The Commission is issuing the Interim GHG Policy Statement to explain how it will assess the impacts of natural gas infrastructure projects on climate change in its reviews under the National Environmental Policy Act (NEPA) and the Natural Gas Act (NGA). The Commission seeks comment on all aspects of the interim policy statement, including, in particular, the approach to assessing the significance of the proposed project’s contribution to climate change. 

The guidance is subject to revision based on the record developed in this proceeding, however, the Commission will begin applying the framework established in this policy statement in the interim. This will allow the Commission to evaluate and act on pending applications under section 3 and section 7 of the Natural Gas Act without undue delay and with an eye toward greater certainty and predictability for all stakeholders

Greenhouse Gas Emissions Threshold

  • A project’s reasonably foreseeable greenhouse gas (GHG) emissions will be based on a projection of the amount of capacity that actually will be used, the projected utilization rate and any other factors impacting the quantification of project emissions.
  • The Commission is establishing a rebuttable presumption that proposed projects with 100,000 metric tons per year of carbon dioxide equivalents (CO2e) emissions will be deemed to have a significant impact on climate change

Quantifying GHG Emissions

  • The Commission will follow CEQ regulations and quantify a project’s GHG emissions that are reasonably foreseeable and have a reasonably close causal relationship to the proposed action, including those effects that occur at the same time and place as the proposed action and effects that are later in time or farther removed in distance from the proposed action. 
  • This will include GHG emissions resulting from construction and operation of the project and, in many cases, GHG emissions resulting from the downstream combustion of transported gas.  
  • The Commission will consider all evidence in the record relating to a project’s estimated GHG emissions, including utilization rate or offsets. 
  • The Commission will:
    • Consider direct emissions of a project to be reasonably foreseeable;
    • Not consider the upstream and downstream emissions associated with NGA section 3 export facility projects; 
    • Consider on a case-specific basis whether downstream emissions are a reasonably foreseeable effect of an NGA section 7 interstate project; and
    • Consider on a case-specific basis whether upstream emissions are a reasonably foreseeable effect of an NGA section 7 project.


To determine if a project is in the public interest under the NGA, the Commission will consider proposals by the project sponsor to mitigate all or a portion of the project’s climate change impacts, and the Commission may condition its authorization on the project sponsor further mitigating those impacts. 

Application of the Interim GHG Policy Statement

  • The interim GHG policy statement does not establish binding rules and is intended to explain how the Commission will consider these issues when they arise in project-specific proceedings.
  • The interim GHG policy statement will serve as interim guidance for project applicants and stakeholders but the Commission is also seeking public comment on this policy statement.
  • The interim GHG policy statement will apply only to pending and new projects; those applicants with projects now pending before the Commission will have the opportunity to supplement their records. Stakeholders will have the opportunity to respond.


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This page was last updated on February 17, 2022