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B.
Comments on the LCA GHG Report and DOE/FE Analysis
As discussed above, the LCA GHG Report compares life cycle
GHG emissions from
U.S. LNG exports to regional coal and other imported natural gas for electric power generation
in Europe and Asia. Following the close of the public comment period on the LCA GHG
Report, DOE/FE identified 18 unique submissions received from the general public, interest
groups, industry, and academia/research institutions, which DOE/FE categorized into seven
distinct comments.
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DOE/FE identifies below: (i) the pertinent
arguments by topic, with reference to
representative comments, and (ii) DOE/FE’s basis for the conclusions that it drew in reviewing
those comments. In so doing, DOE/FE will respond to the relevant, significant issues raised by
the commenters.
1.
Study Conclusions
a.
Comments
Several commenters, including Citizens Against LNG and Oregon Wild, claim that the
life cycle GHG emissions from natural gas are higher than those from coal.
b.
DOE/FE Analysis
These comments assert that natural gas has higher GHGs than coal,
but they do not cite
data sources applicable to the comparison of U.S.-exported LNG to regional coal, nor do they
acknowledge that the different end uses of coal and natural gas (i.e., heating, power, or
transportation) affect their relative life cycle GHG performance. If the characteristics of each
fuel (most critically, the carbon content per unit of the fuel’s energy) and power plant
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In some instances, single letters were sent on behalf of a group of people.
In one case, multiple copies of a form
letter were received from 149 individuals, hereinafter referred to as “Concerned Citizens.” Most of the individuals
in the Concerned Citizens group live in New York, but other states and countries are also represented.
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efficiencies are considered, the
lower per-MWh CO
2
emissions from natural gas power plants in
comparison to coal power plants make natural gas lower than coal in the context of power plant
operations by 61% (see Table 10 below, [(415 – 1,063)/1,063 x 100]). The life cycle of baseload
electricity generation is a reasonable basis for comparing natural gas and coal because both types
of fuels are currently used on a large scale by baseload power plants.
Table 10 shows the life cycle GHG emissions CO
2
, methane (CH
4
), nitrous oxide (N
2
O),
and sulfur hexafluoride (SF
6
) from natural gas and coal systems and demonstrates the importance
of power plant operations to total life cycle GHG emissions over 100- and 20-year GWP
timeframes. This table is representative
of European end-use scenarios, which consume natural
gas exported from the United States and coal extracted in Europe. (This table is based on the
same data as used by Figure 6-1 of the LCA GHG Report.)
Table 10: Life Cycle GHG Emissions from Natural Gas and Coal Systems
(kg CO
2
e/MWh)
Life Cycle Process
100-yr GWP
20-yr GWP
Natural Gas:
New Orleans
to
Rotterdam,
Netherlands
Coal:
European
Regional
Natural Gas:
New Orleans
to
Rotterdam,
Netherland
Coal:
European
Regional
Natural Gas/Coal Extraction
33.9
7.8
88.7
13.6
Natural Gas Processing
34.5
-
60.4
-
Domestic Pipeline Transport
32.3
-
81.4
-
Liquefaction
63.6
-
63.6
-
Tanker/Rail Transport
25.0
14.4
28.4
15.3
Tanker Berthing & Deberthing
1.5
-
1.6
-
LNG Regasification
20.0
-
45.3
-
Power Plant Operations
415
1,063
415
1,064
Electricity T&D
3.4
3.4
2.5
2.5
Total
629
1,089
787
1,095
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2.
Boundaries of the LCA GHG Report
a.
Comments
Sierra Club,
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Food & Water Watch,
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Americans Against Fracking
et al., Susan
Sakmar, and Concerned Citizens, among others, contend that the LCA GHG Report has flawed
boundaries and scenarios. In particular, these commenters contend that the LCA GHG Report
assumes that LNG will displace coal power without also accounting for the displacement of
renewable energy.
b.
DOE/FE Analysis
The boundaries of the LCA were developed with respect to questions about two fossil
fuels, coal and natural gas, and where they come from. The scenarios in
the LCA do not model
displacement of any kind. These two scenarios are purely attributional, meaning that they focus
on independent supply chains for each scenario and do not account for supply or demand shifts
caused by the use of one fuel instead of another fuel.
3.
Natural Gas Transport between Regasification and Power Plants
a.
Comments
Sierra Club and Concerned Citizens, among others, assert that the LCA GHG Report
does not account for natural gas transport between LNG regasification facilities and
power plants
in the importing countries.
b.
DOE/FE Analysis
The choice to exclude transportation between regasification and the power plant was a
modeling simplification. The sensitivity analysis of GHG emissions with changes to pipeline
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Sierra Club submitted comments on behalf of its members and supporters as well as Cascadia Wildlands, Otsego
2000, Inc., Columbia Riverkeeper, Stewards of the
Lower Susquehanna, Inc., Friends of the Earth, Chesapeake
Climate Action Network, Food and Water Watch, and EarthJustice.
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Food & Water Watch submitted comments in the form of a letter signed by 85 individuals representing various
national, state, and local public interest groups.