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exports, the proposed exports will likely have a negative impact on the U.S. economy by
increasing the price of natural gas and eliminating jobs in energy intensive industries.
APGA, V4EI, and Sierra Club further maintain that exports of LNG have the potential to
drastically affect total U.S. natural gas supply. Accordingly, these intervenors contend that the
proposed exports, and U.S. LNG exports generally, will result in significantly higher natural gas
prices domestically than projected by Delfin. Sierra Club also challenges the sustainability of
economic benefits in regions tied to resource extraction industries, as discussed below.
On review, DOE/FE finds that the evidence of record showing that the proposed exports
would be in the public interest outweighs the concerns expressed by the intervenors. DOE has
considered and rejected each of the arguments raised by the intervenors that bear on the validity
of the 2012 NERA Study in this Order or in prior orders.
321
In regards to those arguments, the
intervenors have adduced no additional substantive support for their views in this proceeding.
EIA’s projections in AEO 2017 provide independent support for the proposition that
domestic supplies will be adequate both to meet domestic needs and to supply Delfin’s exports
and other final non-FTA LNG exports previously authorized by DOE/FE. See supra § VIII.A.
Further, Delfin asserts—and MARAD concluded in its ROD—that the proposed exports will
benefit the local economy in and around Cameron Parish, Louisiana; Louisiana’s state economy;
the Gulf Coast regional economy; and/or the greater national economy. These conclusions are
bolstered by the 2014 and 2015 LNG Export Studies. Accordingly, we find that the evidence
shows that the market will be capable of sustaining the level of exports proposed in the
Application over the term of the requested authorization without significant negative price or
321
See, e.g., Sabine Pass Liquefaction, LLC, DOE/FE Order No. 3669, FE Docket Nos. 13-30-LNG, 13-42-LNG, &
13-121-LNG, Final Opinion and Order Granting Long-Term, Multi-Contract Authorization to Export Liquefied
Natural Gas by Vessel from the Sabine Pass LNG Terminal Located in Cameron Parish, Louisiana, to Non-Free
Trade Agreement Nations, at 94-158, 190 (June 26, 2015).
139
other impacts. For these reasons, as further discussed below, we find that none of the intervenors
have overcome the statutory presumption that the requested exports are consistent with the
public interest.
2.
Regional Impacts
Delfin asserts that the proposed exports will stimulate local, regional, and national
economies through direct and indirect job creation, increased economic activity, and tax
revenues. The opponents of the Application attempt to counter these claims.
APGA and V4EI contend that the NERA Study, conducted as part of the 2012 LNG
Export Study, concludes that price increases resulting from LNG exports will hurt consumers of
natural gas and electricity. APGA is also concerned that exports of LNG will undercut a
manufacturing renaissance in the United States and, in particular, will disadvantage the
petrochemical industry for which natural gas is a significant cost component. APGA maintains
that the United States should pursue policies that allow industry to invest in manufacturing
industries rather than LNG export facilities because manufacturing provides a value-added
benefit to the economy that multiplies the value of every dollar spent on natural gas.
Sierra Club makes several of the same arguments raised by APGA—specifically, it
asserts that Delfin “ignores economic harm exports will cause and disregards the economic effect
of environmental impacts.”
322
Sierra Club also challenges the sustainability of economic
benefits in regions tied to resource extraction industries, focusing principally on the durability of
economic benefits in natural gas producing regions where drilling is occurring. In particular,
Sierra Club contends that DOE/FE must consider a full range of counterfactual scenarios by
evaluating whether the nation would be better off without LNG exports, or with lower export
322
Sierra Club. Mot. at 1.
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volumes. Sierra Club asserts that any “boom” in economic activity will be followed by a bust,
and that the prospect of such an event demonstrates that a grant of the requested authorization is
inconsistent with the public interest.
323
We note that certain commenters on the 2014 and 2015 LNG Export Studies make
several of the same arguments raised by these intervenors. In particular, these commenters
contend that DOE/FE must consider a full range of counterfactual scenarios, and they likewise
challenge claimed regional economic benefits and assert that any “boom” in economic activity
will result in a “bust” to the detriment of the public interest.
On review, we do not agree with APGA, V4EI, or Sierra Club that Delfin’s proposed
exports will not yield net economic benefits or that the proposed exports will produce deleterious
economic and societal impacts. The 2014 and 2015 LNG Export Studies, as well as EIA’s
supply data and projections in AEO 2017, show that the proposed exports are likely to generate
net economic benefits for the United States. Further, we note that, in responding to the Notice of
Application, none of the intervenors offered detailed analyses specific to the local and regional
economic impacts of Delfin’s proposal to contradict this evidence.
To the extent that Sierra Club, APGA, or other commenters are claiming that the exports
proposed by Delfin will physically exhaust existing resources ( i.e., resulting in a “bust”), we
refer to the section above in which we conclude that record evidence indicates that there will be
substantial supply into the foreseeable future. To the extent they allege that “bust” cycles will be
brought on by price declines that render existing natural gas resources uneconomic to produce,
we do not see compelling evidence that the exports will exacerbate this risk. If anything, we
agree with Delfin that it seems more likely that Delfin’s ability to export to non-FTA countries
323
See id. at 65.
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