Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

FERC Initiates Rulemaking on Blanket Authorizations at LNG Plants

By Ben Duwve & S. Jennifer Panahi on October 21, 2026
Email this postTweet this postLike this postShare this post on LinkedIn

On October 15, 2026, FERC initiated a rulemaking to enable blanket authorizations for certain activities at liquefied natural gas (LNG) plants. In the Notice of Proposed Rulemaking (NOPR), FERC proposed to revise its regulations to allow LNG plants to modify certain LNG facilities and auxiliary facilities without needing to seek Commission approval under sections 3 or 7 of the Natural Gas Act (NGA).

Under the NGA, FERC’s jurisdiction extends to LNG export terminals, LNG import terminals, and LNG facilities that either regasify LNG or otherwise process natural gas for LNG production or storage. FERC’s current regulations require LNG facility owners to file case-specific applications with the Commission to obtain authorization to modify LNG facilities. FERC noted that there are currently seven large-scale LNG facilities in place, eight currently under construction, and several more LNG terminals expected to be constructed in the coming years.

On November 20, 2025, FERC issued a Notice of Inquiry (NOI) requesting industry input on how FERC should revise its existing regulations under the NGA to allow for blanket authorization of certain activities at LNG plants. More specifically, the NOI sought industry input on what projects at LNG facilities should be eligible for automatic authorization, how to ensure other necessary federal authorizations are obtained before modifications at LNG facilities, and the range of costs for previous modifications at LNG facilities.

FERC’s NOPR proposes to create a tiered blanket authorization program for certain activities at LNG facilities, with some activities receiving full automatic authorization while other activities would require prior notice authorization. FERC proposes that activities that would not (1) increase an LNG plant’s authorized capacity, (2) expand the physical footprint of the LNG plant, or (3) result in operations outside the design limits of the modified or remaining facilities, would be eligible for automatic authorization. The NOPR separately proposes that modifications which would increase the authorized capacity of the LNG plant but not result in any changes to the physical footprint of the plant or expand the design limits of the remaining facilities would be subject to a 60-day prior notice period, with construction of new LNG facilities (like liquefaction trains, storage tanks, or marine berths) being subject to a 90-day prior notice period.

FERC’s NOPR also proposes standard environmental and engineering design conditions, modeled after FERC’s pipeline blanket authorization program, to analyze the impacts of blanket-authorized activities and ensure such activities remain compliant with other applicable law. FERC proposes to not subject LNG blanket-authorized activities to cost limits, arguing the costs of such activities are not an appropriate proxy for whether such activity should be eligible for blanket authorization.

Finally, FERC’s NOPR clarifies that both section 3 LNG facilities and section 7 LNG facilities would be eligible for blanket authorization, but establishes additional safety and engineering requirements for section 7 facilities. FERC’s NOPR also proposes to establish a presumption that automatically authorized activities applicable to section 7 LNG facilities are eligible for rolled-in rate treatment.

FERC’s NOPR, issued in Docket No. RM26-2-001, is available here. Comments on the NOPR are due December 21, 2026.

Photo of Ben Duwve Ben Duwve

Ben is an associate in the firm’s Energy practice. He received his J.D. from the George Washington University Law School, where he served as senior production editor of The Federal Communications Journal.

Read more about Ben DuwveEmailBen's Linkedin Profile
  • Posted in:
    Energy and Utilities
  • Blog:
    Washington Energy Report
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo