On October 21, 2025, the U.S. Department of Energy (DOE) issued a final order (DOE/FECM Order No. 5264-A1) granting Venture Global CP2 LNG, LLC long-term authorization to export up to 1,446 billion cubic feet per year of domestically produced liquefied natural gas (LNG) from its Louisiana facility to countries without a free trade agreement with the United States (Non-FTA Countries). The final order follows a March 2025 Conditional Order,2 which issued while DOE was still completing its review of the agency’s 2024 LNG Export Study.3 The final order confirms that the project’s export volume and term authorization (through December 31, 2050) are unchanged, but provides for a three-year “make-up period” to allow export of any approved volume not shipped during the original term.
The October order reflects several policy updates from the March conditional order. It follows other recent DOE final orders that cite the 2024 LNG Export Study’s findings that the United States has sufficient natural gas supply to support both domestic consumption and export demand, with LNG exports likely to yield net economic benefits, enhance domestic energy security and result in only modest impacts on domestic prices. The October Order deems the environmental analysis in the 2024 LNG Export Study to be irrelevant, instead finding that the DOE’s review under the National Environmental Policy Act (NEPA) considers all relevant environmental effects from the proposed exports. DOE applied its NEPA B5.7 categorical exclusion to the project, which limits the scope of the agency’s environmental review to the export of natural gas by marine vessel. DOE cites the Supreme Court’s recent Seven County Infrastructure Coalition v. Eagle County, CO to support its use of a categorical exclusion, and the Court’s finding that environmental impacts associated with upstream production and downstream consumption fall outside the scope of its NEPA analysis for this authorization. In sum, the final order signals the DOE’s commitment to advancing U.S. LNG infrastructure under a streamlined regulatory framework that does not place any emphasis on greenhouse gas emissions and environmental justice community impacts, which were hallmarks of DOE policy under former President Biden.
Akin has published several Speaking Energy blog posts about recent DOE activities on LNG exports, including on the finalization of the 2024 LNG Export Study, here, and other export terminal authorizations, here.
1 DOE/FECM Order No. 5264-A, October 21, 2025, “Final Order Granting Long-Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations.”
2 DOE/FECM Order No. 5264, March 19, 2025, “Order Conditionally Granting Long-Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations.”
3 U.S. Department of Energy, Office of Fossil Energy and Carbon Management. 2024 LNG Export Study: Energy, Economic, and Environmental Assessment of U.S. LNG Exports. 89 Fed. Reg. 104132 (Dec. 20, 2024). Available at: https://www.federalregister.gov/documents/2024/12/20/2024-30370/2024-lng-export-study-energy-economic-and-environmental-assessment-of-us-lng-exports.
