FERC’s draft policy would stop requesting applicant air-dispersion modeling for proposed Natural Gas Act projects during NEPA review, while leaving Clean Air Act permitting with EPA and state air agencies.
Published by Allstream Insiders
Allstream Insiders Summary
The Federal Energy Regulatory Commission has issued a draft policy statement proposing a more streamlined approach to assessing operational air-quality effects under the National Environmental Policy Act, or NEPA, for proposed projects regulated under the Natural Gas Act.
According to FERC’s October 15 announcement, the Commission proposes to no longer request air-dispersion modeling from applicants or rely on that modeling in its NEPA analysis of operational air-quality effects. FERC said it would instead use other applicant-submitted information and material identified by Commission staff, while continuing to address air-quality effects in its NEPA documents.
The proposal is not a project approval, a construction authorization or a final change to FERC policy. Interested parties may comment on the draft policy statement through November 16, 2026.
What FERC is proposing
FERC’s proposal concerns the information and analysis it uses in NEPA reviews for Natural Gas Act projects. The Commission said the proposal is intended to reduce duplicative review by recognizing the Clean Air Act permitting and mitigation framework administered by the Environmental Protection Agency and state air agencies.
The draft does not eliminate air-quality review from FERC’s NEPA documents. It also does not displace the permits, emissions limits, mitigation requirements or other approvals that may apply under the Clean Air Act and state law.
For project developers, the practical significance is procedural: if adopted, FERC would change one element of the information it requests and relies upon in its NEPA review. Project-specific timing would still depend on the facts of each application, the full FERC review record, other federal and state authorizations, potential litigation, financing and construction readiness.
Why the distinction between a proposal and a permit matters
FERC described the action as a draft policy statement. The Commission has opened a comment period, and the announcement does not establish that the policy has taken effect or that individual project applications will be approved on a shorter timetable.
Likewise, the announcement does not identify a list of affected pipelines, compressor stations, LNG facilities or other natural-gas projects. It should not be read as evidence that a particular project has received a certificate, completed NEPA review, secured air permits or entered construction.
What it could mean across the energy value chain
| Industry segment | Relationship to the draft policy |
|---|---|
| Midstream and LNG | Potentially the most direct relevance. Interstate natural-gas pipelines and other Natural Gas Act projects that require FERC review could be affected by the proposed NEPA-analysis approach. That does not remove separate environmental, air-permit or project-authorization requirements. |
| Upstream | Primarily indirect. Producers may benefit if future interstate takeaway infrastructure proceeds through review more efficiently, but the draft policy does not regulate drilling, production permits or most gathering systems. |
| Downstream and petrochemicals | Generally indirect. Refineries and petrochemical facilities are not made FERC-approved by this proposal, though gas-supply or feedstock infrastructure associated with a development may involve separate FERC-regulated components. |
| Power and data centers | Potentially relevant only where a proposed project depends on FERC-regulated natural-gas infrastructure. The proposal does not authorize gas-fired power plants, data centers, transmission facilities or the related local permits and interconnection work. |
Allstream perspective: A policy signal, not an automatic fast track
Allstream perspective: The proposed policy signals FERC’s interest in narrowing overlap between its NEPA review and the Clean Air Act responsibilities of EPA and state regulators. For natural-gas infrastructure markets, that could improve regulatory clarity around a portion of the federal-review process if the policy is adopted.
But an air-dispersion-modeling change is only one element of project development. The announcement does not disclose new capital projects, awards, procurement packages or construction schedules. Readers should track the final policy outcome and then watch individual FERC applications, regulatory filings and developer announcements for decisions that establish project-level commercial activity.
