Columbia Gas of Ohio THEFT OF SERVICE 2011

1. Columbia Gas of OhioTHEFT OF SERVICE 2011

2. NISOURCE • Columbia Transmission, Columbia Gulf and Crossroads Pipeline, NiSource owns and operates an interstate pipeline network extending from the Gulf of Mexico to New York and the eastern seaboard • 16 northeastern, mid-Atlantic, Midwestern and southern states and the District of Columbia.

3. Nisource • NiSource provide natural gas, electricity 3.8 million customers located within a corridor that runs from the Gulf Coast through the Midwest to New England • Columbia Gas of Massachusetts serves 298,000 customers • NiSource’s own and operate approximately 15,000 miles of pipeline

4. COLUMBIA GAS OF OHIO • Serving more than 1.4 million residential, commercial and industrial customers, Columbia Gas of Ohio • Columbia Gas of Kentucky service 140,000 customers in Lexington and several surrounding communities.

5. Columbus has about 1.8 million people in the metro area. It is the third largest metropolitan area in the state of Ohio, behind Greater Cleveland and Greater Cincinnati and is one of the largest in the Midwestern United States. It is also one of the fastest growing metro areas outside of the Sun Belt. A new casino is being built in Columbus Ohio. The Arena district located in downtown Columbus hosts Blue Jacket and a minor league baseball team the Columbus Clippers. The Ohio State University Football team recruited Urban Meyer to coach the Buckeyes . Columbia Gas Call center is located in Pennsylvania. NiSource has three energy investigators since April 2004. The Investigator in Pa covers Virginia and Maryland. The Investigator in Toledo covers Northern Ohio and the investigator in Columbus cover southern and central Ohio and Northern Kentucky

6. Agenda • Mission • Providing quality Meter to Cash services that are cost effective, customer focused, process driven and regulatory compliant.  • .

7. Other agencies gas theft • Fire Department – responds to gas leak • Training partnership offered by COH for first responders • Police Departments - B&E, Abandoned homes • Thefts of Service -Police reports for ID thefts • Building Codes - Safety Violations, vehicles parked over curb valves • Community action agencies - Referral only

8. Theft • Churches provide assistance • Shelters referrals • Homeowners association – values of home declines • Electric company – Need electric to run furnace applicance

9. Resource • Accurint data base - paid subscription • Government Web sites – Police, Fire • Auditors – Clerk of Court – Marriage information • Facebook • Utilities Companies- Water and Electric • Building inspectors • Community Action referral • PUCO • On site information – for rent sign , yard signs

10. Revenue Recovery and Meter to cash

11. Theft Issues • Theft is occurring at an alarming rate. Clever persons • who have given personal reason not for money and greed. • Squatters, job losses, connect date is too far away • Customers deny, ignore us, personalize reason for unlawful connection and justify reason to themselves • Deceased family members identification • Kids id information. • Identity Theft is a big problem • Contractors and apartment complex are relocating meters. Some have automatic restore agreements • Climatic changes causes some property owners to ignore oblivious thefts of their tenants • Gas service bill not issued.

12. Conversion and Unjust enrichment • Unjust enrichment is a legal term denoting a particular type of causative event in which one party is unjustly enriched at the expense of another, and an obligation to make restitution arises, regardless of liability for wrongdoing.[1] • Definition:1.n. a benefit by mistake or chance. Morally and ethically the one who gains a benefit that he or she has not paid or worked for should not keep it to the rightful owner's detriment. The party that received money, services or property that should have been delivered to or belonged to another must make restitution to the rightful owner. A court may order such restitution in a lawsuit brought by the party who should rightly have the money or property.[2]

13. Goals Theft overview concerns Movement of valve to receive gas . Movement of Gas Meter Stolen Meter Service Technicians, Meter Readers, and other Support Personnel Observe Premise, Document information1 Questions .

14. Performance Expectations • Training, leadership and direction guide • Common sense and good judgment • Work within company guidelines and policies • Work Effectively with teammate and leaders • Communicate constructively and respect others. • Contribute to a positive work environment • Remain mindful of diversity and inclusion • Case by case review

15. Ohio Criminal Code Ohio Revised Code 2913.202 • Theft A) No person, with purpose to deprive the owner of property or services, shall knowingly obtain or exert control over either the property or services in any of the following ways: • (1) Without the consent of the owner or person authorized to give consent; • (2) Beyond the scope of the express or implied consent of the owner or person authorized to give consent; • (3) By deception; • (4) By threat; • (5) By intimidation. • (B)(1) Whoever violates this section is guilty of theft

16. Ohio Criminal Code 4933.18 Tampering with utility equipment. • In a prosecution for a theft offense, as defined in section 2913.01 of the Revised Code, that involves alleged tampering with a gas, electric, steam, or water meter, conduit, or attachment of a utility that has been disconnected by the utility, proof that a meter, conduit, or attachment of a utility has been tampered with is prima-facie

17. Tampering with Utility Equipment Continued • Reconnection of a gas, or attachment of a utility that has been disconnected by the utility, proof that a meter, conduit, or attachment disconnected by a utility has been reconnected without the consent of the utility is prima-facie evidence that the person in possession or control of the meter, at the time of the reconnection has reconnected the meter, conduit, or attachment with intent to commit a theft offense.

18. Definition Theft of service is defined by the graphic below. A Property Owner can benefit from consumption of energy, Theft of service is the immediate focus of the discussion today… Unauthorized Use Has there been POS identification of a responsible party? No Yes Further Internal Investigations Lease, Deeds,etc Theft of service • Meter Tampering • Bypass • Unauthorized Restoral

19. Property Owner/ Managers • Property Owners/Managers, Real Estate, Broker, and Banks in charge of properties have a responsibility/duty to cooperate. • Conversion of COH natural gas services • Unjust enrichment & Unauthorized Usage of Natural Gas • COH/Billing will pursue Civil/Criminal legal actions COH guidelines and policies will apply • Winter heat options. • Dispute Procedures in accordance with COH policies and PUCO regulation are in place.

20. Investigator Notes • Theft of service account identified • Identify Customer who has benefitted from gas service • Billing Exception submits billing – Demand Letter sent through mail • Follow-up by investigator includes visit and telephone call, additional • Legal options are considered • Customer disputes are further investigated

21. Investigators/Billings Exceptions Points 1. Contact Billing Exceptions 614-460-XXXX to gather support information for Service Technician 2. Utilize technician information to identify customer that benefit from unauthorized usage of natural gas service in accordance with COH policies and procedures. 3. Get Public/Property Owners and others involved 866 515 9864 Tip Theft Hotline 614 460 XXXX Fax for Theft Dispute 4. Foreclose or surrended property Note: Customer will fax lease with positive id of suspect to Meter to Cash, dates of customer occupying unit, etc

22. Refresher Information Consistency in the detection or identification of theft is critical to increasing safety and providing more billing and collection opportunities • Locked meter showing consumption &/or broken lock or locking device. • Any evidence of tampering with gas meter, broken seal, meter reading device, wire or index. • Mechanical means of bypassing gas around the meter. • Piping before the inlet side of the meter. • Meter reversed. • Dials out of normal position, or other index tampering • Jaw marks on meter nuts. • Active appliances when meter is off. • Low reading on office generated order. • Meter without meter number showing or different meter of record than on order. • Steam or exhaust coming out of chimney when account is coded off. • Lack of frost &/or condensation on windows in winter when account is coded off. • Fresh pipe dope and or new pipe. ( different color pipe dope ) • Any other unusual conditions of similar nature. • Capturing theft identified with a photograph before securing or removing meter is essential. Does theft exist?

23. Dry cleaners Powell Ohio • Service Tech on 2nd service call reports meter missing and tampering. Customer is manager of dry cleaners and turns meter on after service is disconnected. Investigator responds and finds the original gas meter under the counter in plain view. Manager is defiant and said he had customers waiting on dry cleaners. Powell Police locked him up

24. Southend of Columbus Oh • Service tech call in a meter illegally restored 2nd time. Investigator responds, while checking the stolen meter, customer comes out of home and screaming, cussing, he tells investigator to go away. He releases a pit bull, which stands between fence and investigatpr. Investigator calls police. Police respond, while talking to customer he runs into home, he has a felony warrant for felonious assault, swat responds

25. Middle Class family with swimming pool • Successful business man and his spouse a registered nurse enroll and qualify for low income program while living in a million dollar home. • Service Tech reports she is complaining about the heat put out by the meter, wants larger meter for more heat. • She is interviewed by Investigator and rebilled for $25,000, given a ten day shutoff notice. Pays with certified check

26. Lorrain Ohio Family • Certified plumber bypasses gas meter manifold • Contractor discovers bypass, notified COH • Investigator responds, calls police • Plumber family member works for COH and has family on PD • Resolved with Detectives in Lorrain and family member that is not related, with cut n plug

27. Bypass Refresher Here is another bypass situation with a broken meter valve. Obviously, the customer has created a very unsafe situation. How many have seen by-pass attempts like this? Does theft exist?

28. Bypass Refresher Below is a classic bypass situation. The customer did not attempt to hide the theft, but used a fence around property. Photographs can serve as evidence, which is important for billing and prosecution success. Does theft exist?

29. Recommendation 2 – Field Training What’s wrong with these pictures? Does theft exist?

30. Recommendation 2 – Field Training How about these? Does theft exist?

31. Recommendation 2 – Field Training And these (same residence, different angle)? Does theft exist?

32. Recommendation 2 – Field Training Meter indexes are another area of vulnerability. Broken seals, missing protective covers, and other signs of index tampering should be investigated. Does theft exist?

33. Recommendation 2 – Field Training What’s wrong with these pictures? Does theft exist?

34. Recommendation 2 – Field Training And this one? Does theft exist?

35. Recommendation 2 – Field Training Can anyone spot the problem with this commercial customer (same location in both pictures)? Does theft exist?

36. Meter Bypass

37. Circleville Ohio Firewood covering meter

38. Meter Bypass

39. – Field Training Securing our facilities provides for ongoing revenue protection. There are many options available in this area. • Stolen meter: Remove on 1st theft instance • 1st Theft: Inside meter: Remove meter on 1st theft occurrence when usage is over 50 ccf • Secure the service by turning off valve (use curb box locking • device if necessary) • All inside meters moved out in theft situations before service • restoration with customers covering costs (assuming there is room and code permits it) • 1st Theft: Outside meters: • Install meter locking device. • Install metal disc or solid swivel on domestic meters • If meter valve broken: • Leave OQ card, if applicable, advise of requirements to have OQ contractor replace (Columbia LDC’s) • Install meter locking device • Removal of meter is also an option • Leave tamper tag (BSG - better for inside meter sets) • Curb valve shut-off if available and located (curb box locking device) • 2nd Theft: Remove meter • Curb valve shut-off if available and located • No curb valve: Install curb valve or consider performing cut and plug • Warehouse theft meters at local operation for possible prosecution. (Tag and secure all evidence in a locked area)

40. Recommendation 2 – Field Training Proper documentation is a key to correct billing and possible prosecution. The following guidelines are the basic requirements we need to document. • Pictures – Use digital or disposal cameras • Capture meter #, kind, and size • Record meter reading (separate field on MDT) • Detail names of individuals involved • Communicate with user at location, including contact information • Gather physical evidence (meter, broken locks, bypass equipment) • Document tampering method (type and location of theft, gas on or off at arrival?) • Detail theft prevention activities completed (meter removal, theft device installed, time spent at site, etc.) • If available, get witness statement • If able, detail appliances in use • Indicate special premise instructions (irate customer, vicious dog, and unsafe situations • Label evidence to match with location • Use MDT comments section for all information that does not have separate field on MDT Document Theft Gathering of this documentation will lead to increased safety, cost recovery, and will give the organization prosecution options.

41. Recommendation 2 – Field Training This is a print out of the MDT order showing Theft of Service on the drop down menu. Document Theft When the Tech selects Theft of Service, the MDT will communicate with DIS in real time and code the account at the bottom of the DIS screen: THEFT OF SERVICE FOUND FOR PSID XXXXXXXXX UNDER PCID XXXXXXXX-XXX

42. Recommendation 2 – Field Training The MDT remarks section should be used to capture all documentation related to the theft. If you run out of room, additional comments can be entered. Document Theft This screen is available for any order type. The information entered on this screen shows up on the DIEO PF8.

43. Recommendation 2 – Field Training Lastly, we have the associated paperwork. This helps to create an audit trail … • Columbia companies: • Complete documentation requirements using MDT. • When order is executed, Billing Exceptions consolidates info for billing • BSG/NU: • Report of Gas Diversion • Gas Theft Award Form • This info goes to Billing Exceptions • Complete documentation requirements using MDT • NIPSCO • Complete documentation requirements using MDT. • When order is executed, Billing Exceptions consolidates info for billing • Energy Investigation Form used for additional info • Line cut: Start J.O. for extra cost Execute Paperwork

44. Is this dog your friend?

45. Access Issue • Review problems, consider options, • Advise Meter to Cash –by telephone, email, note, or any other source of problem

46. State Year Amount and CaseStatistics • Kentucky 2011 $25,067 65 • Maryland 2011 $8252 9 • Pennsylvania 2011 $39,000 59 • Ohio 2011 $913,286 1846 • Virginia 2011 $14224 70 • -------------------------------------------------------------------------------------------------------------------------- • Total • $999,229.97 2049

47. Conclusion Your attention to theft in the field can make a huge safety and financial difference for our company. Thanks for being our eyes and ears on theft and helping us …

48. Columbia Gas of Ohio • What is Positive Identification • a. Copy of Government issued photo id • b. Business card • c. Voucher from friend or family member • d. Social security card

49. Columbia Gas of Ohio • What is Theft of Utilities Service • a. Tampering with Meter • B Bypass of Meter • c. Unauthorized restoral of gas service, gas on • d. all of the above

50. Columbia Gas of Ohio • What threats exist because of unauthorized usage • a. Safety violations • b. Roof leaking • c. Plumbing issues • d. A and C