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Jennifer Brough

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Jennifer Brough is a partner in the Real Estate, Energy, Land Use & Environmental Practice Group in the firm's San Francisco office.

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On November 20, 2025, the Federal Energy Regulatory Commission issued a Notice of Inquiry (Docket No. RM26-2-000) asking whether operators of liquefied natural gas (LNG) plants should be allowed to perform certain maintenance, repair and upgrade activities without filing a new application under the Natural Gas Act, as is currently the case. The proposal parallels a hydroelectric inquiry released the same day and draws from the Commission’s long-standing 18 C.F.R Part 157 “blanket certificate” framework for pipelines.Continue Reading Streamlining LNG Oversight: FERC’s Next Evolution in Part 157 Approach

On May 29, 2025, the United States Supreme Court issued an 8-0 opinion in Seven County Infrastructure Coalition, et al. v. Eagle County, Colorado, et al. that affirmed agency deference in review of environmental documents prepared under the National Environmental Policy Act (NEPA).[1] This important decision will bring much-needed certainty for project developers and financing agencies that should reduce permitting obstacles resulting in greater time and cost savings to developers.Continue Reading Supreme Court Restores Agency Deference In NEPA Reviews