Originally published for customers December 31, 2025.
What’s the issue?
As 2025 comes to a close, we look back at how developments across gas, power, permitting, and project execution reshaped the infrastructure landscape.
Why does it matter?
The pace and volume of change blurred signal and noise. Understanding where authority consolidated and where risk actually migrated will matter heading into 2026.
What’s our view?
A pro-gas administration, combined with a fully seated Commission, conservative courts, and rising power demand, shifted the balance toward execution — restoring project momentum and reviving permitting reform as a live question.
A change in administration opened 2025, and the year closed with a materially reshaped Commission. Over the course of the year, the administration’s posture and the Supreme Court’s Seven County decision clarified the outer bounds of NEPA review. Opposition did not disappear, but federal litigation risk declined as agencies gained clearer discretion over the scope of environmental analysis. Against this backdrop, roughly 6 Bcf/d of additional pipeline capacity entered service, as shown below.
At the same time, AI-driven load growth and tightening reliability conditions created new operational demand in the power market, and a more favorable political climate aligned with that pressure to support renewed gas demand. The result was an uptick in project development with multiple projects moving through permitting, litigation, and construction at once, often across different jurisdictions and procedural postures. In that environment, market participants needed a way to track project progress, distinguish momentum from noise, and forecast project in-service.
Arbo evolved in 2025 to meet that gap. Building on more than a decade of infrastructure intelligence, we launched ArView Project Intelligence (PI) in late 2024, and refined it throughout 2025. ArView PI tracks and alerts on project permitting, litigation, and construction milestones to generate benchmarked in-service projections grounded in observed project behavior.
The Trump administration’s pro-gas posture was evident from the start as explored in Day-One Energy Orders Signal Major Regulatory Shift. That tone mattered as power demand accelerated and reliability concerns sharpened.
Coming up on year’s end, the Commission itself has changed. Following Chairman Christie’s departure and Commissioner Rosner’s brief chairmanship, Laura Swett assumed the Chair. The fully seated Commission is operating with a collaborative posture, authorizing projects, and resolving long-running regulatory questions.
That shift was clear with the return of Transco’s Northeast Supply Enhancement project (NESE). FERC’s decision to reauthorize NESE, analyzed in Miracle on Docket 101 — Part II: NESE’s Return, marked the first time the Commission reissued a certificate that it had previously vacated, where demand signals and precedent agreements remained intact.
Procedural actions reinforced that direction. FERC rescinded Order 871, which had barred construction during the rehearing window. It temporarily raised blanket certificate cost limits and initiated a rulemaking to consider doing so permanently, as covered in The INGAA Two-Step: Waivers Now, Reforms Later?. The Commission also launched a proceeding to explore LNG blanket authorizations, as discussed in LNG Blanket Authorizations Arrive, Oil Indexing Finally Settles.
The Commission also focused on regulatory cleanup. It resolved long-running oil-indexing disputes, clarified its market-need analysis in reinstating the certificate for the Regional Energy Access Expansion (REAE) project, and formally closed the door on the Glick-era draft GHG policy statement, as discussed in FERC Ties Up Loose Ends: REAE, GHG Policy and the Changing Regulatory Landscape. Most recently, FERC clarified its approach to Section 311 rate regulation as discussed in Lines Drawn: Large Loads, Matterhorn and MVP Southgate.
If changes in governance set tone, Seven County clarified doctrine. As we explored in The Seven County Decision and the Boundaries of the NEPAverse, the Supreme Court narrowed when agencies must analyze indirect and downstream effects and reinforced deference to agency line-drawing in NEPA analysis. Subsequent appellate decisions confirmed that shift. The D.C. Circuit’s treatment of Cumberland, discussed in Deference Delivered: Cumberland’s D.C. Circuit Win Sets the Seven County Baseline, and the Fifth Circuit’s approach to GTN Xpress, discussed in Two Paths to Deference: The Fifth Circuit Charts FERC’s Authority on NEPA and Rates, both applied Seven County in ways that favored agency discretion.
Two additional developments reshaped NEPA implementation during the year, as discussed in The New NEPA: Guidance Without Direction, Deadlines Without Definition:
The combined effect has been greater durability for federal NEPA approvals, with the potential for faster timelines, though the mechanics of the expedited review process remain unsettled. Vacaturs like those seen in Rio Grande LNG and REAE are now far less likely under the clarified Seven County standard. Without binding CEQ regulations, agencies have greater flexibility in how they conduct NEPA reviews, so long as statutory requirements are met. So while NEPA litigation will not disappear, it has lost some of its stopping power.
At the same time, related arguments increasingly surfaced in state proceedings. This was evident in Louisiana, where climate and environmental justice claims migrated into state permitting disputes for Commonwealth LNG, as covered in Blurring Lines – Commonwealth LNG Climate and EJ Arguments Cross Into State Court.
Power demand was the constant backdrop and gas remained a central part of the discussion. Data center growth, AI load, and electrification pressures pushed PJM and ERCOT to confront co-location, interconnection backlogs, and cost allocation, often without resolving them. We examined several emerging responses, most recently FERC’s co-located load framework for PJM, which now moves into implementation.
Coal-to-gas conversions such as Cumberland and Ridgeline reflected both reliability needs and the difficulty of adding new capacity quickly. They also illustrated how litigation and permitting risk can span multiple venues.
When you sum it up, federal regulatory litigation risk declined over the course of the year, particularly in NEPA challenges, as courts showed signs of greater deference to agency judgment. At the same time, arguments related to GHG emissions and environmental justice found greater traction in state forums. These changes are still new and the pathway from litigation to precedent is long, so we will continue to see arguments unfold.
Although the Commission is now fully seated and regulatory clarity has increased at FERC, including through changes to blanket authority and large-load policy, material friction points remain. Clean Water Act approvals and other non-federal authorizations continue to shape project outcomes and timelines. We will examine those remaining constraints in more detail in a subsequent article exploring what to watch for in 2026.
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