S. 3324 — FERC Greenhouse Gas and Environmental Justice Policy Act of 2025

This section revises the Federal Energy Regulatory Commission's (FERC) criteria under the Natural Gas Act for determining whether proposed interstate natural gas facilities and transportation are required by the present or future public convenience and necessity by adding a new subsection (i) to section 7 that requires FERC to assess (1) whether environmental effects—including those on environmental justice communities—are significant and mitigable via an applicant-submitted proposal required under amended section 7(d); (2) whether any significant unmitigated effects outweigh project benefits; and (3) whether the project ensures energy reliability and affordability. (As background, section 7(c) generally requires FERC to issue a certificate of public convenience and necessity before a natural gas company may construct, extend, or operate interstate transportation or sales facilities.) To determine significance, FERC must evaluate effects on environmental justice communities based on existing and cumulative environmental/public health stressors after public engagement and quantify reasonably foreseeable greenhouse gas emissions—including upstream leakage, construction/operations, downstream combustion, and cumulative effects on environmental justice communities—presuming emissions of at least 100,000 metric tons of carbon dioxide equivalent per year to be significant (using 20-year global warming potentials from the latest Intergovernmental Panel on Climate Change assessment report). FERC must require mitigation proposals addressing climate change and environmental justice community effects, impose practicable conditions to mitigate effects below significance thresholds (explaining any exceptions in detail), and weigh any remaining significant effects against project benefits. (Thus, the provision prioritizes avoiding disproportionate environmental/public health burdens on environmental justice communities and limiting high-emitting projects absent adequate mitigation.)