49
because DOE/FE has the authority and duty to consider environmental impacts in its public
interest analysis.
Next, Sierra Club rejects Delfin’s argument that projected demands from its proposed
exports are not “sufficiently foreseeable.” Sierra Club asserts that Delfin does not acknowledge
that EIA’s NEMS model, among other tools, can predict where natural gas production will
increase in response to Delfin’s natural gas demand. Sierra Club further contends that DOE/FE
must quantify the increase in greenhouse gas (GHG) emissions that would result from the
proposed Liquefaction Facility, including emissions from natural gas production induced from
Delfin’s exports.
166
Finally, Sierra Club reiterates its arguments that the 2012 LNG Export Study understates
the likely economic impacts of LNG exports, including domestic price impacts to natural gas.
For these reasons, Sierra Club contends that DOE/FE cannot reach a public interest
determination, or take any action, without a NEPA analysis that considers induced natural gas
production associated with this Project.
VII.
DOE/FE’S LNG EXPORT STUDIES
A.
2012 LNG Export Study
On May 20, 2011, DOE/FE issued Order No. 2961, DOE/FE’s first order conditionally
granting a long-term authorization to export LNG produced in the lower-48 states to non-FTA
countries.
167
By August 2011, with several other non-FTA export applications then pending
before it, DOE/FE determined that further study of the economic impacts of LNG exports was
166
See id. at 5.
167
Sabine Pass Liquefaction, LLC, DOE/FE Order No. 2961, FE Docket No. 10-111-LNG, Opinion and Order
Conditionally Granting Long-Term Authorization to Export Liquefied Natural Gas From Sabine Pass LNG Terminal
to Non-Free Trade Agreement Nations (May 20, 2011).
50
warranted to better inform its public interest review under section 3 of the NGA.
168
Accordingly, DOE/FE engaged EIA and NERA Economic Consulting to conduct a two-part
study of the economic impacts of LNG exports.
169
First, in August 2011, DOE/FE requested that EIA assess how prescribed levels of
natural gas exports above baseline cases could affect domestic energy markets. Using its
National Energy Modeling System (NEMS), EIA examined the impact of two DOE/FE-
prescribed levels of assumed LNG exports—equivalent to 6 Bcf/d and 12 Bcf/d of natural gas—
under numerous scenarios and cases based on projections from EIA’s 2011 Annual Energy
Outlook (AEO 2011), the most recent EIA projections available at that time.
170
The new
scenarios and cases examined by EIA included a variety of supply, demand, and price outlooks.
EIA published its study, Effect of Increased Natural Gas Exports on Domestic Energy Markets,
in January 2012.
171
EIA generally found that LNG exports will lead to higher domestic natural
gas prices, increased domestic natural gas production, reduced domestic natural gas
consumption, and increased natural gas imports from Canada via pipeline.
Second, DOE contracted with NERA to assess the potential macroeconomic impact of
LNG exports by incorporating EIA’s then-forthcoming case study output from the NEMS model
into NERA’s general equilibrium model of the U.S. economy. NERA analyzed the potential
macroeconomic impacts of LNG exports under a range of global natural gas supply and demand
scenarios, including scenarios with unlimited LNG exports. DOE published the NERA Study,
168
DOE/FE stated in Sabine Pass that it “will evaluate the cumulative impact of the [Sabine Pass] authorization and
any future authorizations for export authority when considering any subsequent application for such authority.” Id.
at 33.
169
See 2012 LNG Export Study, 77 Fed. Reg. 73,627 (Dec. 11, 2012), available at:
http://energy.gov/sites/prod/files/2013/04/f0/fr_notice_two_part_study.pdf (Notice of Availability of the LNG
Export Study).
170
The Annual Energy Outlook (AEO) presents long-term projections of energy supply, demand, and prices. It is
based on results from EIA’s NEMS model.
171
See LNG Export Study – Related Documents, available at: http://energy.gov/fe/downloads/lng-export-study-
related-documents (EIA Analysis (Study - Part 1)).
51
Macroeconomic Impacts of LNG Exports from the United States, in December 2012 (NERA
Study). Among its key findings, NERA projected that the United States would gain net
economic benefits from allowing LNG exports. For every market scenario examined, net
economic benefits increased as the level of LNG exports increased.
In December 2012, DOE/FE published a Notice of Availability (NOA) of the EIA and
NERA studies (collectively, the 2012 LNG Export Study or Study).
172
DOE/FE invited public
comment on the Study, and stated that its disposition of the then-pending non-FTA LNG export
applications would be informed by the Study and the comments received in response thereto.
173
DOE/FE received over 188,000 initial comments and over 2,700 reply comments, of which
approximately 800 were unique.
174
The comments were posted on the DOE/FE website and
entered into the public records of the 15 LNG export proceedings identified in the NOA.
175
DOE/FE responded to those public comments in connection with the LNG export proceedings
identified in the NOA.
176
B.
2014 EIA LNG Export Study, Effect of Increased Levels of Liquefied Natural
Gas Exports on U.S. Energy Markets
1.
Methodology
DOE/FE asked EIA to evaluate the impact of increased natural gas demand, reflecting
possible exports of U.S. natural gas, on domestic energy markets using the modeling analysis
presented in AEO 2014 as a starting point. DOE/FE requested an assessment of how specified
172
77 Fed. Reg. at 73,627.
173
Id. at 73,628.
174
Because many comments were nearly identical form letters, DOE/FE organized the initial comments into 399
docket entries, and the reply comments into 375 entries. See
http://www.fossil.energy.gov/programs/gasregulation/authorizations/export_study/export_study_initial_comments.h
tml (Initial Comments – LNG Export Study) &
http://www.fossil.energy.gov/programs/gasregulation/authorizations/export_study/export_study_reply_comments.ht
ml (Reply Comments – LNG Export Study).
175
See 77 Fed. Reg. at 73,629 & n.4.
176
See, e.g., Sabine Pass Liquefaction, LLC, DOE/FE Order No. 3792, at 66-121 (Mar. 11, 2016).
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