United States Court of Appeals
         FOR THE DISTRICT OF COLUMBIA CIRCUIT



Argued March 4, 2025              Decided September 30, 2025

                       No. 24-1099

         SIERRA CLUB AND APPALACHIAN VOICES,
                     PETITIONERS

                             v.

       FEDERAL ENERGY REGULATORY COMMISSION,
                    RESPONDENT

    TENNESSEE GAS PIPELINE COMPANY, L.L.C., ET AL.,
                    INTERVENORS



                Consolidated with 24-1198


          On Petitions for Review of Orders of the
          Federal Energy Regulatory Commission



     Spencer Gall argued the cause for petitioners. With him
on the briefs was Delaney King.

   J. Houston Shaner, Attorney, Federal Energy Regulatory
Commission, argued the cause for respondent. With him on
                                 2




the brief were Matthew R. Christiansen, General Counsel, at
the time the brief was filed, and Robert H. Solomon, Solicitor.

     David A. Super argued the cause for intervenors in support
of respondent. With him on the brief were David D. Ayliffe,
Brian D. O’Neill, Michael R. Pincus, Kevin A. Ewing, Ann D.
Navaro, and John P. Coyle.

      Before: PILLARD, KATSAS and WALKER, Circuit Judges.

     Opinion for the Court filed by Circuit Judge WALKER,
with whom Circuit Judge PILLARD joins except as to Parts
II.B.3.a and III.

      WALKER, Circuit Judge:

    “The bedrock principle of judicial review in NEPA cases
            can be stated in a word: Deference.”1

     The Tennessee Valley Authority decided to replace a coal-
fired power unit with a natural-gas turbine. That swap will
significantly reduce greenhouse gas emissions. But the Sierra
Club contends that environmental laws call for more.2 So it
sued to pause the TVA’s plans.3

1
  Seven County Infrastructure Coalition v. Eagle County, Colorado,

, 1515 (2025) (emphasis added).
2
  For simplicity, we refer to Petitioners Sierra Club and Appalachian
Voices collectively as the Sierra Club.
3
  See, e.g., Sierra Club v. Tennessee Department of Environment
and Conservation, 

 (6th Cir. 2025) (rejecting the
Sierra Club’s challenge to a Tennessee agency’s issuance of a water
quality certificate for the same pipeline at issue in this case);
Amended Complaint at 37-53, Appalachian Voices v. TVA, No. 3:23-
cv-00604 (M.D. Tenn. Aug. 8, 2023), ECF No. 16 (alleging the
TVA’s decision to build the natural-gas turbine failed to comply with
federal environmental laws).
                               3




     This suit concerns a 32-mile pipeline that will supply
natural gas to the TVA’s new turbine. The Federal Energy
Regulatory Commission approved that pipeline after
publishing a 576-page environmental impact statement. The
Sierra Club says FERC’s decision violates the National
Environmental Policy Act and the Natural Gas Act.

    Because FERC’s approval is consistent with NEPA, the
Natural Gas Act, and related regulations, we deny the petitions.

                        I. Background

        A. Upgrading the Cumberland Fossil Plant

     The Tennessee Valley Authority is a federal agency
charged with leveraging “the resources of the Tennessee
Valley region” to “make life better for the people who call it
home.” About TVA, https://perma.cc/XES6-FMWV. The
TVA is required to “produce, distribute, and sell electric
power” “at the lowest system cost,” which includes the cost of
“environmental compliance.” 16 U.S.C. §§ 831d(l), 831m-
1(b)(1), (3). Congress also requires the TVA when selecting
new energy resources to “evaluate[ ] the full range of existing
and incremental resources,” including “renewable energy.”
Id. § 831m-1(b)(1). Its power plants include a coal-fired
facility in Tennessee called the Cumberland Fossil Plant.

     Several years ago, the TVA decided to retire the
Cumberland facility’s two coal-fired units. It will replace one
of the coal-fired units with a natural-gas turbine. To provide
the new turbine with a steady supply of gas, the Tennessee Gas
Pipeline Company plans to build a 32-mile pipeline.
                               4




                  B. Statutory Framework

           1. National Environmental Policy Act

     The National Environmental Policy Act requires agencies
to prepare an environmental impact statement when they
approve a “major Federal action[ ] significantly affecting the
quality of the human environment.” 

(2)(C).
The agency must “look hard at the environmental effects” of
the federal action. Minisink Residents for Environmental
Preservation and Safety v. FERC, 

 (D.C. Cir.
2014) (cleaned up). It must also consider any “reasonable
alternatives.” 

 (cleaned up).

    However, “NEPA imposes no substantive environmental
obligations or restrictions.” Seven County Infrastructure
Coalition v. Eagle County, Colorado, 

, 1507
(2025). As “a purely procedural statute,” “NEPA does not
require the agency to weigh environmental consequences in
any particular way.       Rather, an agency may weigh
environmental consequences as the agency reasonably sees fit
under its governing statute and any relevant substantive
environmental laws.” Id.

                      2. Natural Gas Act

     The Natural Gas Act regulates “the business of
transporting and selling natural gas for ultimate distribution to
the public.” 

(a). Relevant here, a company
must obtain a “certificate of public convenience and necessity”
from FERC before building or expanding an interstate natural-
gas pipeline. 

 § 717f(c). FERC “shall” issue a certificate
if the proposed project “is or will be required by the present or
future public convenience and necessity.” Id. § 717f(e).

    Before issuing a certificate, FERC must confirm that the
proposed project will not require subsidization from existing
                                  5




natural-gas customers. Minisink, 

. This is
called “market need.” FERC must also balance the project’s
benefits and harms. 

 That analysis includes “all factors
bearing on the public interest, including environmental ones.”
Food & Water Watch v. FERC, 

 (D.C. Cir.
2024) (cleaned up).

                     C. FERC Proceedings

    In January 2024, FERC issued a certificate of public
convenience and necessity for Tennessee Gas’s 32-mile
pipeline. That decision rested on two main conclusions:

         First, market need was established by the TVA’s
          promise to buy 100% of the pipeline’s capacity
          for 20 years.
         Second, the pipeline’s benefits outweigh its
          harms.        FERC’s 576-page environmental
          impact statement explained that most
          environmental effects will be less than
          significant. 4 FERC also noted that the new
          natural-gas turbine will emit less greenhouse gas
          than the coal-fired unit that it will replace,
          resulting in a net emissions reduction.
          Reasoning that the pipeline will enable the
          operation of the new turbine, FERC credited the
          pipeline for the reduction in net emissions.5
4
  The TVA separately produced a 1,662-page environmental impact
statement evaluating the environmental impacts from the retirement
of the coal-fired unit and various replacement generation sources,
including the natural-gas turbine the TVA has decided to build.
5
  FERC granted the Sierra Club’s request for rehearing. In its initial
order, FERC had erroneously stated that the natural-gas turbine
would replace both Cumberland coal-fired units. So FERC issued
a modified order clarifying that the gas turbine would replace only
                                  6




     The Sierra Club petitioned this court for review. It argues
that FERC violated NEPA and the Natural Gas Act.

                            II. Analysis

     The Sierra Club’s petitions are meritless.

                     A. Standard of Review

     The Administrative Procedure Act tells courts how to
review an agency’s legal interpretations and policy choices.
“As a general matter, when an agency interprets a statute,
judicial review of the agency’s interpretation is de novo.”
Seven County Infrastructure Coalition v. Eagle County,
Colorado, 

, 1511 (2025) (citing Loper Bright
Enterprises v. Raimondo, 

, 2261 (2024)). “But
when an agency exercises discretion granted by a statute,
judicial review is typically conducted under the Administrative
Procedure      Act’s     deferential    arbitrary-and-capricious
standard.” Id.; see 

(2) (instructing reviewing
courts to “hold unlawful and set aside agency action, findings,
and conclusions found to be . . . arbitrary, capricious, an abuse
of discretion, or otherwise not in accordance with law”).

     When conducting arbitrary-and-capricious review, “a
court asks not whether it agrees with the agency decision, but
rather only whether the agency action was reasonable and
reasonably explained.” Seven County, 145 S. Ct. at 1511
(citing FCC v. Prometheus Radio Project, 

,
1158 (2021); Motor Vehicle Manufacturers Association of the
United States, Inc. v. State Farm Mutual Automobile Insurance
Co., 

 (1983)).

one of the retiring coal-fired units. But because FERC continued to
find that the pipeline would result in a net decrease in emissions, it
declined to rescind its approval of the pipeline.
                                7




     Yet this court’s “precedent applying NEPA,” id. at 1510,
has sometimes applied a more probing review in conflict with
NEPA’s “statutory text and common sense,” id. at 1514. That
led to a recent “course correction,” id., directed by the Supreme
Court in Seven County Infrastructure Coalition v. Eagle
County, Colorado. It reaffirmed that “NEPA does not
authorize a court to interject itself within the area of discretion
as to the choice of the action to be taken by the agency.” Id.
(cleaned up). Instead, “[c]ourts should afford substantial
deference and should not micromanage those agency choices
so long as they fall within a broad zone of reasonableness.” Id.
at 1513.

     In other words, NEPA does not require an agency to make
the decision that the reviewing judges “would have reached had
they been members of the decisionmaking unit of the agency.”
Id. (quoting Vermont Yankee Nuclear Power Corp. v. NRDC,

 (1978)). Rather, the “role of a court in
reviewing the sufficiency of an agency’s consideration of
environmental factors is a limited one. The bedrock principle
of judicial review in NEPA cases can be stated in a word:
Deference.” Id. at 1514-15 (cleaned up).

     Under the Natural Gas Act, we “review FERC’s public
convenience and necessity determination for whether it was
based on a consideration of the relevant factors and whether
there has been a clear error of judgment.” Citizens Action
Coalition of Indiana, Inc. v. FERC, 

, 236-37 (D.C.
Cir. 2025) (cleaned up). While we “cannot substitute our
judgment for that of the Commission,” we must nonetheless
ensure “that the Commission’s decisionmaking is reasoned,
principled, and based upon the record.” Minisink Residents
for Environmental Preservation and Safety v. FERC, 

 (D.C. Cir. 2014) (cleaned up). That standard reflects
the APA’s deferential standard of review and the Natural Gas
Act’s policy decision “to encourage the orderly development
                                8




of plentiful supplies of . . . natural gas at reasonable prices.”
NAACP v. Federal Power Commission, 

, 670
(1976), while keeping “environmental and conservation factors
in mind,” Public Utilities Commission of California v. FERC,

 (D.C. Cir. 1990).

               B. FERC Complied with NEPA

     The Sierra Club challenges (1) FERC’s calculation of
downstream greenhouse gas emissions, (2) FERC’s discussion
of the no-action alternative, and (3) FERC’s decision not to
analyze the pipeline and power plant together as connected
actions.

                    1. Emissions Analysis

    The Sierra Club challenges FERC’s downstream
emissions analysis in three ways. One way or another, these
challenges overlook the “Deference” that is a “bedrock
principle of judicial review in NEPA cases.” See Seven
County, 145 S. Ct. at 1515.

     First, the Sierra Club says FERC incorrectly credited the
pipeline with enabling the emissions reduction from the gas-
for-coal swap. The Sierra Club believes that the TVA will
retire the coal-fired unit regardless of whether it builds the gas
turbine or FERC approves the pipeline project, so the
retirement of the coal-fired unit cannot be an effect of the
project.

     But the Sierra Club’s belief is unfounded. The TVA said
that absent a replacement generation source, it “would need to
continue operating the coal-fired units.” JA 417. And FERC
explained that the Cumberland pipeline was essential to the
anticipated gas-for-coal swap because it would “serve TVA’s
need for firm natural gas transportation capacity” to the new
gas plant. JA 79. So FERC did not err when it considered
                               9




both the retirement of the coal-powered unit and the emissions
from the new gas turbine as effects of the pipeline for its
downstream emissions analysis.

     Circuit precedent supports that decision. Cf. Citizens
Action Coalition of Indiana, 125 F.4th at 243 (finding no
Natural Gas Act violation from FERC’s decision to credit a
proposed gas pipeline with net emissions reductions associated
with the retirement of coal-fired units in favor of new gas
turbines). And economic logic compels it: If the TVA retires
its coal-fired unit without a replacement gas turbine or an
adequate gas supply, the TVA cannot adequately supply
electricity to its customers. See JA 365. We do not require
FERC to “blind itself to this practical reality.” Citizens Action
Coalition, 125 F.4th at 243.

     Second, the Sierra Club alternatively argues that “even if
FERC could lawfully credit the Project with some emissions
reductions associated with the retirement of the Cumberland
Fossil Plant, the record could not support emissions offsets
beyond 2035” — the latest year the coal-fired units will
operate. Pet’r Br. 30. Thus, the Sierra Club says that “FERC
ignored at least ten years of emissions from the Cumberland
Gas Plant — from 2036 through 2045 — that could not be
netted out.” Pet’r Br. 34.

    But again, the TVA’s plans to retire the coal-fired unit do
not exist in a vacuum. Without a replacement generation
source with requisite fuel, the TVA might instead upgrade and
operate the coal-fired unit well into the future, as the TVA’s
no-action alternative contemplated. So even though the TVA
hopes to replace its coal-fired units by 2035, FERC made the
reasonable choice to credit the pipeline with a net emissions
reduction covering the entire forecast period.

    Could FERC have taken a different approach? Perhaps.
But we must “defer to agencies’ decisions about where to draw
                              10




the line” in their analyses of “indirect environmental effects.”
Seven County, 145 S. Ct. at 1513.

     Third, the Sierra Club faults FERC for presenting
estimates of emissions on an annualized basis, rather than on a
cumulative basis. But it doesn’t matter which way FERC
presented the estimates. Anyone with a calculator — or the
ability to perform basic addition — can convert the annualized
estimates into a cumulative estimate, as the Sierra Club did in
its brief. See Pet’r Br. 35. FERC’s failure to do so itself did
not “frustrate[ ]” NEPA’s “goal of ensuring that relevant
information is available to those participating in agency
decision-making” and was therefore, at worst, “harmless
error.” Nevada v. Department of Energy, 

(D.C. Cir. 2006).

                  2. No-Action Alternative

     Recall that the TVA’s gas turbine will emit less
greenhouse gas than the coal-fired unit it will replace. And
recall that FERC decided to consider those net reductions as a
benefit of the pipeline project. The Sierra Club says that
decision is inconsistent with the analysis in FERC’s “no action
alternative,” in which FERC assumed that the natural-gas
turbine would replace the coal-fired unit even if the proposed
pipeline is not built. See Pet’r Br. 22-23; see 

(2)(C)(iii) (agencies must consider “a reasonable range
of alternatives to the proposed agency action, including . . . a
no action alternative”). The Sierra Club argues that the
project cannot be considered the cause of an emissions
reduction that would have occurred regardless of whether the
pipeline is built.

     We disagree with the Sierra Club. To start, its logic
would require us to hold that FERC should not have attributed
to the pipeline any of the plant-specific emissions from TVA’s
gas-for-coal swap — neither the emissions from the gas
                               11




turbine nor the credit from retiring the coal plant. But the
Sierra Club elsewhere asserts, to the contrary, that downstream
gas-plant emissions are caused by the pipeline. See Pet’r Br.
27-28; Reply Br. 10-11. That position essentially concedes
that there is no inconsistency between FERC’s analysis of the
no-action alternative and its attribution of downstream
emissions effects to the pipeline.

     It was also reasonable for FERC to assume that even if it
did not certify Tennessee Gas’s proposed pipeline — in which
case this pipeline would “not be constructed, the potential
impacts from the Proposed Action would not occur, and the
Project’s objectives would not be met,” JA 190 — another
pipeline could still be proposed, certified, and built. See JA
237. That other pipeline would allow the TVA to retire its
coal-fired units and replace a coal-fired unit with a gas turbine.

     So understood, there is no tension between the no-action
alternative and FERC’s judgment that the net emissions
reduction is an indirect effect of the pipeline. The two are
separate inquiries: the former establishes the baseline for
comparing “reasonable alternatives” to the project, 

(a), and the latter estimates the downstream effects
“caused by” the pipeline if FERC approves it, 

§ 1508.1(g)(2). Multiple alternatives can result in the same
outcome and still independently qualify as legal causes of that
outcome for purposes of the indirect-effects analysis. Said
otherwise, because FERC was predicting the effects of
mutually exclusive decisions, it was reasonable to attribute
emissions reductions to the proposed 32-mile pipeline
(Scenario 1) and also to conclude that if that pipeline were not
built (Scenario 2), a different pipeline would be constructed to
effectuate a gas-for-coal swap and thus cause the net reduction
in emissions. Our prior decisions have endorsed just such
logic. See Citizens Action Coalition, 125 F.4th at 243
(accepting as reasonable FERC’s consideration of both “gross”
and “net” downstream emissions).
                                   12




     Perhaps FERC’s no-action analysis could have been
clearer about its assumption that if the TVA decides to build its
gas turbine, some pipeline will be certified to supply it with
gas. But “a reviewing court must be at its most deferential”
when an agency makes “speculative assessments or predictive
or scientific judgments” about alternatives. Seven County,
145 S. Ct. at 1512 (emphasis added) (cleaned up). So we
cannot fault FERC for reasonably assuming that the gas turbine
will be built even if this particular pipeline is rejected.6

               3. Connected-Action Requirement

    The Sierra Club next argues that the pipeline and the
TVA’s power plant should have been analyzed together as
connected actions.

                       a. FERC Did Not Err

     Under regulations issued by the Council on Environmental
Quality and adopted by FERC, federal actions that “are closely
related . . . should be discussed in the same impact statement.”

6
  The Sierra Club points to one instance where FERC contradicted
its refrain that the gas plant will be built without this pipeline. Pet’r
Br. 24 (“if the Commission selects the no-action alternative, the
Cumberland Project facilities would not be constructed [and] the
potential impacts from TVA’s construction and operation of the
Cumberland Gas Plant would not occur” (quoting JA 62) (emphasis
omitted)). This cited language is a garbled paraphrase of a
statement in the environmental impact statement that, if FERC had
selected a no-action alternative, “the Cumberland Pipeline project
facilities would not be constructed,” JA 190, and so the potential
impacts of the proposed pipeline would not occur. None of that
undercuts FERC’s consistently made point that some pipeline would
be built and would cause net emissions reductions, and the Sierra
Club’s concern with FERC’s inartful phrasing amounts to
“flyspecking.” Minisink, 

.
                                  13

(e)(1) (July 1, 2023). 7 Regardless of
whether, in the past, this Court construed the CEQ regulations
often to require agencies to consider actions within another
agency’s regulatory jurisdiction, cf. Sierra Club v. FERC, 

 (D.C. Cir. 2017) (“Sabal Trail”) (“the
question is not ‘what activities does FERC regulate?’ but
instead ‘what factors can FERC consider when regulating?’”
(cleaned up)), Seven County held that an agency’s duty to
“consult with” other agencies cannot compel it “to speculate
about the effects of a separate project that is outside its
regulatory jurisdiction.” 145 S. Ct. at 1516 (first quoting 

(2)(C), then citing Department of Transportation
v. Public Citizen, 

 (2004)). Seven
County rested that conclusion on the text of NEPA itself, which
focuses the environmental impact statement on some specific
“proposed agency action,” 

(2)(C). See 145
S. Ct. at 1512, 1515. So, the same conclusion must also
inform our interpretation of CEQ regulations implementing the
statute, including the connected-actions regulation. In sum,
after Seven County, agencies are no longer “required to analyze
the effects of projects over which they do not exercise
regulatory authority.” Id. at 1516.

     The Sierra Club’s argument fails because it asks us to
demand exactly what Seven County says we cannot demand.
FERC lacks “jurisdiction . . . over facilities used for the
generation of electric energy” — like the TVA’s power plant.

(b)(1). So in NEPA parlance, the proposed
pipeline and the TVA’s power plant are not “connected
actions” that must be analyzed in the same environmental
impact statement. Cf. El Puente v. U.S. Army Corps of

7
  Although the Council on Environmental Quality regulations were
amended after FERC approved this pipeline, 

(May 1, 2024), and have since been rescinded, 

(Feb. 25, 2025), the parties agree that the regulations in effect at the
time of FERC’s decision control.
                              14




Engineers, 

 (D.C. Cir. 2024) (“the Corps
convincingly argues that it was not required to consider the
potential impact of LNG conversion, at least as a ‘connected
action,’ because the Corps has no regulatory authority over the
construction or operation of LNG terminals”); Alabama
Municipal Distributors Group v. FERC, 

(D.C. Cir. 2024) (FERC is not required to analyze the effects
of exported natural gas because exports fall within the
jurisdiction of the Department of Energy); Center for
Biological Diversity v. FERC (Alaska LNG), 

 (D.C. Cir. 2023) (same).

        b. Even Assuming Error, It Was Harmless

      Even if the connected-action requirement did apply, we
would not vacate FERC’s approval of the pipeline “absent
reason to believe that the agency might disapprove the project
if it” had analyzed the pipeline and the TVA’s power plant as
connected actions (as the Sierra Club demands) rather than as
projects with cumulative effects (as FERC did). Seven
County, 145 S. Ct. at 1514; see JA 93-96; see also 

 (“due account shall be taken of the rule of prejudicial
error”). The Sierra Club has not identified any additional
information it seeks that is not already provided in FERC’s
environmental impact statement. So another environmental
impact statement “would serve no purpose.” Public Citizen,

 (cleaned up); see also Oglala Sioux Tribe v.
Nuclear Regulatory Commission, 

 (D.C. Cir.
2022) (courts should uphold agency action “in the NEPA
context when the agency has undertaken the required analysis
but failed to comply precisely with NEPA procedures”
(cleaned up)). The claimed error is particularly immaterial
here, where TVA itself — the agency with exclusive
jurisdiction over the choice of power generation — did
consider the power plant and pipeline as connected actions and
analyzed them both in its own environmental impact statement,
see JA 366, 379-80; see also 

(e)(1) (July 1,
                              15




2023), which FERC in turn referenced as part of its
environmental analysis, see, e.g., JA 173-74, 185.

    The Sierra Club also argues that if FERC and the TVA had
conducted a joint environmental impact statement, FERC
could have avoided its initial confusion as to the number of
coal-fired units the gas turbine would replace. Maybe so.
But that error was harmless because FERC corrected it in the
rehearing order.

    Finally, the Sierra Club contends that by combining the
two environmental impact statements, FERC might have
avoided the alleged errors related to its no-action analysis.
But as already discussed, that analysis was reasonable.

       C. FERC Complied with the Natural Gas Act

     FERC complied with the Natural Gas Act when it
analyzed the market need for the pipeline and the public
interest.

                  1. Market Need Analysis

     Before certifying a pipeline, FERC must confirm a market
need by evaluating “whether the project can proceed without
subsidies from the existing pipeline’s customers.” Minisink,

 (cleaned up). Here, FERC determined that
there was a market need for the project because the TVA
entered into a 20-year precedent agreement with Tennessee
Gas to purchase 100% of the pipeline’s capacity.8

     As a general rule, FERC may find market need by relying
solely on a precedent agreement. Minisink, 

8
  “A precedent agreement is a long-term contract subscribing to
expanded natural gas capacity.” Myersville Citizens for a Rural
Community, Inc. v. FERC, 

 (D.C. Cir. 2015).
                              16




n.10. There is an exception to that rule when an agreement
involves affiliated entities and there is “plausible evidence of
self-dealing.” Environmental Defense Fund v. FERC, 

 (D.C. Cir. 2021). But the TVA and Tennessee Gas
are not affiliated, and the Sierra Club has not alleged self-
dealing. So that exception does not apply.

     Instead, the Sierra Club argues that FERC should have
more thoroughly scrutinized the market need because the TVA
is an “unregulated utility” that is “not subject to routine
oversight from a utility regulator like a state commission.”
Pet’r Br. 48, 50.

     We disagree. Though the TVA is not subject to state
supervision, it is hardly a rogue entity. The TVA must follow
a statutorily prescribed “least-cost planning” framework in
making investment decisions; it is subject to congressional
oversight and must annually notify Congress of any “major
new energy resource”; and its investment decisions are subject
to public notice and comment. 16 U.S.C. § 831m-1(a), (d).

     We also reject the Sierra Club’s argument that FERC
ignored evidence about green-energy subsidies available under
the Inflation Reduction Act. Once again, absent self-dealing,
FERC was entitled to rely on the precedent agreement without
considering additional evidence. And even if there had been
a need for FERC to look beyond the precedent agreement,
FERC had no obligation to consider information about the
TVA’s choice of natural gas over a renewable alternative. See

(b)(1) (FERC “shall not have jurisdiction . . .
over facilities used for the generation of electric energy”). As
FERC explained, FERC’s role is limited to reviewing whether
this pipeline is in the public interest, and FERC does not have
veto power over the TVA’s natural-gas turbine.
                             17




                2. Public Interest Balancing

     Finally, the Sierra Club argues that FERC improperly
weighed the pipeline’s benefits and harms because it
misunderstood the pipeline’s environmental impacts and failed
to consider whether non-gas generation methods might result
in lower costs for energy consumers. This argument simply
repeats objections that we have already considered and
rejected. FERC’s environmental assessment was adequate.
And while FERC’s power under § 7 of the Natural Gas Act
permits it “to look into matters excluded from [its] direct
regulatory jurisdiction,” it may not purport[ ] to regulate”
matters outside that jurisdiction. Office of Consumers’
Counsel v. FERC, 

, 1146 n.31, 1147-48 (D.C.
Cir. 1980); see Federal Power Commission v.
Transcontinental Gas Pipe Line Corp., 

(1961). FERC generally has no jurisdiction “over facilities
used for the generation of electric energy.” 

(b)(1). The agency thus reasonably declined to leverage
its § 7 power to reconsider the TVA’s gas-for-coal decision.

                      III. Conclusion

     NEPA requires federal agencies to prepare environmental
impact statements for “major Federal actions significantly
affecting the quality of the human environment.” 

(2)(C). In the past ten years, FERC has issued final
environmental impact statements for approximately 60 natural-
gas transportation projects. Some of those environmental
impact statements were thousands of pages long. See, e.g.,
Alaska LNG Project, Final Environmental Impact Statement,
No. CP17-178 (Mar. 6, 2020) (5,078-page final EIS for
natural-gas export infrastructure).

    At oral argument, we asked the Sierra Club if any of those
environmental impact statements were legally adequate. It
could not identify one. Cf. Appalachian Voices v. FERC, 139
                                 

, 916 (D.C. Cir. 2025) (denying the Sierra Club’s
petition); Healthy Gulf v. FERC, 

 (D.C. Cir.
2025) (same); Center for Biological Diversity v. FERC, 

 (D.C. Cir. 2023) (same); Sierra Club v.
FERC, 

 (D.C. Cir. 2022) (same); Sierra Club
v. FERC, 

 (D.C. Cir. 2016) (same).

     The Sierra Club is entitled to the expansive view of NEPA
that its answer reflects, and it is free to argue for robust judicial
scrutiny of environmental impact statements. But the Sierra
Club’s understanding of NEPA is not shared by the Supreme
Court. This year, in Seven County Infrastructure Coalition v.
Eagle County, Colorado, the Supreme Court repudiated NEPA
arguments like those raised by the Sierra Club in this case.
See, e.g., 

, 1513 (2025).

     After Seven County was decided, the Sierra Club informed
this court that though “it may apply in other cases, Seven
County has little utility here.” Sierra Club Rule 28(j) Letter at
1 (June 6, 2025). That is incorrect. The Sierra Club’s
briefing depended on circuit precedent abrogated by Seven
County, including this court’s decision in Sabal Trail, which
the Sierra Club cited on pages 19, 26, 27, 29, 36, and 46 of its
opening brief. Compare Seven County, 145 S. Ct. at 1516
(“agencies are not required to analyze the effects of projects
over which they do not exercise regulatory authority”), with
Sierra Club v. FERC (Sabal Trail), 

 (D.C.
Cir. 2017) (requiring FERC to consider “power-plant carbon
emissions that the pipelines will make possible” even though
FERC lacks regulatory jurisdiction over power generation
facilities).

    After Seven County, the era of searching NEPA review is
over — or at least it should be.
                            19




                      *      *      *

    Because FERC reasonably discharged its NEPA and
Natural Gas Act duties, we deny the Sierra Club’s petitions.

                                                So ordered.