69
supply the natural gas sector and/or benefit from the capital expenditures needed to increase
production. This includes some energy-intensive sectors and helps offset some of the impact of
higher energy prices.
VIII.
COMMENTS ON THE 2014 AND 2015 LNG EXPORT STUDIES
AND DOE/FE ANALYSIS
DOE/FE published the Notice of Availability of the 2014 and 2015 LNG Export Studies
in the
Federal Register on December 29, 2015, seeking public comment on both studies.
DOE/FE specifically invited comment on:
[T]he potential impact of LNG exports on domestic energy
consumption,
production, and prices; the macroeconomic factors
identified in the two studies, including Gross Domestic Product,
consumption, U.S. economic sector analysis, and U.S.
LNG export
feasibility analysis; and any other factors included in the analyses.
181
DOE noted that, “[w]hile this invitation to comment covers a broad range of issues, the
Department may disregard comments that are not germane to the present inquiry.”
182
DOE/FE has reviewed the 38 comments submitted in response to the NOA. Of those, 14
comments opposed the two Studies and/or exports of LNG, 21 supported the Studies, and three
took no position. Below, DOE/FE summarizes: (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 has responded to the relevant, significant
issues raised by the commenters.
183
181
80 Fed. Reg. at 81,302.
182
Id.
183
See,
e.g.,
Public Citizen v. F.A.A., 988 F.2d 186, 197 (D.C. Cir. 1993).
70
A.
Data Inputs and Estimates of Natural Gas Demand
1.
Comments
Several commenters, including Sierra Club, the Industrial Energy Consumers of America
(IECA), Cascadia Wildlands, Wim de Vriend,
and Hair on Fire Oregon, challenge the data used
as inputs to the LNG Export Studies.
184
Specifically, these commenters assert that the 2015
LNG Export Study relies on inaccurate assumptions that fail to reflect “current conditions”
adversely affecting the viability of exporting domestically produced LNG from the United
States. Citing various articles and natural gas industry reports, these commenters point to the
following conditions—some of which they acknowledge arose after the 2015 LNG Export Study
was published:
•
An oversupplied global energy market due to the rapid expansion worldwide
of LNG terminals (“supply glut”), which commenters allege will be the status
quo
for years to come;
•
The drop in international oil prices, which allegedly has reduced or eliminated
the price advantage for U.S. LNG exports;
•
The difference in costs between greenfield and brownfield LNG projects and
the associated risks to capital, given the alleged uncertainties associated with
LNG exports;
•
The declining costs of and advances in renewable energy sources, which
allegedly will compete directly with U.S. LNG in end markets;
•
Japan’s re-starting of some of its nuclear power plants;
•
The increasing prevalence of carbon trading regimes internationally (
e.g.,
China), making natural gas less of a
viable energy source; and
•
China’s slowing economy.
According to Sierra Club and other commenters, these conditions undermine the assumptions
and constraints of the 2015 LNG Export Study, calling into question the Study’s conclusions
that LNG exports will provide a slight benefit to GDP. Sierra Club further contends that, in
184
Unless specifically noted, the comments address the 2015 LNG Export Study.
71
light of these changing conditions, DOE should have revisited the 2012 LNG Export Study,
rather than conducting new studies to analyze the marginal effects of higher LNG export
volumes.
2.
DOE/FE Analysis
We note that the 2015 LNG Export Study modeled a wide range of possible future supply
and demand conditions, including alternative assumptions for domestic resource availability,
domestic natural gas demand, and a range of international supply and
demand conditions that
generate different potential market pull for U.S. LNG exports. The 2015 Study scenarios were
constructed so there was sufficient international demand to support commercially viable LNG
export flows from the United States in accordance with the volumes indicated in each case. This
approach allowed Rice-Oxford to assess the macroeconomic impacts of increased levels of U.S.
LNG exports under global market conditions where that trade would occur. The 2015 LNG
Export Study found that “the overall macroeconomic impacts of higher LNG exports are
marginally positive, a result that is robust to alternative assumptions for the U.S. natural gas
market.”
185
That is, the macroeconomic results are similar across the different scenarios
examined. The energy market conditions noted by the commenters would, all else being equal,
reduce international demand for U.S. LNG exports. The 2014 LNG Export Study included cases
with levels of U.S. LNG exports below 20 Bcf/d, specifically 12 and 16 Bcf/d. The 2014 LNG
Export Study found that “GDP gains from increasing LNG exports are positive across all cases,
although relatively modest.”
186
185
2015 Study at 8.
186
2014 Study at 25.