Comment of Sierra Club under CP14-122, 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. As reported by the International Energy Agencys (IEA), renewables are projected to become the worlds second-largest source of power generation by 2015, and are expected to close in on coal as the primary source by 2035. Other sources of information similarly predict an increasing role for renewables in likely import markets. For example, a June 2013 report by Bernstein Research predicts that in China, wind and solar will expand from roughly 61GW and 8.3GW of installed capacity currently to 250GW and 200GW, respectively, by the end of the decade. In combination, wind and solar will account for roughly half of incremental power generation over the rest of the decade. 2 Forecasts for India are similar, with HSBC concluding that wind power is already at parity, or cost- competitiveness, with new coal fired generation3 and HSBC and KPMG predicting that photovoltaic power will reach parity between 2016 and 2018.4 In Europe, renewables constitute 55% of new electric ...