Comment of Sierra Club under CP13-483, et. al.

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 compare with natural gas sourced from Russia and delivered to the same European and Asian markets via pipeline?1 This comparison of the greenhouse gas intensity of U.S.-sourced LNG with other fossil fuels for purposes of electricity generation does not reflect the climate impacts of proposed exports, because U.S. LNG exports will not simply and exclusively displace other fossil fuels. End use markets in Europe and Asia are rapidly investing in clean energy infrastructure like wind, solar, and efficiency. U.S. LNG exports would likely displace these energy investments in addition to, or instead of, displacing use of other fossil fuels. In addition, U.S. LNG exports will affect U.S. greenhouse gas emissions in ways not captured by this lifecycle analysis. As modeled by the EIA over two years ago, LNG exports will raise U.S. natural gas prices, which will likely shift some electricity generation from gas to coal, with EIA predicting a net increase in carbon dioxide emissions from U.S. electricity generation. We discuss both of these issues below. A. DOE Cannot Assume that The Only Effect of U.S. LNG Exports in End Use Markets Will Be One-for-One Displacement of Other Fossil Fuel Use 1 79 Fed. Reg. 32260, 32261 (June 4, 2014). See also Export LCA at 2 n.1 (The goal of this analysis is to model plausible (medium and long distance) export scenarios while also considering regional fuel alternatives. The purpose of the medium and long distance scenarios is to establish low and high bounds for likely results.). 2 July 21, 2014 ...