13
of promoting market competition, and (iv) any other factors bearing on
the public interest
described herein.
IV.
DESCRIPTION OF REQUEST
Delfin requests long-term, multi-contract authorization to export domestically produced
LNG, on its own behalf and as agent for other entities that will hold title to the LNG, by vessel
from the proposed Liquefaction Facility to non-FTA countries. Delfin seeks to export LNG in a
volume equivalent to 657.5 Bcf/yr of natural gas (1.8 Bcf/d) over a 20-year term, beginning on
the date of first export of each train or seven years from the date of issuance of the requested
authorization, whichever is sooner.
Specifically, Delfin requests that, in light of the “planned phased development” of its
Facility—with successive trains expected to become operational from 2017 through 2021—
DOE/FE construe the “date of first export” on a train-specific basis.
41
Under this approach,
exports from
the first train, if placed in operation in 2017, would extend for 20 years from that
first export. However, if the third train were placed in operation in 2020, exports from the third
train would be authorized for 20 years from the start of
that train’s export operations (rather than
only 17 years, if based on the date of first export from the first train). Delfin acknowledges that
this phased approach has not been previously adopted by DOE/FE but asserts that it will
facilitate the orderly development of its Facility and its customer contracting.
42
41
Delfin App. at 9.
42
See id.
14
A.
Description of Applicant
Delfin is a Louisiana limited liability company with its principal
place of business in
Dallas, Texas. Delfin states that it is a wholly-owned subsidiary of Fairwood Peninsula Energy
LLC (Fairwood Peninsula).
According to Delfin, Fairwood Peninsula is a Delaware limited liability company formed
by executives from both the Fairwood Group (based in India and Singapore) and the Peninsula
Group (based in the United States). Delfin describes the corporate structure as follows:
•
Fairwood Peninsula is owned by FWNR Energy Holdings (USA) Corporation
(Fairwood USA) and the Peninsula Group.
•
Fairwood USA is a Delaware corporation and a subsidiary of Fairwood Welbeck
Natural Resources Pte. Ltd. (FWNRL).
•
FWNRL is part of the Fairwood Group, an India-based group of companies with
investments in energy,
transportation, and urbanization. FWNRL is a company
organized and existing under the laws of Singapore, with its principal place of
business in Singapore.
•
The Peninsula Group is a privately owned, Texas-based group of companies with
interests in
land development, construction projects, and oil and gas.
Delfin states that principals of FWNRL and the Peninsula Group have been working on the
development of Delfin’s Liquefaction Facility for several years.
43
B.
Proposed Liquefaction Facility
Delfin proposes to develop, own, and operate its floating Liquefaction Facility in West
Cameron Block 167
in the Gulf of Mexico, approximately 30 miles offshore of Cameron Parish,
Louisiana. Delfin states that Liquefaction Facility will utilize four floating LNG vessels
(FLNGVs) for the planned liquefaction and storage. According to Delfin, the FLNGVs will be
moored at purpose-built single point moorings located as near the terminus of the existing
43
See id. at 2-3.
15
pipeline in West Cameron Block 167 as operationally and safely as possible (expected to be
within approximately 2000 feet). The FLNGVs will have the capability to export LNG to off-
taking LNG carriers utilizing a ship-to-ship, side transfer process.
44
Delfin states that the platform is the terminus and metering point
of the existing Enbridge
Offshore Pipelines (UTOS) natural gas pipeline system, and is connected to the shore via an
existing 42-inch diameter, 30-mile long gas pipeline. Delfin states that the pipeline system
commenced operation in 1978 and previously was utilized for the purpose of transporting
offshore natural gas production to onshore connections with Transcontinental Gas Pipe Line,
Natural Gas Pipeline Company of America, and ANR Pipeline Company, as well as to nearby
gas processing plants.
Delfin asserts that, because of significantly decreased flow volumes, the
UTOS gas pipeline could no longer be economically operated for its original purpose. As a
result, in 2011, FERC authorized the pipeline to abandon its services and certificates, while
deferring the final disposition of its facilities.
45
Delfin maintains that the system has been idle
since that time.
Delfin states that its parent company, FWNRL, has entered into a letter of intent with the
owner of the UTOS pipeline system that provides FWNRL the exclusive
right to acquire the
pipeline system, subject to the satisfaction of certain conditions including regulatory approvals.
46
Delfin intends to recommission and to reverse the flow on the existing 42-inch pipeline for
purposes of delivering feed gas to the Liquefaction Facility. According to Delfin, the existing
pipeline is anticipated to have capacity to transport up to 1.8 Bcf/d of natural gas from the
Louisiana coastline to Delfin’s proposed Liquefaction Facility. Delfin states that, following the
44
A site plan for the mooring system and other site depictions are attached to the Application as Appendix D.
45
See Delfin App. at 5 (citing
Enbridge Offshore Pipelines (UTOS) LLC, 136 FERC ¶ 62,269 (2011)).
46
See id.