On November 20, 2025, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) seeking comment on potential reforms to the approval process for liquefied natural gas (LNG) facilities1. FERC is evaluating whether certain construction, modification, and operational activities at LNG plants—including export terminals—should no longer require case-specific authorization orders under Sections 3 or 7 of the Natural Gas Act. Instead, FERC is considering whether a blanket or tiered authorization program, like the framework used for interstate natural gas pipelines, could streamline regulatory review while maintaining necessary safety and environmental protections.
FERC’s interest in revisiting its approach stems from the United States becoming the world’s largest exporter of LNG. As the LNG industry has matured, the industry and FERC have developed extensive experience with LNG facility design, engineering, safety, and environmental issues. This has given FERC perspective on which LNG activities should be closely regulated, and which can be approved without a full application proceeding. FERC notes that the current process, which often requires full applications even for routine equipment replacements or system modifications, may slow needed upgrades and create uncertainty for operators of increasingly complex and long-lived LNG facilities.
The NOI requests stakeholder perspectives on several core issues, including whether LNG operators should automatically receive blanket authorization, whether certain projects should proceed automatically or after prior notice, and how operators should demonstrate compliance with federal, state, and local safety and environmental requirements. FERC also asks for input on the types of facility modifications that could be eligible for streamlined treatment, the terms and conditions that should accompany any blanket authorization, and the cost implications of the existing approval regime.
If FERC moves forward with a blanket or tiered authorization system, LNG developers and operators could see shorter permitting timelines, more predictable approval pathways, and a reduced administrative burden for low-impact activities. At the same time, new reporting, notification, or compliance demonstrations may be required to ensure continued alignment with federal statutes, including Pipeline and Hazardous Materials Safety Administration siting rules, Coast Guard safety reviews, and National Environmental Policy Act obligations.
Comments on the NOI are due on January 26, 2026. Venable’s Energy Group has decades of experience participating in rulemakings before FERC, and we can assist companies with existing or planned LNG facilities in filing comments and/or evaluating how these potential regulatory changes may affect future project planning and operations.
[1] Authorization for Certain Activities at Liquified Natural Gas Facilities, 193 FERC ¶ 61,141 (2025).