The U.S. Maritime Administration (MARAD) released the Final Environmental Impact Statement (FEIS) for the ST LNG Deepwater Port project on July 23, 2026, scheduled for Federal Register publication on July 24, 2026. The proposed terminal would be located approximately 10.4 nautical miles offshore Matagorda, Texas, in federal waters, and would export up to 8.4 million tonnes of LNG annually to both free-trade-agreement (FTA) and non-FTA countries.

The FEIS is a major federal permitting milestone — it completes the environmental review required under the National Environmental Policy Act (NEPA) and the Deepwater Port Act, and will support MARAD's decision to approve, conditionally approve, or reject the deepwater-port licence. A final public hearing will be announced separately. The FEIS does not itself authorize construction or operation.

Offshore LNG export terminals in U.S. federal waters are licensed under the Deepwater Port Act of 1974, administered by MARAD in coordination with the U.S. Coast Guard. The licensing process requires:

1. NEPA environmental review — completed by the FEIS
2. Coastal Zone Management Act consistency determination — coordination with Texas state agencies
3. MARAD licensing decision — approve, conditionally approve, or deny
4. Department of Energy export authorization — separate DOE authorization required for exports to non-FTA countries; FTA-country exports are authorized by statute

The FEIS completion means the project has cleared the most time-consuming element of the federal permitting process. The remaining steps — MARAD's licensing decision and any DOE non-FTA export authorization — are typically faster once the FEIS is finalized, though both remain subject to regulatory discretion and potential legal challenge.

• Location: Approximately 10.4 nautical miles offshore Matagorda, Texas, in the Gulf of Mexico
• Export capacity: Up to 8.4 million tonnes per annum (MTPA) of LNG
• Export markets: Both FTA and non-FTA countries
• Structure: Deepwater port — a floating or fixed offshore facility in federal waters, distinct from onshore LNG export terminals licensed under the Natural Gas Act

The 8.4 MTPA capacity positions ST LNG as a mid-scale terminal relative to the largest U.S. LNG export projects (Sabine Pass, Freeport, Corpus Christi), which operate at 15–22 MTPA. The offshore deepwater-port structure avoids certain onshore siting constraints and may offer advantages in marine logistics and vessel access.

The FEIS completion is a critical milestone for project-finance lenders evaluating the ST LNG project. Key considerations include:

• Permitting risk. The FEIS completion substantially reduces NEPA-related permitting risk, but the MARAD licensing decision and DOE non-FTA export authorization remain outstanding. Financing documents should address the conditions and timeline for these remaining approvals, and should include regulatory-delay and change-in-law provisions.
• Licence conditions. MARAD licences typically include environmental mitigation conditions, operational requirements, and financial assurance obligations. Lenders should review the licence conditions carefully once issued, as they may affect project costs, operational flexibility, and compliance obligations.
• Final investment decision contingencies. Project-finance structures for LNG terminals typically require a minimum volume of contracted offtake before the FID is taken. The FEIS completion may accelerate offtake negotiations by reducing permitting uncertainty.

Foreign LNG buyers — including Turkish energy companies and state-owned utilities — considering offtake agreements with ST LNG should note:

• Non-FTA export authorization. Turkey is not a U.S. FTA partner, meaning LNG exports to Turkey require a separate DOE non-FTA export authorization. The FEIS completion does not resolve this requirement. Offtake agreements should include conditions precedent tied to DOE authorization and should address the risk of authorization delay or denial.
• Offtake contract structure. Long-term LNG offtake agreements typically involve free-on-board (FOB) or delivered ex-ship (DES) pricing, take-or-pay obligations, destination flexibility, and force majeure provisions. The offshore deepwater-port structure may affect vessel specifications and marine logistics terms.
• Regulatory delay risk. Offtake agreements should include provisions addressing the risk that the MARAD licence or DOE authorization is delayed, conditioned, or denied — including termination rights, deposit return mechanisms, and liability allocation.

Engineering, procurement, and construction contractors and marine service providers evaluating the ST LNG project should note:

• Construction authorization. The FEIS does not authorize construction. EPC contracts should include conditions precedent tied to MARAD licence issuance and, where relevant, DOE authorization.
• Licence conditions and construction interfaces. MARAD licence conditions may impose specific construction requirements, environmental monitoring obligations, and operational restrictions that affect EPC scope, schedule, and cost. These conditions should be reviewed and allocated in EPC contracts once the licence is issued.
• Marine construction in federal waters. Offshore construction in U.S. federal waters is subject to U.S. Coast Guard oversight, Jones Act requirements for certain vessel operations, and MARAD coordination. Turkish marine contractors and vessel operators should assess Jones Act compliance requirements before bidding on offshore construction work.

LNG traders evaluating the ST LNG project as a supply source should note:

• Export authorization timing. Non-FTA export authorization from DOE is required before LNG can be exported to non-FTA markets. Traders should track the DOE authorization timeline and structure trading agreements accordingly.
• Destination flexibility. U.S. LNG export authorizations typically permit exports to any country not subject to U.S. sanctions, subject to the FTA/non-FTA distinction. Traders should confirm destination flexibility in both the DOE authorization and the underlying offtake agreement.

Turkey is a significant LNG importer, and Turkish state-owned and private energy companies have been active in securing long-term LNG supply agreements with U.S. export terminals. The ST LNG FEIS completion is relevant for Turkish companies in several respects:

Offtake opportunities. The FEIS completion may accelerate ST LNG's commercial development, creating potential offtake opportunities for Turkish buyers. Turkish companies should monitor the MARAD licensing decision and DOE authorization timeline and engage with the developer on offtake terms.

Non-FTA authorization. Any offtake agreement between ST LNG and a Turkish buyer will require DOE non-FTA export authorization. Turkish companies should factor the authorization timeline and conditions into their supply planning.

Project investment. Turkish energy companies or sovereign wealth vehicles considering equity investment in U.S. LNG export infrastructure should assess CFIUS review requirements, as investments in U.S. energy infrastructure by foreign government-affiliated entities may be subject to CFIUS jurisdiction.

ULF New York advises Turkish companies and investors on U.S. energy regulatory matters, LNG offtake agreements, project finance, and cross-border energy transactions.