[Update: This analysis was finalized in November 2023. In January 2024, DOE announced that it will update its greenhouse gas analysis.]
In July 2023, DOE denied a petition for rulemaking on LNG exports. In the denial, DOE argued that it is “able to take into account new or different facts” and supplement its case-by-case adjudication of export applications with technical analyses.
The purpose of this analysis is to provide insights from new data that could encourage and assist DOE in updating its technical analysis for assessing the greenhouse gas impact of new LNG authorizations. LNG projects authorized by DOE in the coming year or later will likely not begin exports until 2027 or beyond. The context in which these facilities will operate is substantially different than prior authorizations, with a substantially different impact on greenhouse gas emissions.
DOE’s methodology for assessing greenhouse gas emissions has not been updated since 2019, and relies largely on approaches first used in 2014, before the first shipments of US LNG exports. Using the International Energy Agency’s World Energy Outlook 2023, I provide updated assessments of regional energy markets to illustrate the need for DOE to update its GHG technical analysis when assessing pending or future LNG authorizations, including timeline extensions.
This analysis was developed by Symons Public Affairs and was not requested by DOE.