153
(aided by conservation and efficiency measures), increased generation from other resources
(such as coal, renewables, and nuclear), and more efficient use of natural gas (
i.e.,
shifting of
generation to natural gas-fired generators with superior heat rates).
Although EIA’s 2012 Study found that additional natural gas production would supply
most of the natural gas needed to support added LNG exports, EIA modeled the effects of higher
natural gas prices on energy consumption in the United States in the years 2015 through 2035,
and found several additional results. In particular, EIA found that “under Reference case
conditions, decreased natural gas consumption as a result of added exports are countered
proportionately by increased coal consumption (72 percent), increased
liquid fuel consumption
(8 percent), other increased consumption, such as from renewable generation sources (9 percent),
and decreases in total consumption (11 percent).”
353
Further, EIA determined that, in the earlier
years of the 2015 to 2035 period, “the amount of natural gas to coal switching is greater,” with
“coal play[ing] a more dominant role in replacing the decreased levels of natural gas
consumption, which also tend to be greater in the earlier years.”
354
Likewise, “[s]witching from
natural gas to coal is less significant in later years, partially as a result of a greater proportion of
switching into renewable generation.”
355
EIA ultimately projected that, for LNG export
levels
from 6 to 12 Bcf/d of natural gas and under Reference case conditions, aggregate carbon
dioxide
emissions would increase above a base case with no exports by between 643 and 1,227 million
metric tons (0.5 to 1.0 percent) over the period from 2015 to 2035.
356
It is worth noting,
however, that a substantial portion of these projected emissions came from consumption of
natural gas in the liquefaction process, rather than from increased use of coal. The liquefaction
353
2012 EIA Study at 18.
354
Id.
355
Id.
356
Id. at 19.
154
of natural gas is captured in the LCA GHG Report’s estimate of the life cycle GHG emissions of
U.S.-exported LNG, discussed above.
We further note that EIA’s 2014 Study assumed the regulations in
effect at the time the
AEO 2014 was prepared.
357
Therefore, EIA’s analysis included the impacts that EPA’s Mercury
and Air Toxics Standard
358
but not EPA’s Transport Rule
359
as it had been vacated at the time.
EIA’s analysis in 2014 also captured the Clean Air Interstate Rule, which sets limits on regional
sulfur dioxide and mono-nitrogen oxides (SO
2
and NO
x).
There are, however, other rules that
were not final at the time of AEO 2014, including two then-proposed rules from EPA to reduce
the extent to which the increased use of coal would compensate for reduced use of natural gas.
These rules, finalized in the fall of 2015, impose limits on GHG emissions from both new and
existing coal-fired power plants.
360
In particular, these rules have the potential
to mitigate
significantly any increased emissions from the U.S. electric power sector that would otherwise
result from increased use of coal, and perhaps to negate those increased emissions entirely.
The AEO 2017 incorporated the Clean Power Plan (CPP) final rule in the Reference case
and assumes that all states choose to meet a mass-based standard to cover both existing and new
sources of carbon dioxide emissions. In the AEO 2017 Reference case—which includes 12.1
Bcf/d of LNG exports from the United States in 2040—electric
power sector carbon dioxide
357
See supra § VII.B.
358
U.S. Envtl. Prot. Agency, National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired
Electric Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility,
Industrial-Commercial- Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units; Final
Rule, 77 Fed. Reg. 9,304 (Feb. 16, 2012).
359
U.S. Envtl. Prot. Agency, Federal Implementation Plans: Interstate Transport of Fine Particulate Matter and
Ozone and Correction of SIP Approvals; Final Rule, 76 Fed. Reg. 48,208 (Aug. 8, 2011).
360
U.S. Envtl. Protection Agency, Standards of Performance for Greenhouse Gas Emissions from New, Modified,
and Reconstructed Stationary Sources: Electric Utility Generating Units; Final Rule, 80 Fed. Reg. 64,510 (Oct. 23,
2015); U.S. Envtl. Protection Agency, Carbon Pollution Emission Guidelines for Existing Stationary Sources:
Electric Utility Generating Units; Final Rule, 80 Fed. Reg. 64,662 (Oct. 23, 2015) (effective Dec. 22, 2015). As
noted above, the U.S. Supreme Court has issued a stay of the effectiveness of this rule
pending review,
see supra
note 188.
155
emissions are projected to be 37 percent below 2005 levels in 2040, decreasing from 2,416
million metric tons of carbon dioxide (MMmt CO2) in 2005 to 1,531 in 2040, due to the
implementation of the CPP as well as decreasing use of coal-fired generation. Natural gas
generation increases by 33 percent in the Reference case from 2015 to 2040, and coal generation
declines by 31 percent from 2015 to 2040.
In the AEO 2017 Reference case that did not incorporate the Clean Power Plan, LNG
exports from the United States are 12.7 Bcf/d in 2040 and electric power sector carbon dioxide
emissions are projected to be 20 percent below 2005 levels in 2040, decreasing in this case from
2,413 MMmt CO2 in 2005 to 1,941 in 2040, which is primarily attributable to increased use of
natural gas generation that still occurs without the CPP. Also in the 2017 AEO Reference Case
without the CPP, natural gas generation still rises from 2015 to 2040, but to a lesser degree, with
a 33 percent increase with the CPP and a 22 percent increase without it.
Coal generation
increases 3 percent from 2015 to 2040 without the CPP.
Therefore, on the record before us, we cannot conclude that exports of natural gas would
be likely to cause a significant increase in U.S. GHG emissions through their effect on natural
gas prices and the use of coal for electric generation.
b.
International Impacts Associated with Energy Consumption in
Foreign Nations
The LCA GHG Report estimated the life cycle GHG emissions of U.S. LNG exports to
Europe and Asia, compared with certain other fuels used to produce electric power in those
importing countries. The key findings for U.S. LNG exports to Europe and Asia are summarized
in Figures 3 and 4 below, which are also presented above in Section IX.A (Figures 1 and 2):