Speak up for clean air
Comments are due Monday, November 16
The Federal Energy Regulatory Commission (FERC), the federal agency that approves gas pipelines, compressor stations, and LNG terminals, wants to stop studying how pollution from these facilities affects air quality in nearby neighborhoods. Before a project is approved, residents deserve to know what they will be breathing. Tell FERC to keep its air quality review.
What FERC is proposing
For years, FERC has asked companies building compressor stations and LNG terminals to provide “air dispersion modeling.” This modeling shows where a facility’s pollution goes and how much reaches nearby homes, schools, and parks. FERC compares those results to EPA’s health-based air quality standards. That comparison tells FERC whether a project could push local pollution to unhealthy levels.
FERC now proposes to drop this review. It would no longer ask for the modeling. Instead, it would generally assume that a project’s air pollution is not significant if the company has a state air permit. A state permit with a broad, regional perspective doesn’t tell us everything about impacts for the fenceline communities who are directly affected by these projects. Some expansion projects may get no review at all, and unhealthy spikes in air pollution may get obscured by looking broadly at yearly totals.
If these proposed changes are accepted, fossil fuel projects that spew emissions into the surrounding air, poisoning our environment and communities, can be approved with even less FERC oversight. You can access the full draft policy statement here.
FERC MUST WITHDRAW THE PROPOSED RULE for the safety of our communities and environment. Under-regulated and outright unregulated fossil fuel infrastructure is dangerous for the future of our air and water quality, climate safety, and access to clean and healthy environments.
FERC is seeking public comments on the proposed changes until November 16, 2026. We encourage you to submit a comment rejecting the changes, using the sample comment below if you so choose.
Comment as an individual, or on behalf of an organization you represent, TODAY!
(it only takes a few minutes!)
!! Be sure to reference the appropriate docket number when submitting your comments:
Docket No. PL26-3-000 !!
Step-by-step instructions for using FERC e-Comment:
- Go to FERC Online e-Comment web page: https://ferconline.ferc.gov/QuickComment.aspx
- Enter the required Name, Address, Contact, CAPTCHA information into the online form to authorize your e-Comment.
- You will receive an e-mail from FERC.gov with a special quick comment link with a hashcode at the end of the URL. Click this link to go back to the e-Comment portal.
- Enter the docket number PL26-3-000 into the search box and click “Search”. Click the blue plus sign (+) to the right of the docket that appears to select it for your comment.
- Enter your comment of up to 10,000 characters in the provided box. Feel free to use the sample comment below as a starting point.
- Note: Personal details make a comment stronger: where you live, how close you are to a pipeline, compressor station, or LNG facility, and whether you or your family have asthma or other health concerns.
- Click the “Send Comment” button to submit. You should see a screen saying that you have successfully submitted a comment and you will receive an email confirming your submission.
Sample Comment:
I am writing to oppose FERC’s Draft Policy Statement on Efficient Environmental Reviews of Natural Gas Project Applications, Docket No. PL26-3-000.
FERC should continue to require air dispersion modeling for compressor stations and LNG facilities. This modeling is the only way to know how much pollution will reach the homes, schools, and neighborhoods near these facilities. A state air permit cannot serve as a substitute. State permits look at air quality across entire regions, not at what people breathe near a facility, and small expansions at existing compressor stations often receive no state modeling at all.
Yearly emissions totals cannot show short-term pollution spikes that harm people with asthma and other health conditions. That matters in places like the Philadelphia region, which EPA already classifies as a serious ozone nonattainment area.
FERC has a legal duty to evaluate the effects of the facilities it approves. I urge FERC to withdraw this proposal. If it moves forward, FERC should at minimum keep modeling for expansions of existing facilities, LNG terminals, projects in areas with unhealthy air, and projects near homes, schools, and hospitals, and it should make all state permit materials public before it decides.
[Your name, town, and any personal connection to the issue]
COMMENTS ARE DUE MONDAY, NOVEMBER 16, 2026 BY 5:00pm ET.
Additional Background:
Issues with the State Permit Approach
A state permit doesn’t answer the question that matters to people who stand to be directly affected by these projects. State air programs look at whether a whole region meets federal standards, and some regions are as large as a state. They don’t show what happens at the fence line or down the street. A project can fit within a state’s regional plan while still adding pollution to a neighborhood that’s already struggling with unhealthy air.
Some projects would get no review at all. Smaller expansions at existing compressor stations often fall below the threshold for a state permit, so the state doesn’t model them either. Under FERC’s proposal, no one would look at what these expansions add to the pollution already coming from the station. In the Delaware River Watershed, many projects are expansions of existing compressor stations.
Additionally, yearly pollution totals don’t show unhealthy spikes. FERC would rely on estimates of how many tons of pollution a facility releases each year. Some health standards protect people from short spikes, such as one hour of high nitrogen dioxide, that can trigger asthma attacks. A yearly total can’t show those spikes.
Our region already has unhealthy air. EPA classifies the Philadelphia-Wilmington-Atlantic City area as a “serious” ozone nonattainment area. Compressor stations and LNG facilities release nitrogen oxides, which form ozone.
The modeling has made a difference, which is why it is crucial that it remains. When FERC approved the Atlantic Sunrise expansion in Pennsylvania, modeling showed that existing equipment at two compressor stations could exceed the one-hour nitrogen dioxide standard. As a direct result, FERC required air monitoring. Without the modeling, that problem would never have come to light.
What’s at stake: a full environmental review
A federal law called the National Environmental Policy Act (“NEPA”) requires FERC to study how a project will affect the environment and the people living near it before FERC approves the project. NEPA review comes in two main forms:
- Environmental assessment (“EA”): a shorter review for projects that aren’t expected to cause serious harm.
- Environmental impact statement (“EIS”): the most thorough review the law provides. It’s required when a project could significantly affect the environment or public health. An EIS looks closely at the harms a project could cause, considers other options such as a different location or cleaner equipment, and identifies ways to reduce the damage. The public also gets to read and comment on a draft before FERC makes its final decision.
Whether a project gets a full EIS depends on whether its effects could be “significant.” Under FERC’s proposal, any project with a state air permit would generally be treated as having no significant air quality effects. That means air pollution alone would never be enough to require a full EIS, no matter how close a facility is to homes and schools or how polluted the air already is.
It is notable that FERC’s own commissioners are divided on this. Commissioner Judy Chang dissented and warned that under this policy, no project would ever get a full environmental impact statement because of its air pollution. Because the commission is split, community input could make a real difference.