Weakening FERC and NRC Climate Oversight Locks In Decades of Fossil Fuel and Nuclear Risk
Project 2025 directs FERC to ignore upstream/downstream climate impacts when approving natural gas pipelines and LNG terminals, and orders NRC to expedite nuclear license extensions while eliminating the ALARA radiological protection principle. These steps are designed to fast-track fossil fuel and nuclear infrastructure without meaningful environmental review, locking in emissions for decades and eroding public health safeguards.
This section of Project 2025 treats FERC and NRC not as independent watchdogs but as project expeditors for the fossil fuel and nuclear industries. At FERC, the mandate is clear: limit NEPA analysis to the physical pipeline itself, ignoring the methane leaks from upstream production, the emissions from downstream power plants, and the cumulative climate damage of an entire LNG export facility. This is a deliberate blindfold. The Biden-era DOE 2024 LNG Export Study already demonstrated that GHG emissions can—and should—be part of the public interest determination. Rolling that back ensures the United States continues approving gas export infrastructure that, once built, will operate for 30+ years, directly contradicting the IPCC's 1.5°C window.
At the NRC, the push to eliminate ALARA—"as low as reasonably achievable"—is especially dangerous. ALARA is the bedrock principle that forces operators to minimize radiation exposure even when a dose is technically legal. Replacing it with static, risk-based standards would permit higher cumulative exposures for workers and communities, disproportionately affecting the low-income and rural populations living near reactors. The directive to complete Combined Operating Licenses in two years and Early Site Permits in one year also pressures reviewers to cut corners on safety and environmental justice analysis. While the DC Circuit has already forced NRC to conduct new NEPA reviews for license renewals, this chapter's proposals aim to undermine that ruling administratively.
Environmental justice is not an afterthought here—it is the target. FERC's current NEPA practice already considers cumulative impacts on overburdened communities; this blueprint would erase those considerations entirely. Communities along the Gulf Coast, already choking under petrochemical pollution, would see a new wave of LNG terminals approved without climate analysis. The alternative is clear: restore and expand climate and public health analysis at both FERC and NRC, codify ALARA, and make environmental justice a mandatory part of every licensing decision.
The humanitarian alternative
Codify into law that FERC and NRC must consider direct, indirect, and cumulative climate effects in all licensing decisions, and require that public interest determinations include a finding that a project does not undermine U.S. climate commitments. Restore ALARA by statute and expand environmental justice screening tools across both agencies.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Rescind FERC policy statements limiting NEPA analysis A future FERC majority (post-2028) can withdraw any policy statements that restrict NEPA review to direct impacts and reinstitute full consideration of upstream/downstream climate effects.
- Reinstate ALARA through NRC rulemaking NRC must issue a new rule restoring ALARA as the regulatory standard for radiation protection; Congress could also pass legislation codifying ALARA to prevent future elimination.
- Restore GHG consideration in DOE LNG export determinations DOE could issue a new public interest determination that reinstates GHG emissions as a factor, requiring DOE to find that exports are consistent with U.S. climate goals.
Reversing it is step one. The forward agenda — what we build so it can’t recur — is in Answers to this entry →
Grounded in
- FERC Natural Gas Pipeline Certificate NEPA Review (CRS)
- Energy, Economic, and Environmental Assessment of US LNG Exports (DOE 2025)
- DOE and FERC Step on the Gas: LNG in the New Trump Administration (Venable, Sep 2025)
- Failing the Climate Test (Greenpeace, Jul 2025)
- NRC Status of Subsequent License Renewal Applications
- NRC Ordered New Environmental Reviews for Subsequent License Renewals (Hogan Lovells, Mar 2022)
- NRC Approves Subsequent License Renewal for Oconee (ANS News, Apr 2025)
- U.S. Federal Oversight of Nuclear Reactors by NRC, DOE, and DoD (Nuclear Innovation Alliance, Nov 2025)
Original source — excerpted
project2025 Project 2025 ch. 13: EPA (pp 440-442)"— 407 — Department of Energy and Related Commissions New Policies FERC should: l Recommit itself to the NGA’ s purpose of providing the American people with access to affordable and reliable natural gas. l Limit its NGA decision-making on natural gas pipeline certificates to the question of whether there is a need for the natural gas. l Limit its NEPA analysis to the impacts of the actual pipeline itself, not indirect upstream and downstream effects. In addition, Congress, the states, and FERC should consider how better to pro- tect and compensate property owners whose property is taken for the benefit of the public. FERC also needs to be mindful that natural gas pipelines and projects are important for domestic access to natural gas, including local natural gas utilities, natural gas–fired electric generation, and manufacturing, as well as for exports of liquefied natural gas. FERC: LNG EXPORT FACILITIES Mission/Overview FERC permits, sites, and authorizes the construction and operation of LNG export facilities.125 It does not authorize the export of natural gas; DOE exercises that authority. LNG export facilities are important for delivering natural gas to markets …"