FERC moves to drop air-dispersion modelling from its gas reviews — what that changes

Serguey Asael Shinder17 October 2026, 08:432 min read

At the same 15 October 2026 meeting where it proposed a blanket authorization program for LNG plants, FERC issued a draft policy statement (Item C-2, Docket PL26-3-000) that would change how it reviews air quality effects of natural gas projects under the National Environmental Policy Act (NEPA). This piece looks at what the draft would actually change and where the disagreement lies.

The proposed change. FERC proposes to no longer request air dispersion modelling from applicants for Natural Gas Act projects, nor to rely on such modelling when assessing operational air-quality effects under NEPA. Air dispersion models simulate how a project's emissions spread in the atmosphere and interact with background pollution and nearby sources. FERC's reasoning is that the Clean Air Act's regulations already cover this, administered by the EPA and state air agencies, so its own modelling duplicates work Congress assigned to those bodies. The Commission says it will still address air-quality effects in its NEPA documents and disclose adverse effects, but "in a more streamlined way", using other information from applicants and staff.

The stated rationale, in its own words. In the companion LNG proposal, Chairman Laura V. Swett called air dispersion modelling "an unnecessary source of confusion, delay and litigation risk" and "a tremendous boon for the infrastructure opponents and lawyers who litigate the commission's natural gas authorizations". The draft policy statement frames the move as bringing NEPA analysis "back in line with the statutory text and common sense" and avoiding functional duplication of Clean Air Act review.

The dissent. The vote on the draft policy statement was not unanimous. Commissioner Judy Chang dissented, saying the change would make it harder to assess how people near a gas project may be affected. She called air dispersion models "the best tool we have for understanding the likely local and regional air impacts of the projects we permit, outside of actually having physical monitors". That is the crux: FERC's majority treats the modelling as redundant with Clean Air Act permitting; the dissent treats it as the main way NEPA itself surfaces local impacts for the public record.

What is actually settled. Nothing yet. This is a draft policy statement, open for comment until 16 November 2026, and a policy statement guides how FERC exercises discretion rather than binding it as a rule would. For anyone tracking a pending gas or LNG application, the practical reading is that the air-quality section of NEPA reviews is the part in play, that EPA and state Clean Air Act permits are where the majority would place that scrutiny, and that the comment window is the point of leverage before anything takes effect.

Source: FERC, "FERC Launches NEPA Overhaul to Accelerate Natural Gas Projects" — https://www.ferc.gov/news-events/news/ferc-launches-nepa-overhaul-accelerate-natural-gas-projects