/operator, or other technical methods that may be developed. Hand digging and non-invasive methods are not required for pavement removal. Practice Description: Safe, prudent, non-invasive methods that require the excavator to manually determine the actual location of a facility are considered "safe excavation practices" in a majority of state/provincial laws (38 states). A majority of states outline safe excavation practices to include hand digging or pot holing (16 states). Some states specifically allow for the use of power excavating equipment for the removal of pavement. Each state/province must take differing geologic conditions and weather related factors into consideration when recommending types of excavation within the tolerance zone. 5.29 Trenchless Excavation Practice Statement: All stakeholders comply with all best practices and the following general guidelines prior to, during, and after any trenchless excavation (as applicable). Practice Description: • The excavator requests the location of underground facilities at the entrance pit, trenchless excavation path, and the exit pit by notifying the facility owner/operator through the one call center. • The trenchless equipment operator performs a site inspection, walking the trenchless excavation path prior to commencing work, and has a good understanding of the job. • The trenchless excavation operator confirms and maintains the path and minimum clearances established by the project owner and design engineer by tracking and recording the path of the trenchless excavation until complete. Means of tracking trenchless excavations include electronic locating/guidance devices, pipe lasers, water levels, visual inspection, etc. • When existing facilities are known to be present but cannot be potholed as a result of local conditions, the facility owner and the excavator meet to discuss how to safely proceed with the excavation. • The excavator stops the trenchless excavation operations if an abnormal condition, unknown substructure, or other hidden hazard is encountered. The excavator proceeds safely only 6xM1ibit ,3 6�34 after making positive identification. (Refer to Practice Statements 2-13 and 4-19 for additional information.) 5.32 Vacuum Excavation Practice Statement: Vacuum excavation, when used appropriately, is an efficient, safe, and effective alternative to hand digging within the designated underground facility tolerance zone. Use of equipment also follows state/provincial laws and/or local ordinances. Practice Description: The safe exposure of underground facilities within the tolerance zone is essential to damage prevention. Site conditions may make the use of hand tools to expose underground facilities difficult or even impractical. Vacuum excavation is often an appropriate alternative. Locates must be obtained prior to the commencement of work (see Practice Statement 5-1). Many underground facility owners/operators have specific criteria for safe excavation/exposure practices around their facilities. Some underground facility owners/operators accept vacuum excavation as equivalent to hand excavation for exposing their facilities, and others have restrictions on its use. Vacuum excavation is an appropriate method of excavating safely around underground facilities provided that the equipment: • has been specifically designed and built for this purpose; • is operated by a worker trained and experienced in its operation; • is operated in accordance with practices that provide appropriate levels of worker and public safety and prevent damage to buried facilities; and • is used in compliance with state/provincial laws and/or local ordinances 5.33 Facility Owner Provides a Monitor During Excavation Practice Statement: If a facility owner/operator considers it necessary to be on site during excavation activities to work with the excavator in protecting their existing facilities, the facility owner/operator makes arrangements with the excavator to be present during those excavation activities within the time specified by state/provincial law. Practice Description: The facility owner/operator may determine it necessary to be on site during excavation activities taking place near their facilities to help protect them. A facility owner/operator has access to information and resources that may not be available to the excavator. This practice should be considered in conjunction with Practice Statement 2-4: Utility Coordination. E 'bit xbi �1 3Y�3y Underground Construction Safety Plan Safety of MetroNet's associates, its contract workers and the communities it serves is priority #1. This document focuses on safe excavation practices during underground network construction. Safety Processes and Procedures. ❑ Pre-quali)� Contractors — Before signing a contract, MetroNet evaluates each construction firm's qualifications. A contractor's safety practices, safety experience (including utility strike rates), safety training, and commitment to safe practices area major part of MetroNet's pre -qualification evaluation. See "Safety Information" and "Utility Strikes" section of MetroNet's Contractor Pre -Qualification Statement included under Tab 1. ❑ New Contractor Orientation — MetroNet requires its underground contractors to conform to certain safety standards and best practices. To communicate our expectations, MetroNet supplies the following materials to each contractor (See Tab 2, the "Safety Materials"). Common Ground Alliance Best Practice Recommendations State Excavator Manual' Potholing Guidelines Exposing Underground Utility Lines — Requirements and Best Practices ❑ Safety program — During the contractor pre -qualification process and every year thereafter, MetroNet confirms that each contractor has a valid safety program in place. Although we don't mandate a specific safety program for our contractors, we expect the practices described in the Safety Materials to be a part of their programs. Furthermore, each safety program must require compliance with applicable law, including the State 811 excavators manuals/handbooks, OSHA and NESC requirements. Safety Training. MetroNet requires the following safety training: ❑ Contractor training — Before conducting excavation services for MetroNet, excavation contractors must provide documentation to MetroNet that their crews are trained and qualified regarding safe digging practices and understand the requirement of the state's 811 Call Before You Dig Laws. Training is expected to include safe excavation techniques and when and how to request additional information from utility owners to validate the location of underground facilities. Documentation may include verification of attendance at a MetroNet sponsored or facilitated training session (e.g. training put on or approved by a professional or accredited safety organization, gas or other utility), and/or documentation of completion of other similar training. In Indiana, documentation may also include verification of attendance with a passing score at one of the Underground Plant Protection Advisory Committee's ("UPPAC's) training classes and/or completion of the IURC sponsored online excavation damage training at httns://www.safedigindiana.com/. ❑ New worker training — Each contractor is required to verify that all of their workers and any subcontractors have met the above training standards prior to commencing underground construction activities including all new workers joining existing excavation crews. Each contractor is expected to document such training and, upon request produce such documentation for MetroNet's inspection. ' State excavator manuals will be provided upon request or can be found on line as follows: Indiana 811 Excavators Manual can be found at http://indiana81Lor g; JULIE Excavator Handbook can be found at www.illinoislcall.com/; Iowa 811 One Call Excavators Manual may be found at h=://www.iowaonecall.com/contractors/; Michigan 811 Best Practices may be found at httv:Hcall8l I.com/best-practices-p-uide; Tennessee 811 Damage Prevent Guide may be found at b=s7//www.tn.yov/assets/entities/tra/attachment&TN81 ICaIl8I lBkltf.pdf, and Kentucky 811 Excavator Manual can be found at https•//www.kentuckvgl I ore/wo content/uploads/2011/07/KY81I-Excavator-Manual-6 27 2010 pdf. DExhibit co�3 ❑ Ongoing safety meetings — MetroNet contractors involved in underground excavation are required to have weekly safety meetings. The meeting dates, times, topic(s) and attendance are required to be documented by each contractor with such documentation available for inspection by MetroNet. In addition to the contractor's standard safety training, subject matter from the Safety Materials should be included in the topics covered during safety meetings as well as safety standards imposed by applicable law. ❑ Mandatory Annual Utility Training — Utility companies are an excellent resource for learning the latest and best safety practices. When such resources are available, MetroNet will facilitate annual training with mandatory contractor attendance. Such training will be free of charge to all contractors and their subcontractors. ❑ MetroNet Construction Executives, Project Managers and Outside Plant Engineers — MetroNet's construction executives, project managers and OSP engineers are required to attend safety training and are expected to be familiar with the Safety Materials and safety standards imposed by applicable law. Safety training may include attendance at a MetroNet sponsored or facilitated training session (e.g. training put on or approved by a professional or accredited safety organization, gas or other utility ) and/or similar training. Training may also include attendance (with a passing score) at one of UPPAC training classes and/or completion of the IURC sponsored online excavation damage training at https://ww.safedigindiana.com/. Safety Tracking and Monitoring. In order to identify trends, learn from mistakes and improve practices, MetroNet tracks incidents involving safety concerns. ❑ Safety Committee - MetroNet has created a committee comprised of senior executives ("Safety Committee") to meet on a quarterly basis to review MetroNet's continuing construction safety performance. The Safety Committee will review all reported utility strikes, safety violations and discuss other relevant safety topics. The Safety Committee may determine if (i) practices or procedures should be modified (e.g. temporary use of hydro -excavation during periods of extremely dry and hard ground conditions), (ii) safety training or oversight needs to be enhanced (e.g. mandatory safety refresher training), (iii) disciplinary action needs to be taken, or (iv) other measures need to be instituted. The Safety Committee will also meet on an "as needed" basis to review any major utility strikes or safety violations. ❑ Director of Safety and Quality Assurance (the "Director of Safety') - MetroNet has created a position for a Safety Director to oversee all construction safety practices and procedures. The Safety Director will track, monitor and adjust, as necessary, the safety practices of MetroNet and will coordinate with internal construction personnel, contractors and MetroNet's executive team to ensure safe construction practices are being utilized at all times. The Safety Director will also be primarily responsible for investigating, tracking and reporting all major safety violations to the Safety Committee and making recommendations on improving safety through the incorporation of new procedures and additional training. ❑ Utility Strike Reports - If a contractor causes damage involving hazardous circumstances, such as a rupture gas line, MetroNet requires that the contractor call 911, then 811, and then immediately thereafter, MetroNet. MetroNet requires MetroNet construction field personnel to prepare a utility strike report (see form included under Tab 3 each time there is a major strike (e.g. a gas line is hit, an electric, water or communication mainline cable is hit affecting several customers, or 911 is called). MetroNet requires contractors to prepare a utility strike report for all other public utility line strikes and submit it to MetroNet within 48 hours of the strike. In the event of a major strike, the utility strike report must be accompanied by pictures at pertinent angles, measurements from locate marks, description of the operation being conducted, date/time the damage occurred, on-site analysis of cause of the damage, and list of measures taken/not taken to prevent the incident. Strike reports must be submitted to MNT-Claimsna metronetinc.com and will be tracked by MetroNet's Director of Safety. ❑ Safety inspections and field audits - MetroNet's construction field personnel are trained to identify unsafe practices and take appropriate action. MetroNet's field personnel routinely inspect contractor excavation work sites. MetroNet is committed to ensuring that the ratio of such field personnel to excavation crews is sufficient to ensure that inspections are frequent and effective. During onsite inspections, field personnel are required to observe operations, including safety practices. MetroNet field personnel are given the authority Ex%b t 263 to take action if unsafe practices are observed, which action may range from requiring additional training to immediately stopping a crew's work. MetroNet's Director of Safety will also conduct impromptu field audits. In addition, as noted above, when a major utility strike occurs, MetroNet field personnel must be deployed to the site promptly to complete a comprehensive utility strike report and to take pictures and measurements. ❑ Damage claims - MetroNet tracks claims for damages received from utility providers, notifies contractors of such claims, and records contractors' responses. If merited due to the frequency, severity or root cause of claims, contractor damage claim experience will be reported to the MetroNet's Director of Safety and Safety Committee. ❑ Contractor Annual Statement - MetroNet contractors must confirm their commitment to safety and compliance at the beginning of each calendar year. Failure to provide the statement may result in contractor suspension until MetroNet receives the contractor's statement. See Contractor Annual Statement at Tab 4. Improving Safety. MetroNet's management encourages all associates, regardless of position or tenure with the organization, to speak up on safety matters and bring safety improvements or concerns to management's attention. ❑ Suggestion Box - A suggestion box has been posted Associates are encouraged to suggest ways to improve safety. Suggestions may be sent MNT-Safety6a.metronetinc.com. ❑ Participation in Industry Groups - MetroNet will seek to learn from organizations and groups with the shared goal of community, worker, and residential safety, damage prevention, and loss mitigation. An excellent example of such a group is the Indiana Damage Prevention Council. As a member of such groups, MetroNet will meet with underground facility owners, locators (e.g. USIC), operators, government agencies, excavators, industry associations and service providers to help address issues related to the Council's and MetroNet's mutual goal of improving safety, reducing damages, improving communications and supporting positive initiatives with respect to excavation and related processes. Safety Incentives and Penalties. To help ensure success of the programs, MetroNet uses carrots and sticks to encourage good safety practices and to discourage poor ones. Safety incentives and penalties must be carefully constructed to encourage safe practices without discouraging damage and strike reporting. ❑ Retainage - MetroNet retains a portion of amounts to be paid to contractors pending confirmation that a job has been performed to MetroNet's satisfaction. Retained amounts will not be released if the contractor has damaged property and such damage has not been resolved. ❑ Suspension and Termination - MetroNet will suspend work, terminate crews, and/or terminate a construction contract if safety experience is not acceptable. Project managers and OSP engineers have the authority to suspend a crew's work if unsafe practices are identified. Of course, members of the Safety Committee have the authority to suspend work, terminate crews, and/or terminate construction contracts. ❑ Priority Contractors - When awarding contracts, contractors with exemplary safety records are given priority. Communication. MetroNet understands the importance of communicating across all audience types: residents, impacted residents, home owner associations, city officials, business owners, local utilities, locators (e.g. USIC), property owners, contractors and associates. Communications include press releases regarding the start of construction, detailed letters to impacted residents in advance of construction, reminder postcards and yard markers prior to construction, entrance and exit signs in neighborhoods during times of construction, frequent calls with locators (e.g. USIC). Communications will be enhanced by directing audiences to MetroNet's construction website found at h=s://construction.metronetinc.com/cct. MetroNet's construction website will also allow concerns and issues to be directed to the appropriate MetroNet associates and will facilitate prompt responses to questions and concerns. Exhibit 3 �of -3 City of Carmel www.carmet.in.gov NEWS RELEASE Date: January 25, 2018 Contact: Nancy Heck (317) 571-2474 Release: Immediate One Civic Square, Carmel, IN 46032 City clears Metronet to work again Carmel, IN - The City of Carmel and Metronet have reached an agreement to allow Metronet to resume work in Carmel. Metronet has updated its safety practices, including improved sub -contractor training. The updated safety plan follows the recommendations put forth by the Indiana Utility Regulatory Commission. The agreement provides that any breach of safety protocol may result in a stop work order. Metronet has expressed strong commitment to working with the City of Carmel to ensure the safety plan is followed. Before digging resumes in neighborhoods, Metronet will be providing notice to residents affected 30 days prior to entering their property. This action comes after the City and Metronet signed an agreement that affords local residents assurances that proper steps will be taken to prevent problems and issues that arose prior to the issuance of a stop work order last year. Prior to the agreement, the Carmel City Council passed a new ordinance in December that establishes new conditions for anyone wishing excavate in City right-of- way. Much of those provisions were included in the Metronet agreement - including the need for contractors to have participated in a "Gold Shovel Standard" or similar program of training, Indiana 811 Online excavation training, new right-of-way permit fees of $50, the Exlu'bit _----- 1 �5(3 posting of cash bonds prior to a project's inception, proper notice to property owners and adjacent property owners and the requirement of hand -digging or vacuum excavation techniques for all underground utility locates. made: Under the Metronet memorandum of understanding, the following assurances were Training - Metronet construction personnel assigned to supervise and monitor work will complete the IURC Pipeline Safety Division training and shall require its contractors to do the same. Personnel - Metronet will have a Metronet employee available at each dig site who can effectively communicate with property owners about the digging, construction and restoration activities. Complaints - Metronet will visit each property where an outstanding restoration complaint has been made in order to resolve the situation. Notification to property owners - Metronet will notify each property owner and homeowners association (if one exists) at least 30 days prior to entering any property for excavation. Notification to 911- If any further underground facility hits occur, Metronet will ensure that 911, 811, the underground utility and the City of Carmel Engineering Department are notified. Violation of the memorandum could result in a new stop work order and fines of up to $S00 per breach of contract, in addition to reimbursement of costs incurred due to the breach. Exhibit Any questions regarding Metronet planned projects in Carmel can be directed to Keith Leonhardt at 812-213-1016 -30- Exhibit r �or�