99
injected over a longer period of time without any withdrawal of fluids, with the result that fluid
pressures can be increased within a large area surrounding the injection well.”
231
The Addendum
identifies seismic events thought to have been triggered by wastewater disposal into injection
wells in Oklahoma, Colorado, Arkansas, and Ohio.
Addressing the severity of seismic events induced by natural gas activities, the Addendum
cites a 2013 National Research Council report characterizing the risk of induced seismicity as
principally one of alarm to the public and minor property damage, as opposed to significant
disruption.
232
E.
Land Use
The Addendum addresses potential land use impacts resulting from unconventional natural
gas production. Land use impacts arise from the construction and development of new access
roads, heavy truck traffic on existing local roadways, well pads, pipeline rights of way, and other
structures such as compressor stations. The Addendum includes discussions of increased vehicle
traffic, habitat fragmentation, reflective light pollution, noise, and other impacts associated with
these land use changes. According to the Addendum, “[t]he real issue with land use impacts is not
the minor impacts related to each well pad, access road, or pipeline.”
233
Rather, “[w]hen the
impacts from these individual components of shale gas development are considered in aggregate,
or cumulatively, the impacts become magnified on an ecosystem or regional scale.”
234
The
Addendum identifies siting and design considerations that may minimize land use impacts, as well
as traffic and road way impacts associated with large vehicles and concerns for vehicular safety
231
Id. at 52.
232
Id at 55-56 (citing Induced Seismicity Potential in Energy Technologies. National Research Council. The
National Academies Press, Washington, D.C. (2013) at 5).
233
Addendum at 62.
234
Id.
100
for the motoring public.
X.
DOE/FE LIFE CYCLE GREENHOUSE GAS PERSPECTIVE ON EXPORTING
LIQUEFIED NATURAL GAS FROM THE UNITED STATES
A.
Description of LCA GHG Report
In January 2014, DOE/FE commissioned NETL to undertake a study analyzing the life
cycle emissions of greenhouse gases (GHG), including carbon dioxide (CO
2
) and methane (CH
4
),
associated with natural gas produced in the United States and exported as LNG to other countries
for use in electric power generation. The study was intended to inform DOE/FE’s decision-
making under NGA section 3(a) and to provide additional information to the public. The study—
entitled Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the
United States (LCA GHG Report)—estimated the life cycle GHG emissions of domestically
produced LNG (also referred to as U.S. LNG) exports to Europe and Asia, compared with
alternative fuel supplies (such as regional coal and other imported natural gas), for electric power
generation in the destination countries.
NETL published the LCA GHG Report on May 29, 2014, as well as a 200-page supporting
document entitled, Life Cycle Analysis of Natural Gas Extraction and Power Generation.
235
On
June 4, 2014, DOE/FE provided notice of the documents in the Federal Register and invited
public comment.
236
The 45-day public comment period closed July 21, 2014. In this section, we
summarize the scope of the LCA GHG Report, as well as its methods, limitations, and
235
See Dep’t of Energy, Nat’l Energy Tech. Lab., Life Cycle Greenhouse Gas Perspective on Exporting Liquefied
Natural Gas from the United States (May 29, 2014) , available at: http://energy.gov/fe/life-cycle-greenhouse-gas-
perspective-exporting-liquefied-natural-gas-united-states; see also Dep’t of Energy, Nat’l Energy Tech. Lab., Life
Cycle Analysis of Natural Gas Extraction and Power Generation (May 29, 2014), available at:
http://www.netl.doe.gov/energy-
analyses/temp/NaturalGasandPowerLCAModelDocumentationNG%20Report_052914.pdf [hereinafter NETL, Life
Cycle Analysis of Natural Gas Extraction and Power Generation].
236
Dep’t of Energy, Notice of Availability of Life Cycle Greenhouse Gas Perspective on Exporting Liquefied
Natural Gas from the United States and Request for Comment, 79 Fed. Reg. 32,260 (June 4, 2014). The NETL
documents and all comments received were placed in the administrative record for each of the 25 non-FTA export
application dockets then before DOE/FE, including this docket. See id.
101
conclusions. Below, we summarize the public comments on the Report and respond to those
comments. See infra § X.B.
1.
Purpose of the LCA GHG Report
The LCA GHG Report was designed to answer two principal questions:
•
How does LNG exported from the United States compare with regional coal (or
other LNG sources) used for electric power generation in Europe and Asia, from a
life cycle GHG perspective?
•
How do those results compare with natural gas sourced from Russia and delivered
to the same European and Asian markets via pipeline?
In establishing this framework, NETL considered the following:
•
In what countries will the natural gas produced in the United States and exported
as LNG be used?
•
How will the U.S. LNG be used in those countries, i.e., for what purpose?
•
What are the alternatives to using U.S. LNG for electric power generation in those
countries?
Because the exact destination country (or countries) of U.S. LNG cannot be predicted for this
study, NETL considered one medium-distance destination (a location in Europe) and one long-
distance destination (a location in Asia). NETL chose Rotterdam, Netherlands, as the European
destination and power plant location, and Shanghai, China, as the Asian location. NETL used
other locations for the alternative sources of natural gas and coal, as specified in the Report.
NETL also determined that one of the most likely uses of U.S. LNG is to generate electric power
in the destination countries. In considering sources of fuel other than U.S. LNG, NETL assumed
that producers in Europe and Asia could generate electricity in the following ways: (1) by
obtaining natural gas from a local or regional pipeline, (2) by obtaining LNG from a LNG
producer located closer geographically than the United States, or (3) by using regional coal
supplies, foregoing natural gas altogether.
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