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Macroeconomic Outcomes of Market Determined Levels of U.S. LNG Exports

On June 12, 2018, the Office of Fossil Energy (FE) of the Department of Energy (DOE) gave notice of the availability of a study, Macroeconomic Outcomes of Market Determined Levels of U.S. LNG Exports (2018 LNG Export Study or 2018 Study), in 25 docket proceedings. Per the Federal Register Notice, DOE/FE invited the submission of public comments on the 2018 Study. DOE commissioned the 2018 LNG Export Study to inform its decision on pending and future applications seeking authorization to export domestically produced liquefied natural gas (LNG) from the lower-48 states to countries with which the United States does not have a free trade agreement (FTA) requiring national treatment for trade in natural gas, and with which trade is not prohibited by U.S. law or policy (non-FTA countries). The 2018 LNG Export Study, which was conducted by NERA Economic Consulting, evaluates a wider range of scenarios than DOE’s prior LNG export studies, including examining the probability of various export scenarios.

 The comment period was opened from June 12, 2018, to July 27, 2018. The comment period is now closed. The comments submitted appear below.

On December 28, 2018, in this Federal Register document, Study on Macroeconomic Outcomes of LNG Exports: Response to Comments Received on Study, DOE/FE responds to the 19 public comments received on the 2018 Study and summarizes its conclusions on the Study.

 

 

Comment period closed.
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ID DATE SUBMITTED FILED/ISSUED BY FILING TYPE comment RELATED DOCUMENT
DATE SUBMITTED FILED/ISSUED BY FILING TYPE COMMENT RELATED DOCUMENT
1. expand/collapse 6/18/2018 8:54:38 AM Burke, Vincent General Comment Your "List of Acronyms" is actually a list of abbreviations, with some acronyms.
2. expand/collapse 7/17/2018 2:53:45 PM Spigelmyer, David General Comment Please see attached comments submitted on behalf of the Marcellus Shale Coalition. Thank you.
  1. DOE - LNG Export Study - July '18.pdf
3. expand/collapse 7/21/2018 6:27:54 PM Weber, Patricia General Comment Please see attached file.
  1. Macroeconomic Outcomes of Market Determined Level...
4. 7/25/2018 3:18:57 PM Riedl, Charlie General Comment
  1. CLNG DOE LNG Study Comments 2018.pdf
5. expand/collapse 7/26/2018 10:48:06 AM Sunday, Kevin General Comment Please find attached the comments of the Pennsylvania Chamber of Business and Industry.
  1. PCBI DOE LNG Export Study Comments FINAL 072618.p...
6. 7/26/2018 1:40:29 PM Snitchler, Todd General Comment
  1. API Comments on DOE 2018 LNG Study.pdf
7. expand/collapse 7/27/2018 9:52:31 AM Stockman, Lorne General Comment Comments on 2018 LNG Export Study on behalf of Oil Change International, Food & Water Watch, 350.org, Center for International Environmental Law, Center for Biological Diversity, Friends of the Earth and dozens of local citizen groups concerned about gas infrastructure in their communities in the United States, Europe and around the world.
  1. Comments on 2018 LNG Export Study - OCI FWW et al...
8. 7/27/2018 10:01:07 AM Markowitz, Sean General Comment
  1. Cheniere LNG Export Study Comment 7-26 AM (Execut...
9. expand/collapse 7/27/2018 11:03:15 AM Diocee, Tajvinder General Comment Comments on 2018 LNG Export Study of Jordan Cove Energy Project L.P.
  1. Comments of Jordan Cove Energy Project on 2018 LN...
10. expand/collapse 7/27/2018 12:08:39 PM Cicio, Paul General Comment IECA Comments on U.S. Department of Energy (DOE) Study on Macroeconomic Outcomes of Market Determined Levels of U.S. LNG Exports, Docket No. 2018-12621
  1. 07.27.18_2018 DOE LNG Export Study Comments.pdf
11. 7/27/2018 12:36:22 PM Edwards, Scott General Comment
  1. 2018 LNG Export Study Comments.pdf
12. expand/collapse 7/27/2018 2:11:15 PM Hutchison, Fred General Comment The comments of LNG Allies are contained in the attached document.
  1. LNG Allies Comments - 2018 DOE Study.pdf
13. expand/collapse 7/27/2018 4:07:31 PM Wochner, David General Comment NextDecade Corporation submits the attached comments addressing NERA Economic Consulting’s 2018 LNG Export Study on behalf of its subsidiaries Rio Grande LNG, LLC and Galveston Bay LNG, LLC .
  1. Comments of NextDecade Corporation in Response to...
14. expand/collapse 7/27/2018 4:16:54 PM Heiken, Doug General Comment We feel it is critical that DOE understand the profound implications of market imperfections related to fossil fuels that have such significant externalities. The market for fossil fuels, including LNG, is deeply flawed. As a result of these flaws, prices are artificially low because prices do not reflect the full costs of production. Market signals are therefore incorrect, resulting in skewed demand and supply, and an inefficient allocation of resources that fails to optimize public welfare as expected in a properly functioning market. In short, the price of natural gas is artificially low because there are significant externalities, such as global climate change and ocean acidification, that are not included in the price of gas. Low prices for fossil fuels, including LNG, result in artificially high demand and supply that far exceeds optimal levels. Building the Jordon Cove LNG Export Project, or other LNG infrastructure, will increase the supply of a commodity that is already oversupplied at a global scale.
  1. Macroeconomic-LNG-cmt-7-27-2018-DOE.pdf
15. expand/collapse 7/27/2018 4:19:20 PM Matthews, Nathan General Comment Please see attached comment. Sierra Club also reiterates its comments on the 2012 and 2015 Macroeconomic Studies, which apply to this study with equal force.
  1. 2018 LNG macroeconomic comments.pdf
16. 7/27/2018 4:22:26 PM Schaaf, Deb Evans and Ron General Comment
  1. Evans-Schaaf Comments on 2018 Macroeconomics LNG ...
17. expand/collapse 7/27/2018 4:28:07 PM McCaffree, Jody General Comment Please see attached comment and exhibits
  1. USDOE_McCaffree comment_LNG-Export-Study_7-27-201...
  2. USDOE_McCaffree_CFR__Index-for-Exhibits_7-27-2018...
  3. McCaffree Exhibit 1-12.pdf
18. expand/collapse 7/27/2018 4:50:32 PM Young, John General Comment I have been following LNG issues since 05-05-2014 when I first learned that LNG export projects were targeting my local Port of Brownsville, next door to South Padre Island, TX. The 25 LNG export projects listed in Document 83 FR 27314 include two seeking FERC permitting here (Rio Grande LNG, Texas LNG) but not the 3rd (Annova LNG). Galveston Bay LNG, like Rio Grande LNG, is a NextDecade subsidiary. For various reasons, including strong local opposition to LNG here, Annova, Texas, and even Rio Grande LNG have, at best, an uncertain future here. And if Rio Grande LNG goes under, Galveston Bay LNG will probably go under with it. Three other companies on the list – Gulf Coast LNG, Eos LNG & Barca LNG – preleased land at our Port. However, their preleases have lapsed and they never even pre-filed for FERC permitting. According to NERA Economic Consulting's 2018 Macroeconomic report, the company believes that all eight of its proposed LNG export scenarios will benefit most US households. The benefits are “relatively small in magnitude,” but higher for higher volumes of LNG exports. This is in line with NERA's previous 2012 report, also prepared for DOE. Question: How does this optimism square with the problems the 25 LNG projects listed have had with moving forward and achieving revenue inflow? And don't forget EIA's 2016 caution that its case studies are projections and not predictions (https://www.eia.gov/todayinenergy/detail.php?id=26272). Interestingly, this NERA 2018 report makes no mention of the 2013 scathing critique that Synapse Energy Economics made of its 2012 report (http://www.synapse-energy.com/sites/default/files/SynapseReport.2013-01.SC_.LNG-Exports-Benefits.13-009.pdf). Also, Synapse recently published 2018 scathing critique of ISO New England's 23 scenario “Operational Fuel Security Analysis” arguing for unnecessary & costly gas pipeline projects (http://www.synapse-energy.com/sites/default/files/Working-Toward-a-Clean-Reliable-Electric-Grid.pdf). In part, the critique found the present level of LNG imports and other gas sources adequate. Looking at both of these critiques, I strongly urge DOE to hire Synapse as a 3rd party contractor to critique NERA's 2018 report. I also strongly recommend that you check out "The reliability and usefulness of economic impact studies: Research roundup,"  Denise-Marie Ordway, last updated 04-17-2018, Journalist’s Resource, https://journalistsresource.org/studies/government/economic-impact-studies-research-reliable. Question: How long would “independent” 3rd party contractors line NERA (and Synapse) stay in business if they didn't produce the results sought by those employing their services? Question: What's the empirical evidence of Economic Impact Study and Case Study reliability? What's their track record in retrospect – a year or 5 or 20 down the road?
19. expand/collapse 6/30/2018 12:00:00 AM Anonymous, Anonymous General Comment Five anonymous comments were received through the Federal Document Management System, on three dates: June 30, 2018; July 1, 2018; and July 11, 2018. The five comments are attached.
  1. 1 DOE-HQ-2018-0030-DRAFT-0001-10_02_2018-12_45_PM...
  2. 2 DOE-HQ-2018-0030-DRAFT-0002-10_02_2018-12_46_PM...
  3. 3 DOE-HQ-2018-0030-DRAFT-0003-10_02_2018-12_46_PM...
  4. 4 DOE-HQ-2018-0030-DRAFT-0004-10_02_2018-12_47_PM...
  5. 5 DOE-HQ-2018-0030-DRAFT-0005-10_02_2018-12_47_PM...