Home » Services » Natural Gas Regulation » Electronic Docket Index
Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States
On May 29, 2014, the Department of Energy’s (DOE) Office of Fossil Energy announced the availability for public review and comment the report Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States (LCA GHG Report).  The purpose of this LCA GHG Report is to provide additional information to the public and to DOE to inform its decisions regarding the life cycle greenhouse gas (GHG) emissions of U.S. LNG exports for use in electric power generation.  The LCA GHG Report compares life cycle GHG emissions from U.S. LNG exports to regional coal and other imported natural gas for electric power generation in Europe and Asia. The LCA GHG Report is based on the NETL report Life Cycle Analysis of Natural Gas Extraction and Power Generation (Natural Gas and Power LCA Model Documentation).

The LCA GHG Report and comments received will be included in the dockets of the 25 pending applications for which Notices of Application have been issued seeking authorization to export LNG by LNG tanker from large-scale liquefaction facilities in the lower-48 states to non-FTA nations.  DOE will accept initial comments on the report for 45 days after the official notice of the study appears in the Federal Register.  All comments received need only be submitted once as they will be placed in the administrative record for each of the 25 dockets. 

DOE prefers that comments be submitted electronically using the online Comment Submission Form, which can be accessed below.  Please note that the Comment Submission Form allows comments on the LCA GHG Report and also on the Natural Gas and Power LCA Model Documentation.  If you cannot submit comments electronically, the Federal Register Notice provides instructions on how to submit comments.  All comments must be received by DOE no later than 4:30 p.m., Eastern Time, July 21, 2014.  To view comments already submitted, select the Comments link below.

Comment period closed.
Related Documents & Comments Library
Indicate comment
1. expand/collapse 7/17/2014 1:13:06 PM Univ. of Houston Law Center LCA GHG Report * Request for Extension of Time to Comment * On May 29, 2014, the DOE released a number of documents in connection to proposed changes to the DOE's review process for LNG exports. Together, the documents total hundreds of pages and involve complex issues related to LNG exports, environmental impacts of increased shale gas development, life cycle analysis of greenhouse gas emissions from natural gas extraction and exports and a myriad of other related issues. Public comments for all 3 major issues - (1) LNG export procedures, (2) Draft Addendum to Environmental Issues, (3) Life Cycle Greenhouse Gas Perspective - are due on July 21, 2014. I intend to comment on all three issues but the 45- day comment period for all three issues is not enough time to review and analyze all of the complex issues involved. I respectively request that DOE extend the comment period to 90-days for the Life Cycle Greenhouse Gas Perspective which would allow time for the public to review the large volume of information DOE has released and make useful and relevant comments.
2. expand/collapse 7/18/2014 1:26:25 PM Center for Liquefied Natural Gas LCA GHG Report Please see the attached comments.
  1. CLNG DOE comments on LCA GHG Report final July 18...
3. expand/collapse 7/18/2014 4:03:10 PM Grand Junction Economic Partnership LCA GHG Report Please see attached letter from the Board of Directors of the Grand Junction Economic Partnership (GJEP) - the official economic development organization for Mesa County, Colorado.
  1. LNG Export Comments.pdf
4. expand/collapse 7/21/2014 7:09:01 AM Univ. of Houston Law Center LCA GHG Report Please see attached.
  1. Sakmar Comments_DOE LNG Export Change of Procedur...
5. expand/collapse 7/21/2014 11:05:21 AM Cameron LNG LLC, Cameron LNG LLC LCA GHG Report Please see the attached file.
  1. Comments of Cameron LNG on GHG Study.pdf
6. expand/collapse 7/21/2014 12:56:09 PM American Petroleum Institute LCA GHG Report Please find the Submission of the American Petroleum Institute Regarding DOE's LCA GHG Report Comments Attached as a PDF File.
  1. 14 July 21 API_DOE-LNG_LCA Perspectives_FINAL.pdf
7. expand/collapse 7/21/2014 3:03:32 PM Americans Against Fracking and others LCA GHG Report Please accept the attached comments on the Life Cycle Greenhouse Gas Perspective on Exporting LNG from the U.S. This is submitted on behalf of Americans Against Fracking and others listed as signatory organizations.
  1. Comments on DOE lifecycle report_7-21-14.pdf
8. expand/collapse 7/21/2014 3:07:35 PM Americans Against Fracking, et al. LCA GHG Report Please consider the comments attached.
  1. CHPNY Fracking Compendium_woal.pdf
  2. Sign_on_letter_to_Obama-Moniz_re_DOE_reports_7 21...
9. expand/collapse 7/21/2014 3:49:28 PM Dominion Cove Point LNG, LP LCA GHG Report Comments of Dominion Cove Point LNG, LP Concerning: (1) the Proposed Changes in Procedures For LNG Export Decisions, (2) the Draft Addendum to Environmental Review Documents Concerning Exports of Natural Gas from the United States and (3) the Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States - Please see attached.
  1. DCP comments on DOE LNG environmental reports 7 2...
10. expand/collapse 7/21/2014 3:56:19 PM on behalf of Freeport LNG Expansion, et al LCA GHG Report Please see attached pdf. entitled Comments on Summary Draft of Life Cycle Greenhouse Gas Perspective on Exporting U.S. Sourced LNG.
  1. Freeport LNG Life Cycle GHG.pdf
11. expand/collapse 7/23/2014 11:03:44 AM Food & Water Watch LCA GHG Report See attached.
  1. Sign_on_letter_to_Obama-Moniz_re_DOE_reports_7.21...
  2. CHPNY Fracking CompendiumJuly11_woal.pdf
12. expand/collapse 7/23/2014 1:29:45 PM Lish, Christopher LCA GHG Report See attachment.
  1. Christopher Lish comment.pdf
13. expand/collapse 7/23/2014 1:54:14 PM on behalf of Cameron LNG, LLC LCA GHG Report See Attachment.
  1. Comments of Cameron LNG on GHG Study.pdf
14. expand/collapse 7/24/2014 2:30:43 PM Sierra Club LCA GHG Report See attachments
  1. 201407211543.pdf
  2. Ex. 01 - Bernstein peak coal report.pdf
  3. Ex. 02 - Vorrath - Wind at Parity.pdf
  4. Ex. 03 - Rising-Sun-2 KPMG Report 2012.pdf
  5. Ex. 04 - EWEA Wind In Power Annual Stats 2013.pdf
  6. Ex. 05 - Leaked Trade Document.pdf
  7. Ex. 06 - Miller - Emission of methane US.pdf
  8. Ex. 07 - Petron - A new look at methane and non-m...
  9. Ex. 08 - Abstract Methane emissions estimate from...
  10. Ex. 09 - Fugitive Emissions.pdf
  11. Ex. 10 - Letter to Executive Secretary of UN Fram...
  12. Ex. 11 - Framework Convention on Climate Change.p...
  13. Ex. 12 - Projected Greenhouse Gas Emissions.pdf
  14. Ex. 13 - First Biennial Report of the USA.pdf
  15. Ex. 14 - Reporting Guidance and Tables.pdf
  16. Ex. 15 - Technical Support Document.pdf
  17. Ex. 16 - SC Comments on IGC.pdf
  18. Ex. 17 - EDF & NRDC IGC Comments.pdf
  19. Ex. 18 - Estimating social cost of non-CO2 GHG Em...
  20. Ex. 19 - Social Cost of Carbon for RIA.pdf
15. expand/collapse 7/25/2014 1:41:57 PM Citizens Against LNG LCA GHG Report Please consider attached comments and exhibits. (DOE/FE note: Portions of these exhibits are being withheld pending redaction of Personally Identifiable Information. A redacted version of this document will be posted when that process is complete.)
  1. DOE_CALNG-McCaffree_7-21-2014_Comments.pdf
  2. DOE_July-21-2014_CALNG-McCaffree_Exhibits_portion...
16. expand/collapse 7/28/2014 1:53:45 PM Oregon Wild LCA GHG Report Dear DOE: Please accept the following comments from Oregon Wild regarding the Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States. Oregon Wild represents approximately 10,000 members and supporters who share our mission to protect and restore Oregon's wildlands, wildlife and waters as an enduring legacy. Science clearly shows that the LNG fuel cycle causes (directly and indirectly) significant net emissions of greenhouse gases. First, industry-wide natural gas production methods, including but not limited to fracking, cause significant leakage of methane, which has a significant worse climate forcing effect than CO2. Second, the process of compressing natural gas to a liquid form is an energy-intensive process that results in significant emissions of GHG, even before the LNG has reached the end user. Third, natural gas is a fossil fuel, and fossil fuel use must be curtailed. Indeed, if we want to save the climate, fossil fuels must stay in the ground. Detailed information supporting these points is attached. Based on these factors, we feel strongly that LNG is not a "bridge fuel" that deserves to be promoted, expanded, or subsidized. Thank you for considering these comments. Sincerely, /s/ Doug Heiken Oregon Wild PO Box 11648 Eugene OR 97440 dh@oregonwild.org
  1. Summary-of-DOE-Lifecycle-GHG-report by Chesapeake...
  2. Brandt et al 2014 Science Magazine.pdf
  3. Leaky Methane Makes Natural Gas Bad for Global Wa...
  4. PNAS-2013-Miller methane leakage Harvard.pdf
  5. Stanford Report Re Brandt 2014 Science Magazine m...
17. expand/collapse 8/8/2014 2:56:16 PM concerned citizens LCA GHG Report 174 copies of a letter were submitted by 149 unique individuals (see attachment). Most letters were from residents of NY state, but other states were also represented (CA, LA, MD, MI, NC, NE, NH, NJ, NY, OH, PA, TX, VA, and WY). This letter was also received from residents of India, Germany, the UK, and France.
  1. Concerned Citizens.pdf
18. expand/collapse 8/11/2014 2:12:18 PM Zimmerman & Associates LCA GHG Report On behalf of Damascus Citizens for Sustainability, Inc. and NYH2O, Inc., I am submitting the following comments on the draft report entitled "Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States." See attached letter.
  1. 201408061514_2.pdf