90
$15
across the scenarios; the spread for NBP-Henry Hub in 2040 is roughly $3 to nearly $8.
207
The 2015 Study noted that the impact of LNG exports on the Henry Hub price depends on both
domestic and international market considerations. For example, Henry Hub prices would rise
with increased domestic demand for natural gas.
Additionally, prices for U.S. LNG would include the cost of inland transportation,
liquefaction,
shipping, and regasification. The 2015 Study’s model assumed competition among
different suppliers, such that buyers would have no incentive to buy natural gas from the United
States if the delivered price after liquefaction and transportation is higher than the alternative
delivered LNG price from other sources. DOE/FE agrees that a competitive market would
behave in this manner and U.S. natural gas prices would be lower than international LNG prices
in such a market by at least the costs previously described. Further, the introduction of LNG
exported from the United States into the international market would
tend to exert downward
pressure on the prevailing higher delivered price for LNG in those foreign markets and could
weaken the “oil-indexed” pricing terms.
For these reasons, we agree with those commenters who maintain that LNG exports from
the United States will have difficulty competing with LNG exports from other countries unless
domestic U.S. natural gas can be produced much cheaper. There is no evidence before us
demonstrating that the prices of natural gas or LNG in the international market are more volatile
than the prices in the U.S. domestic market.
IX.
DOE/FE ADDENDUM TO ENVIRONMENTAL REVIEW DOCUMENTS
CONCERNING EXPORTS OF NATURAL GAS FROM THE UNITED STATES
On June 4, 2014, DOE/FE published the Draft Addendum for public comment. The
purpose of the Addendum, DOE/FE explained, was to provide information to the public regarding
207
Id. at 52.
91
the potential environmental impacts of unconventional natural gas production. Although not
required by NEPA, DOE/FE prepared the Addendum in an effort to
be responsive to the public
and to provide the best information available on a subject that had been raised by commenters in
this and other LNG export proceedings. The 45-day comment period on the Draft Addendum
closed on July 21, 2014. DOE/FE received 40,745 comments in 18 separate submissions, and
considered those comments in issuing the Addendum on August 15, 2014.
208
DOE provided a
summary of the comments received and responses to substantive comments in Appendix B of the
Addendum.
209
DOE/FE has incorporated
the Draft Addendum, comments, and final Addendum
into the record in this proceeding.
The Addendum focuses on the environmental impacts of unconventional natural gas
production, which primarily includes production from shale formations, but also includes tight gas
and coalbed methane production. DOE/FE elected to focus the Addendum on unconventional
production because such production is considered more likely than
other forms of production to
increase in response to LNG export demand. EIA’s 2012 Study, published as part of the LNG
Export Study, projected that more than 90 percent of the incremental natural gas produced to
supply LNG exports would come from these unconventional sources.
210
Although the 2012 EIA Study made broad projections about the types of resources from
which additional production may come, the Addendum stated that DOE cannot meaningfully
estimate where, when, or by what particular method additional natural gas would be produced in
response to non-FTA export demand. Therefore, the Addendum focuses broadly on
208
Addendum at 3.
209
Id. at 79-151.
210
See LNG Export Study – Related Documents,
available at http://energy.gov/fe/services/natural-gas-
regulation/lng-export-study (EIA 2012 Study) at 11 (total from shale gas, tight gas, and coalbed sources).
92
unconventional production in
the United States as a whole, making observations about regional
differences where appropriate.
The Addendum discusses several categories of environmental considerations—Water
Resources, Air Quality, Greenhouse Gas, Induced Seismicity, and Land Use Impacts—each of
which is summarized briefly below.
A.
Water Resources
1.
Water Quantity
Natural gas production from shale resources requires water at various stages of
development, approximately 89 percent of which is consumed through
the process of hydraulic
fracturing.
211
The Addendum presents information regarding water usage for shale gas production
both in comparison to other energy sources and other regional uses. Although production of
natural gas from shale resources is more water-intensive than conventional natural gas production,
it is substantially less water-intensive than many other energy sources over the long term after the
well has been put into production. As shown in the Addendum, Table 6 below captures
differences in water intensity across energy sources.
211
Addendum at 10.