LNG Allies Comments on the DOE LNG Study
May 2025

The USLNG Association filed detailed comments in March 2025 challenging the DOE’s Dec. 2024 LNG Export Study on multiple fronts. Drawing on independent analysis from the OIES, Berkeley Research Group (BRG), and economist R. Dean Foreman, Ph.D., the comments argue that DOE’s core scenario relies on implausible global gas demand projections running ≈20% above other major forecasts, and that the study’s methodology was likely designed to reach predetermined conclusions. On the climate question, a BRG LCA across 13 markets found USLNG’s GHG emissions intensity averages 9% lower than pipeline gas imports to Europe and 63% lower than coal in Asia. A separate BRG analysis rebutted the Greenpeace/Sierra Club “Permit to Kill” report, identifying fundamental methodological flaws, including reliance on permitted rather than actual emissions data. Foreman’s updated analysis found no sustained, significant link between USLNG exports and domestic Henry Hub prices. LNG Allies’ bottom line: DOE should place greater weight on observed data, conduct fair and unbiased reviews, and continue evaluating each USLNG project on its individual merits.

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