On June 18, 2025, FERC temporarily raised the cost limits for blanket certificate natural gas pipeline projects constructed and placed into service by May 31, 2027, from $41 million to $61.65 million. Citing what it called a pressing nationwide near-term demand for expanded natural gas transportation capacity and reliability concerns associated with maintaining existing natural gas infrastructure, FERC found good cause to temporarily waive its regulations setting the cost limit for blanket certificate projects.
Interstate pipelines that hold a certificate under section 7(c) of the Natural Gas Act may obtain a blanket certificate under FERC’s regulations to undertake certain activities without case-specific authorization from FERC, subject to cost limits. The blanket certificate is intended to streamline procedures as a means of increasing flexibility and decreasing regulatory burdens for certain routine activities generally considered to be minor. Currently, blanket certificate projects are capped at $41 million per project.
In April 2025, the Interstate Natural Gas Association of America (“INGAA”), a nonprofit trade association representing interstate pipelines, petitioned FERC to temporarily waive its regulations setting the blanket certificate cost cap. In its petition, the INGAA described an urgent, nationwide need for enhanced and expanded natural gas infrastructure, cited President Trump’s Executive Order “Declaring a National Energy Emergency” in support (see January 22, 2025 edition of the WER), and and asked FERC to double the blanket certificate cost limit from $41 million to $82 million for two years.
FERC granted the INGAA’s request in part, temporarily waiving its regulations to increase the blanket certificate cost limit to $61.65 million for projects constructed and placed into service by May 31, 2027. According to FERC, good cause exists to waive its regulations because there is “widespread recognition” that new natural gas infrastructure and continued maintenance of existing infrastructure is “critical” to address nationwide reliability and resource adequacy concerns in the short term. FERC also explained that near-term gas and electricity demand are expected to grow rapidly during the period covered by the waiver.
FERC noted that it last evaluated the underlying cost limits for blanket certificate projects in 2006. Concurrently with the instant order, FERC issued a notice of inquiry seeking public comments as to whether the cost limit regulations should be modified on a permanent basis. In its notice, FERC posed specific questions for commenters, including what types of projects should be included under blanket certificate projects and what constitutes “minor investment” projects.
FERC’s waiver order, issued in Docket No. CP25-208, can be accessed here. The notice of inquiry, issued in Docket No. RM25-12, can be accessed here.