Originally published for customers April 18, 2025.
What’s the issue?
Although FERC’s April open meeting did not have any new gas certificates on the docket, it focused on reliability concerns. With grid reliability at risk and dispatchable resources retiring, the in-service timings of natural gas projects are becoming increasingly important.
Why does it matter?
Our historical benchmarks indicate that most short-distance projects can be completed in under three years, and recent studies confirm natural gas’s increasing role in grid reliability.
What’s our view?
Developers are still advancing projects through the prefiling, application, and construction phases, and benchmarks can provide insight into when new gas projects might come online.
Although FERC’s April open meeting did not have any new gas certificates on the docket, it focused on reliability concerns. With grid reliability at risk and dispatchable resources retiring, the in-service timings of natural gas projects are becoming increasingly important.
Our historical benchmarks indicate that most short-distance projects can be completed in under three years, and recent studies confirm natural gas’s increasing role in grid reliability. Developers are still advancing projects through the prefiling, application, and construction phases, and benchmarks can provide insight into when new gas projects might come online.
While FERC’s April meeting lacked certificate approvals, natural gas remained the primary topic within the context of reliability. Reports highlighted the emerging risks associated with winter storms and increasing data center demand. Chairman Christie credited natural gas with helping to avoid load shedding during recent storms, noting record peak gas demand and stronger coordination between gas and power.
A presentation by NERC raised new concerns: large data centers going offline simultaneously, creating grid frequency imbalances. Christie noted that losing load may pose a similar risk as losing generation. The discussion at the meeting indicates that the conversation around reliability is evolving fast and underscores the importance of pipeline infrastructure.
As we highlighted in Tracking Capacity: Forecasting the Next Wave of Gas Infrastructure, a substantial volume of interstate natural gas capacity remains in various stages of development. From pre-filing to pending certificate applications, developers continue to advance a wide range of projects.
Creating benchmarks based on historical data can help forecast when these projects could move forward, as well as provide valuable insights that enable stakeholders to better anticipate when projects will become operational. This is particularly important as natural gas infrastructure continues to play a crucial role in ensuring electric reliability.
In Demystifying LNG Terminal Timelines, we discussed how most LNG projects typically follow ten key FERC orders. By aggregating historical data and analyzing timing trends of these orders, they serve as valuable benchmarks to forecast when projects are likely to enter service.
For pipelines, we apply a similar methodology, identifying four key stages that a typical project goes through before being placed into service: application submittal, environmental review, pending certificate issuance, and construction.
To develop accurate benchmarks, we analyzed how long more than 240 projects spent in each of these stages. While timelines can vary due to factors such as litigation, opposition, and the complexity of environmental reviews, our analysis suggests that project mileage is the most significant factor in determining duration. Based on this, we categorized projects by length: zero-mile projects (typically involving only compressor station upgrades or construction), 1–50 miles, 51–100 miles, 101–150 miles, and over 150 miles.
Arbo’s data acquisition system monitors the FERC e-Library for status changes to a project. The following example illustrates how we analyze keywords in FERC filings to determine when a project has progressed to a new stage.
This particular analysis excludes the pre-filing stage, as not all projects are required to pre-file; however, we do analyze pre-filing timelines when relevant. To reflect the current permitting environment, we excluded projects approved between 2008 and 2013. Additionally, we excluded projects filed between 2021 and 2022, during which permitting delays were unusually prolonged due to broader environmental reviews under Chairman Glick. As noted in Shifting Headwinds Set the Stage for New Interstate Buildout, Glick’s tenure significantly slowed project development and influenced the types of projects proposed.
The chart below shows the average time projects spend in each stage, grouped by total mileage. Projects longer than 50 miles tend to have extended timelines, primarily due to longer construction periods and more rigorous environmental reviews. Projects under 50 miles often undergo less intensive environmental review processes, resulting in shorter overall timelines.
On average, shorter projects (0–50 miles) take approximately 28 months from submitting a 7(c) application to completing construction, compared to roughly 33 months for projects exceeding 50 miles. Additionally, our analysis reveals a large gap between the mean and median for projects under 50 miles. This reflects the variability in two key phases: the time projects wait to begin construction after receiving FERC approval and the duration of the construction period itself.
Some projects begin construction soon after receiving approval, while others face delays or intentionally wait until a related project is placed into service. This can extend the time between a project receiving its certificate and beginning construction. Projects with prolonged timelines in either the pre-construction or construction phase raise the mean, even though most projects follow a more typical timeline that falls closer to the median.
To validate our benchmarking model, we tested it against three projects completed within the past year, each within the 1–50 mile range. Collectively, these projects added over 1.7 Bcf/d of new capacity and tracked closely with our forecasted timelines.
Although we initially excluded projects filed during Chairman Glick's tenure from our broader dataset, two of the three projects evaluated below filed applications during Glick’s tenure. Nevertheless, our benchmarks remain robust and accurate, as both projects fell within our expected data ranges, despite being reviewed in environmental impact statements, resulting in longer review periods compared to our average and median for projects within the same category.
A project trending ahead of the average timeline in one stage does not guarantee early completion. Both construction and regulatory timelines are highly variable and can shift due to a range of factors, including litigation, public opposition, or the scope of environmental review. These elements can introduce delays that offset earlier progress, underscoring the importance of evaluating each stage within the broader context of a project’s full development cycle.
To complement our benchmarking analysis, we’ve developed a Monte Carlo simulation model to generate more dynamic, project-specific timeline forecasts. We start by identifying a project's “nearest neighbors” based on shared characteristics, such as pipeline length, location, timing, and capacity, and simulate how long each phase might take based on historical outcomes. This produces a range of outcomes, including the 25th percentile, median, and 75th percentile durations, which provide low, median, and high estimates for each phase. This method enables us to consider both historical precedent and project-specific nuances, providing stakeholders with a more realistic and probabilistic view of potential timelines.
It appears that forecasting the future of infrastructure necessitates more than simply monitoring dockets. It involves combining regulatory intelligence with quantitative forecasting and tracking risks that may not be immediately apparent in the permit itself.