Comment of Sierra Club under CP13-553, et. al.

July 21, 2014 U.S. Department of Energy (FE34) Attn: LCA GHG Report Comments Office of Oil & Gas Global Security & Supply Office of Fossil Energy Forrestal Building, Room 3E042, 1000 Independence Avenue SW., Washington, DC 20585. Dear Secretary Moniz: Thank you and the Department of Energys Office of Fossil Energy (DOE/FE) for accepting these comments on the Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States (Export LCA) and Life Cycle Analysis of Natural Gas Extraction and Power Generation (Gas LCA) reports, as well as the related Addendum to Environmental Review Documents Concerning Exports of Natural Gas from the United States and the Environmental Impacts of Unconventional Natural Gas Development and Production report. We submit these comments on behalf of the Sierra Club, our millions of members and supporters, and 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. I. Introduction This comment supplements the comment concurrently submitted by the above groups regarding the Addendum to Environmental Review Documents Concerning Exports of Natural Gas from the United States and related materials. We incorporate that comment here by reference, including in particular sections I and II, which summarize DOEs National Environmental Policy Act (NEPA) and Natural Gas Act obligations regarding the review of export authorization applications, explain the errors in DOEs interpretation of those obligations, and present addition concerns regarding the packaging of and procedures surrounding the four environmental documents released on May 29, 2014. the most skewed of DOEs emission estimates (i.e., the estimates DOE provides that are most favorable to LNG),8 U.S. LNG would need to displace at least twice as much coal as renewable energy to show any climate benefit. As we explain below, however, DOE significantly underestimates U.S. LNGs lifecycle emissions. Based on methane leakage rates indicated by atmospheric studies (e.g., 3% or more), U.S. LNGs lifecycle emissions approach will likely exceed coals, applying 100-year and 20-year methane global warming potentials, respectively.9 Adding in the fact that U.S. LNG will also compete with regional LNG, which DOE estimates to have lower lifecycle emissions than U.S. LNG, makes it even less likely that U.S. LNG exports would decrease importing countries aggregate lifecycle energy emissions. Thus, using realistic estimates of the lifecycle greenhouse gas emissions of U.S.-sourced LNG, if even a small fraction ...