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On December 18, 2025, FERC maintained that gas pipelines offering service under section 311 of the Natural Gas Policy Act (NGPA) that base their section 311 rates on state-approved rates must nonetheless comply with Straight-Fixed Variable (SFV) rate design or justify a departure from SFV.  Specifically, FERC denied Matterhorn Express…

On October 28, 2025, the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) denied several petitions for review of FERC’s authorization of Gas Transmission NW, LLC’s (GTN) GTN Xpress compressor expansion project (Project).  Specifically, the Fifth Circuit (1) denied GTN’s petition for review challenging FERC’s denial of a…

On October 7, 2025, FERC rescinded the regulation that precluded natural gas pipeline companies from receiving authorization to proceed with construction of their new projects during the period for filing requests for rehearing of certificate orders, or while rehearing is pending. In doing so, FERC stated that its rescission will…

On September 30, 2025, the D.C. Circuit Court of Appeals denied a joint petition for review brought by Sierra Club and Appalachian Voices (together, Petitioners) challenging FERC’s grant of a certificate of public convenience and necessity (CPCN) to Tennessee Gas Pipeline Company (Tennessee Gas) to construct a new natural gas…

On September 30, 2025, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) vacated and remanded FERC’s order approving a two-tiered fuel rate structure for Antero Resource Corporation’s (“Antero”) usage of Tennessee Gas Pipeline Company, L.L.C.’s (“Tennessee Gas”) Broad Run Expansion Project (“Expansion Project”). The D.C. Circuit held FERC’s approval of the rate structure was arbitrary and capricious because it required Antero to always pay for the highest fuel rates irrespective of the segment’s actual operations.

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…

On May 22, 2025, the U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) addressed a dispute between ANR Pipeline Company (“ANR”) and FERC. The case centered on the interpretation of ANR’s tariff and whether it required shippers to deliver and take gas simultaneously, even for short-notice shipments. The Fifth Circuit denied ANR Pipeline Company’s petition for review, affirming FERC’s decision that ANR’s tariff did not require simultaneous delivery for short-notice shipments. The court found the tariff ambiguous and emphasized ANR’s longstanding practice of not requiring simultaneous delivery, which supported FERC’s position.

On May 23, 2025, FERC upheld on rehearing its prior orders authorizing Venture Global CP2 LNG, LLC to build a new liquified natural gas (“LNG”) export terminal (“CP2 LNG Terminal”) and granting Venture Global CP Express, LLC (together, with Venture Global CP2 LNG, LLC, “Venture Global”) a certificate of public convenience and necessity (“CPCN”) to construct and operate a new natural gas pipeline (“CP Express Pipeline,” together, with the CP2 LNG Terminal, the “Projects”) to connect the CP2 LNG Terminal to the existing natural gas pipeline grid (“May 23 Rehearing Order”). In its May 23 Rehearing Order, FERC continued to find that the Projects are environmentally acceptable actions and not inconsistent with the public interest.

On May 9, 2025, fifteen democratic states (“Plaintiff States”) sued the Trump Administration in Washington District Court, claiming that President Trump’s executive order “Declaring a National Energy Emergency” (“Executive Order”) is unlawful. The Plaintiff States argue that the Executive Order commands federal agencies to disregard the law and applicable regulations to fast-track activities that will damage waters, wetlands, endangered species, and the people and wildlife that rely on these resources.