28
consider the many federal and state policies, market trends, and current regional shortages that
indicate higher natural gas demand in the United States. V4EI states that demand for natural gas
will increase as more intermittent renewable energy generation is brought online and as coal-
fired power generation declines. V4EI also argues there will be increased demand for natural gas
in the transportation and manufacturing sectors.
100
V4EI states that stable domestic energy prices in the United States are dependent on the
security and stability of domestic natural gas supply. V4EI argues that DOE/FE must assess the
linkage between the natural gas and power markets to gauge domestic gas demand accurately as
a basis for its public interest review, and that ignoring this linkage runs contrary to the NGA’s
consumer protection mandate. Citing the wholesale electricity pricing of the PJM Regional
Transmission Organization during the extremely cold winter of 2013-2014, V4EI argues that real
world conditions—including insufficient regional natural gas transportation infrastructure—
increase the threat of a “natural gas demand driven run up” in electricity prices.
101
V4EI
maintains that the 2012 LNG Export Study ignored regional natural gas infrastructure
limitations, and in turn underestimated actual seasonal and regional domestic natural gas
demand. V4EI contends that, by granting long-term LNG export authorizations, DOE/FE is
supporting the construction of export infrastructure over the expansion of domestic natural gas
infrastructure, at the risk of critical domestic demand.
102
Finally, V4EI argues that neither Delfin nor DOE/FE have substantively addressed the
trade, national security, and foreign policy aspects of the public interest analysis contemplated in
the 1984 Guidelines. V4EI specifically contends that Delfin has provided no evidence that
100
See id. at 24-26.
101
Id. at 28.
102
See id. 28-31.
29
DOE/FE’s approval of its Application will provide U.S. allies with natural gas, counteract
concentration within the global natural gas markets, or advance national security interests. In
sum, V4EI contends that Delfin’s Application is devoid of substantial evidence on many relevant
factors considered by DOE/FE in its public interest determination under the NGA.
103
D.
APGA’s Motion to Intervene and Protest
APGA filed a Motion for Leave to Intervene and Protest on May 27, 2014. APGA is a
national non-profit association of publicly-owned natural gas distribution systems, with
approximately 700 members in 36 states. APGA states that its membership covers 950 not-for-
profit retail distribution entities that are owned by, and accountable to, the citizens they serve,
including municipal gas distribution systems, public utility districts, county districts, and other
public agencies that have natural gas distribution facilities. APGA maintains that its members
are active participants in the domestic market for natural gas where they secure the supplies of
natural gas to serve their end users. APGA states that it has a direct and substantial interest in
this proceeding that cannot be adequately represented by any other party.
In protesting the Application, APGA asserts that Delfin’s request for authority to export
domestic LNG to non-FTA countries is inconsistent with the public interest and should be
denied. APGA argues that the proposed exports will increase domestic natural gas prices,
burdening households and jeopardizing potential growth in the U.S. manufacturing sector, as
well as the nation’s transition away from more environmentally damaging fossil fuels.
104
APGA first argues that the EIA 2012 Study, conducted as part of DOE’s 2012 LNG
Export Study, concluded that LNG exports will increase prices, with higher volumes causing
more drastic increases. APGA points out that the NERA Study, also part of DOE’s 2012 LNG
103
See id. at 31-34.
104
APGA Mot. at 3.
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Export Study, found that exports would yield net economic benefits but would raise domestic
natural gas prices. According to APGA, these price increases would burden the U.S. consumers
who can least afford the increase and disadvantage domestic manufacturing. APGA argues that
DOE/FE must go beyond the EIA and NERA Studies to consider the tradeoffs entailed by
exporting an increasingly valuable U.S. fuel, rather than supporting and enhancing the use of
natural gas domestically.
105
APGA points out that, as of April 18, 2014, DOE/FE had received 43 applications for
LNG export authority to FTA or non-FTA countries. APGA states that the total applied-for
export capacity (to both FTA and non-FTA countries) would increase the daily demand for
natural gas by roughly 58 percent.
106
APGA contends that authorization of this large quantity for
export will have an impact on natural gas demand, will increase domestic natural gas and
electricity prices, will inhibit the United States’ ability to forge a path toward energy
independence, and will undermine sustained economic growth in key manufacturing sectors.
107
APGA states that increased natural gas prices due to LNG exports will raise the costs of
both natural gas and electric energy, arguing that such increases threaten other domestic
industries such as steel and petrochemical manufacturing.
108
APGA further contends that price
increases due to exports will both (i) jeopardize the viability of natural gas as a “bridge-fuel” in
the transition away from carbon-intensive and otherwise environmentally problematic coal-fired
electric generation, and (ii) inhibit efforts to foster natural gas as a major transportation fuel.
105
Id. at 3-4.
106
See id. at 5.
107
See id. at 5-6.
108
See id. at 10-11.
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