FERC is considering something it hasn't done in 44 years: extending blanket authorization to LNG facilities. If you operate, develop, or invest in liquefied natural gas infrastructure, the comment deadline is January 26, 2026. That's Sunday.
The Notice of Inquiry dropped in November, but the implications are just now hitting the desks of operators who've spent years working through FERC's case-by-case approval process. The Commission is asking whether routine LNG plant activities should be handled the same way routine pipeline work has been since 1982: through a streamlined blanket certificate that skips individual project orders.
This isn't a minor procedural tweak. It's a potential paradigm shift in how LNG terminals get built, modified, and operated.
What Happened
The NOI That Changed the Question
On November 20, 2025, FERC issued a Notice of Inquiry in Docket No. RM26-2-000, seeking stakeholder input on whether to establish blanket authorization procedures for certain activities at LNG plants. The comment period closes January 26, 2026.
The NOI invites comments on revising FERC regulations to allow LNG plant operators to undertake specific construction, expansion, and operational activities without case-specific orders under sections 3 or 7 of the Natural Gas Act. FERC Chairman Laura Swett framed it directly: "Energy infrastructure needs to be built now, and existing projects need to be maintained efficiently to ensure grid reliability today and in the future."
For context, FERC has maintained a blanket certificate program for interstate natural gas pipelines since 1982. That program lets pipeline operators perform certain routine activities without individual authorization, increasing flexibility and reducing regulatory burden. LNG facilities were explicitly excluded in 1982, and again in 2006, when FERC cited environmental and security concerns and characterized LNG projects as "not within the class of minor, well-understood, routine activities" suitable for blanket treatment.
The Commission now believes circumstances have changed. Since 2006, FERC has evaluated more than 100 LNG project applications. Eight export terminals are operational, eight more are under construction, and another 10 have been approved but not yet built. The agency has significant experience with the engineering, environmental, safety, and security issues specific to LNG plants.
The Broader Policy Context
This NOI doesn't exist in a vacuum. It's part of a broader deregulatory push that accelerated after President Trump's January 2025 executive order, "Unleashing American Energy" (E.O. 14154), which lifted the Biden administration's pause on LNG export approvals and directed DOE and FERC to cut permitting timelines.
In June 2025, FERC took four separate actions to ease regulatory burdens on natural gas infrastructure. One key move: a one-year waiver (through June 30, 2026) allowing pipeline developers to begin construction immediately after receiving a certificate, even if rehearing requests are pending. The cost threshold for projects that can proceed under prior-notice provisions jumped to $61.65 million.
The LNG blanket authorization NOI is the logical next step. If FERC proceeds to rulemaking, it would extend the same streamlining philosophy to the facilities that turn natural gas into an export commodity.
What It Means
The Case for Blanket Authorization
The operational case is straightforward. Under current rules, even minor modifications at an LNG terminal can trigger a full FERC application process. Want to upgrade a vaporization unit? Replace aging compressors? Add a small-scale efficiency improvement? Each change potentially requires a case-specific authorization order, with the associated timelines, filings, and uncertainty.
A blanket certificate program would create categories of pre-approved activities. Operators could proceed with qualifying work by filing a notice, not an application, and in some cases without any filing at all. The model would mirror what's worked for pipelines for four decades.
For LNG developers with expansion plans, this matters right now. Venture Global just filed to increase its CP2 terminal capacity from 28 to 35 million metric tons per year. Under current rules, that amendment requires individual FERC review. Under a blanket regime, certain categories of expansion might qualify for expedited treatment.
The Counterarguments
Not everyone sees blanket authorization as appropriate for LNG. The original exclusions in 1982 and 2006 reflected real concerns.
First, scale and complexity. LNG facilities are fundamentally different from pipeline segments. They involve cryogenic processes, hazardous materials handling, and concentrated infrastructure footprints. A blanket certificate for a 10-mile pipeline extension is categorically different from a blanket certificate for expanding a 28 MTPA liquefaction train.
Second, environmental review. The National Environmental Policy Act requires FERC to evaluate environmental impacts before authorizing projects. Blanket certificates work for pipelines partly because many pipeline activities involve previously disturbed corridors. New LNG construction often doesn't have that history.
Third, safety and security. LNG terminals are critical infrastructure with unique risk profiles. Post-9/11 security requirements added layers of review that FERC may not be able to streamline without legislative changes.
FERC's NOI acknowledges these concerns by asking stakeholders to comment on which specific activities should qualify for blanket treatment, and what compliance demonstrations operators should provide. This isn't an all-or-nothing proposal. The question is where to draw lines.
What the Final Rule Might Look Like
Based on the NOI's framing and the pipeline blanket certificate precedent, here's a reasonable prediction: a tiered system.
Tier 1 (Automatic): Certain maintenance, replacement, and operational activities that don't increase capacity or footprint. These might proceed with no FERC filing required, subject to annual reporting.
Tier 2 (Prior Notice): Modifications below a cost or capacity threshold. Operators file a notice; the project proceeds unless FERC objects within a set period (often 45-60 days for pipeline blanket certificates).
Tier 3 (Case-Specific): Major expansions, new liquefaction trains, or activities with significant environmental implications. These would still require full NGA Section 3 or 7 applications.
The NOI asks stakeholders to comment on all of these structures. If you have views on where specific activities should fall, this is the time to put them on record.
Getting Your Comments on File
Filing comments to FERC isn't as simple as sending an email. If your company wants to shape this rulemaking, here's what the process actually looks like.
How to File Comments
Comments must reference Docket No. RM26-2-000 and include the commenter's name, organization (if applicable), and address. Electronic filing through ferc.gov is preferred. Paper filings go to the Secretary of the Commission at 888 First Street NE, Washington, DC 20426.
There's no page limit, but effective comments typically run 5-15 pages. They should address specific questions posed in the NOI, not just express general support or opposition.
What FERC Actually Wants to Hear
The NOI poses questions across five broad areas:
1. Process: What procedures should FERC follow for issuing blanket authorizations? Should there be different processes for existing versus new facilities?
2. Eligible Activities: Which construction, modification, and operational activities should qualify? Should there be cost or capacity thresholds?
3. Compliance Demonstration: How should operators show they qualify for blanket treatment? What ongoing reporting should be required?
4. Interaction with Other Laws: How would blanket certificates interact with NEPA, the Coastal Zone Management Act, state permitting, and other regulatory frameworks?
5. Security: What safeguards are needed given LNG facilities' critical infrastructure status?
If you're an operator, the most valuable comments address specific activities your facility performs and explain why blanket treatment would (or wouldn't) be appropriate. Concrete examples carry more weight than abstract policy arguments.
How This Shows Up in Your Deal Documents
If you're involved in LNG project financing, joint venture agreements, or offtake contracts, this NOI has implications for your deal documents.
Development agreements often include regulatory approval milestones tied to FERC certificates. If blanket authorization becomes available for certain modifications, those milestones may need redefinition. What previously required a FERC order might soon require only a FERC notice, or nothing at all.
Lenders and equity investors will want clarity on how blanket certificates affect risk allocation. Does a blanket authorization carry the same legal weight as a case-specific certificate? (Based on the pipeline precedent, yes.) How does the rehearing waiver affect project finance timelines?
If you're negotiating LNG project documents in 2026, you'll want contingency language that accounts for potential regulatory changes. The safe bet: include provisions that adjust approval timelines and milestone definitions if FERC adopts blanket authorization for relevant activities.
Practical Takeaways
If you operate, develop, finance, or invest in LNG infrastructure, here's your compliance checklist:
Review the NOI immediately. The full document is at Docket No. RM26-2-000. Identify which proposed activities affect your operations.
Decide whether to file comments by January 26. If blanket authorization would materially affect your projects, this is your best opportunity to influence the rule. Friday is your last realistic workday.
Inventory your routine modification activities. Which activities currently require case-specific FERC authorization? Build a list of what you'd want included in a blanket program.
Coordinate with industry associations. API, LNG Allies, and similar groups likely are preparing comments. If you can't file individually, ensure your priorities are represented in trade group submissions.
Brief your project finance teams. If you have pending or planned LNG investments, explain how blanket authorization could affect approval timelines and deal structures.
Review pending deal documents. Check whether regulatory milestone definitions would need updating if FERC adopts blanket treatment for certain activities.
Track the rulemaking calendar. If FERC moves to a proposed rule after reviewing comments, there will be another comment period. Add this docket to your regulatory watch list.
What We're Watching
January 26, 2026: Comment deadline for FERC LNG blanket authorization NOI (Docket No. RM26-2-000).
February 6, 2026: Intervention deadline for Venture Global CP2 expansion to 35 MTPA.
June 30, 2026: Expiration of FERC's pipeline certificate rehearing waiver.
Q2-Q3 2026: Potential FERC proposed rule on LNG blanket authorization (timing depends on comment volume and complexity).
2027 projection: If FERC follows typical rulemaking timeline, final rule could be effective by mid-2027.
The LNG industry has been waiting 44 years for FERC to reconsider blanket authorization. The agency is now asking the right questions. The answers will depend partly on what stakeholders put in the record over the next three days.
If you've spent years working through FERC's case-by-case process, you know what works and what doesn't. That operational knowledge is exactly what the Commission needs to hear. File your comments, or make sure someone files them for you.
The window closes Sunday.