Comment of Sierra Club under CP14-119, 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. II. DOE Must Do More than Compare The Lifecycle Emissions of U.S. LNG with Other Fossil Fuels As explained in the comment incorporated above, NEPA and the Natural Gas Act require DOE to consider the environmental impacts of the proposed LNG exports. DOEs Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States provides some useful information regarding the climate impacts of proposed LNG exports. Full consideration of the climate impacts of LNG exports, however, requires much more than mere comparison of the lifecycle emissions of LNG with those of other fossil fuels. In DOEs words, The primary questions addressed by the [Export LCA] are: How does exported liquefied natural gas (LNG) from the U.S. compare with regional coal (or other LNG sources) for electric power generation in Europe and Asia, from a life cycle greenhouse gas (GHG) perspective? How do those results ...