“Biden/Granholm DOE Releases Garbage Anti-LNG Exports “Study”
“Yesterday, the U.S. Department of Energy (DOE), headed by ultra-dumb Jennifer Granholm, issued a bogus “study” (copy below) arguing that no new approvals should be granted for additional LNG exports.
Biden/Granholm DOE Releases Garbage Anti-LNG Exports “Study”
ANTI-DRILLING/FOSSIL FUEL | CNG/LNG | EXPORTING | INDUSTRYWIDE ISSUES | REGULATION
December 18, 2024
Yesterday, the U.S. Department of Energy (DOE), headed by the ultra-dumb Jennifer Granholm, issued a bogus “study” (copy below) arguing that no new approvals should be granted for additional LNG exports. The report (and Granholm, in a cover letter) argues that “the amounts [of LNG export facilities] that have already been approved will be more than sufficient to meet global demand for U.S. LNG for decades to come.” In other words, the so-called elites know better than the free market how many LNG export plants the country should support. Granholm argues in favor of a command-and-control approach (i.e., Communism) over a free market, free enterprise approach to approving new LNG exports.
In his inaugural address of 1981, Ronald Reagan said this:
In this present crisis, government is not the solution to our problem; government is the problem. From time to time we’ve been tempted to believe that society has become too complex to be managed by self-rule, that government by an elite group is superior to government for, by, and of the people. Well, if no one among us is capable of governing himself, then who among us has the capacity to govern someone else? (1)
Biden’s so-called pause and this “study” was rigged from the beginning. There was never any doubt as to what the Bidenistas, completely controlled by the radical, hate-America left, would propose. The only problem is that with this study now on the record, it will be used by the left as part of their lawfare to block Trump in approving more LNG exports. That’s pretty easy to predict.
As soon as Trump assumes office in less than six weeks, he will approve more LNG exports. The rabid left will try to find paid-off judges to halt the approvals. Let’s see how that all plays out.
In the meantime, there too many articles about the study than we can share here. We’ve tried to select a representative sample from both sides to give you a fair-and-balanced view of the news.
The DOE press release announcing the release of the study:
The U.S. Department of Energy (DOE) today released an updated study of U.S. liquefied natural gas (LNG) exports. DOE has been given the responsibility by Congress under the Natural Gas Act to evaluate the public interest of proposed exports to countries with which the United States does not have a Free Trade Agreement.
The study, released today, will have a 60-day comment period that will begin once published in the Federal Register. The public is encouraged to submit comments, which will inform how DOE may apply the study’s findings to its public interest analysis of export applications going forward. This is consistent with DOE’s past practice.
Additional to the study release today, and subsequent publication in the Federal Register, U.S. Energy Secretary Jennifer M. Granholm released a Secretarial Statement outlining departmental leadership’s perspective on the final study.
Excerpts:
“The Natural Gas Act has given the U.S. Secretary of Energy the responsibility to evaluate whether authorizations for the export of liquefied natural gas to non-free-trade-agreement countries is consistent with the “public interest.” […] I want to take this opportunity to highlight five key findings and considerations that I think are especially relevant to help guide future Secretaries of Energy in making decisions about whether particular applications are in the public interest. Today’s publication reinforces that a business-as-usual approach is neither sustainable nor advisable.
‘DOE analysis exposes a triple-cost increase to U.S. consumers from increasing LNG exports – the increasing domestic price of the natural gas itself, increases in electricity prices (natural gas being a key input in many U.S. power markets), and the increased costs for consumers from the pass-through of higher costs to U.S. manufacturers.
‘Special scrutiny needs to be applied toward very large LNG projects. An LNG project exporting 4 billion cubic feet per day – considering its direct life cycle emissions – would yield more annual greenhouse gas emissions by itself than 141 of the world’s countries each did in 2023.
‘…any sound and durable approach for considering additional authorizations should consider where those LNG exports are headed, and whether targeted guardrails may be utilized to protect the public interest.’… ‘the demand for LNG in the People’s Republic of China – already the world’s largest importer – is expected to nearly double between now and 2030 and become the highest of any country by 2050. PRC entities have already signed several contracts with operating or proposed U.S. LNG projects.
‘In the decade to come, we will see strong and mounting pressure within our democratic system to ensure that the United States uses its market position in a way that truly advances our national interest and energy security, which must include the needs of American workers, American families, and our responsibility to address the climate crisis. In our view, the question is not whether U.S. export policy will be forced to respond to those interests, but when and what that response is.”
The U.S. liquefied natural gas export sector has experienced transformative and unprecedented growth in just a decade, with the first LNG exports from the lower-48 states commencing in 2016. DOE has authorized 48 billion cubic feet per day (Bcf/d) of natural gas for export, or nearly half of current domestic production.
Of this 48 Bcf/day in total authorized exports, 14 Bcf/d of associated capacity is now operating, making the U.S. the largest exporter of LNG in the world. Another 12 Bcf/d is under construction and expected to double present export volumes by 2030, at which time the U.S. will remain the top exporter, exceeding other countries by roughly 40 percent based on announced expansions. And a further 22 Bcf/d of capacity exports has been approved by DOE, but has not secured a final investment decision to begin construction.
Given these robust export commitments already made, and before considering additional applications that would take authorized U.S. natural gas exports beyond levels previously evaluated, DOE leadership recognized the need for a comprehensive update to ensure the most comprehensive and up-to-date analysis possible of market, economic, national security, and environmental considerations of different potential volumes of U.S. LNG exports. (2)
Granholm’s cover letter defending this bilge:
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The main part of the report (called the Summary), minus the appendices:
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For the appendices, see this DOE page.
A fairly balanced view of the news from Reuters:
The administration of U.S. President Joe Biden released a long-awaited study on the economic and environmental impacts of liquefied natural gas exports on Tuesday, saying the results underscored the need for a cautious approach to new permits.
Biden in January had paused the Department of Energy’s approvals of U.S. LNG exports to big consumers in Asia and Europe so that his administration could conduct the review, triggering complaints from the oil and gas industry.
“The main takeaway is that a business-as-usual approach is neither sustainable nor advisable,” Energy Secretary Jennifer Granholm told reporters ahead of the release of the study. Granholm said in a letter about the study’s findings that rising LNG exports risk dramatically raising greenhouse gas emissions and could also trigger price hikes for U.S. energy consumers.
Incoming President Donald Trump, a climate-change skeptic and a big supporter of fossil fuel development, has promised to immediately end the moratorium on new LNG export permits when he returns to the White House on Jan. 20.
The study, opens new tab contained various scenarios of the impacts of LNG exports depending on domestic and international climate policies, technologies and resource availability.
Across all scenarios, the study found U.S. natural gas supply is sufficient to meet domestic demand for the fuel and global demand for U.S. LNG. But in an unconstrained LNG export scenario, domestic gas prices would rise 31% in 2050, it found, boosting natural gas bills for U.S. households by more than $100 a year with prices varying by region.
The study is meant to inform Energy Department decisions on new permits to export the gas. The department is required by law to determine whether exports are in the public interest.
Liquefied natural gas is natural gas that has been super-cooled to a liquid state, reducing its volume and allowing it to be transported to places pipelines do not reach.
When asked whether the results of the study would give LNG opponents legal grounds to challenge new LNG export permits in court, a DOE official, speaking on condition of anonymity, told reporters it should first be a consideration for any U.S. energy secretary. The official added that proponents of being cautious on LNG have a variety of recourses in Congress and in the courts, which the study could inform.
The study said while Europe has been the top destination for U.S. LNG since 2016, especially as the region weans itself off gas from Russia after its 2022 invasion of Ukraine, global demand and the destination of U.S. LNG in the future is less certain.
“European policies are moving to reduce the use of fossil fuels, including natural gas,” the study said. “Demand for natural gas and LNG in Asia is expected to increase in most scenarios.”
LNG supporters said the U.S. study was influenced by politics in an election year.
A study by S&P Global also released on Tuesday said U.S. LNG has contributed more than $400 billion to U.S. GDP over the past decade, supporting about 273,000 jobs and will add about 495,000 jobs through 2040.
“LNG exports are not only in America’s national interest, but also in the world’s interest, including our European allies seeking to break free from dependence on Russian gas,” the U.S. Chamber of Commerce said in a release about the Biden administration study. (3)
A left-tiling view of the news from The Hill, required reading in the D.C. swamp:
Domestic energy prices would sharply increase if the U.S. conducts unrestricted exports of liquefied natural gas (LNG), the Department of Energy said in a long-awaited report released Tuesday.
The report comes nearly a year after the Biden administration announced a pause on new LNG exports, which surged after Russia invaded Ukraine and set off a scramble for other sources of European energy. The department announced the pause as part of an effort to determine the economic and environmental effects of exports.
The report determined that unregulated exports could lead to a spike of up to 30 percent in wholesale natural gas costs while also creating an extra 1.5 gigatons a year of greenhouse gas emissions by 2050.
“To date, U.S. consumers and businesses have benefited from relatively stable natural gas prices domestically as compared to those in other parts of the world who have faced far greater price volatility,” Energy Secretary Jennifer Granholm said in a statement. “[But] the more volumes of U.S. LNG are exported, the greater the risk of this global price volatility being imported into our domestic market and impacting U.S. consumers and manufacturers.”
The pause did not affect existing export approvals, which are currently sufficient to generate about 15 billion cubic feet a day.
The report is subject to a 60-day comment period, which will stretch into the second Trump administration. Chris Wright, Trump’s nominee for Energy secretary, is CEO of fracking company Liberty Energy and his nomination has been well-received by industry figures.
The report was hailed by environmental organizations and sharply rebuked by the gas industry.
“These studies show clearly that LNG exports are in gas executives’ best interest and nobody else’s,” said Lauren Parker, an attorney at the Center for Biological Diversity’s Climate Law Institute, in a statement. “Exporting fracked gas worsens climate change, harms wildlife and raises prices for U.S. consumers. The studies find current supply meets all domestic and global energy needs. Expanding LNG hasn’t been in the public interest for a long time. If Trump wants to drive up dangerous gas exports, he’s going to have to answer for causing more deadly storms, condemning the Rice’s whale to extinction, and socking consumers with higher costs.”
American Gas Association President and CEO Karen Harbert, meanwhile, blasted the report as “a clear and inexplicable attempt to justify [the Biden administration’s] grave policy error.”
“We look forward to working with the incoming administration to rectify the glaring issues with this study during the public comment period,” Harbert added. (4)
Reporting from the more conservative Washington Examiner:
Energy bills would shoot up as a result of increased exports of liquified natural gas, the Energy Department projected in a highly anticipated report released Tuesday, seemingly marking the end of the saga that has been the Biden administration’s pause on approvals of new LNG export projects.
With President-elect Donald Trump’s inauguration just over 30 days away, the last-minute release of the report appears to be the Biden administration’s last-ditch effort to block additional approvals, complicating the Republican’s plans to increase LNG exports while in office. Ending the pause was a top priority for the oil and gas industry.
The report, which will now undergo a 60-day public comment period, determined that increased LNG exports would drive up costs for consumers, increase global greenhouse gas emissions, and even offer support to China.
It stops short, though, of recommending banning LNG exports, indicating that exports at some level are still within the public’s best interests.
“Further increasing exports, unconstrained, would surely generate more wealth for the LNG industry, but American consumers and communities and our climate would pay the price,” Energy Secretary Jennifer Granholm told reporters ahead of the study’s publication.
In a letter released in tandem with the report, the secretary warned that the analysis found that current LNG exports were “neither sustainable or advisable,” claiming “unfettered exports” could drive up domestic gas prices by 30%.
“Those are the facts, and the final decision, of course, is now in the hands of the next administration,” Granholm said Tuesday. “We hope that they’ll take these facts into account to determine whether additional LNG exports are truly in the best interest of the American people and economy.”
While the department is now moving forward with the public comment period, a senior DOE official told reporters it has no intention to revise the report after receiving comments, calling the study “final.”
In January, the Biden administration initiated a pause on new LNG export approvals to countries without free trade agreements to conduct the study.
Many questioned the timing of the pause, as it came around the same time Venture Global LNG sought approval to build a $10 billion facility in Louisiana that would allow the United States to export massive quantities of LNG.
Critics have lambasted the pause as unconstitutional, while environmentalists have praised the move as a way to reduce emissions. In July, the freeze was overturned by a federal judge in Louisiana after several Republican states claimed it would hurt their economies. One month later, DOE officials said they would appeal the decision.
When pressed on whether the release of the report marked the official “end” of the original pause, a senior DOE official told reporters that the administration was in compliance with all court orders regarding the matter and approved an export authorization application for an LNG project in August. Given pending litigation challenging the summer overturn of the pause, the official declined to comment further.
The report specifically estimates that increased exports of LNG could lead to the average family seeing its gas and electricity bills increase by $122.54 per year by 2050. It found that higher LNG export levels were associated with higher domestic gas prices, with prices rising by around 4%. In the same time frame, though, the analysis projected, exports could also result in a 0.2% increase in GDP. Authors of the report pointed to that, adding that an increase in GDP “does not necessarily correlate with a positive effect on broader public and consumer welfare.”
Regarding emissions, the study found that if LNG exports exceeded currently authorized levels, associated direct emissions would be around 1.5 gigatons per year by 2050 — roughly equivalent to a quarter of all emissions generated in the U.S. annually currently. Additionally, the report found that increased natural gas production within the U.S. would increase toxic air pollution, light pollution, contamination of waterways, and more.
The report also estimated that demand for LNG in Europe, the primary importer of U.S. LNG, will drop, while demand in Asia is expected to increase, with China leading the way.
Natural gas is considered to be a much cleaner fuel source than coal, as it is primarily composed of methane. However, methane emissions have a great impact on warming in the atmosphere, as methane is considered to be 80 times more potent than carbon dioxide. Methane emissions do have a shorter lifespan than other greenhouse gases, though environmental and climate activists have long expressed concerns over its ability to leak and release into the atmosphere at any stage of the production, export, and operation processes.
The U.S. has been exporting LNG since 2016, and in 2023, it became the largest exporter worldwide. Despite the pause on new project approvals, exports are only expected to grow.
Weeks before the report was released, several top Republican lawmakers sent a letter to Granholm urging the agency to halt its review, pointing to the results of the November presidential election. Led by House Energy and Commerce Committee Chairwoman Cathy McMorris Rodgers (R-WA), the lawmakers said they were worried the administration was rushing to publish the report to “intentionally hamstring the incoming administration’s ability to process LNG export applications in a timely fashion.”
“The results of the 2024 presidential election are clear, and DOE leadership will soon change,” the Republicans said. “As a traditional part of the peaceful transfer of power, DOE should immediately stop work on any plans to expand the scope of review or add new conditions to LNG export licenses.”
The Republican Party has long criticized the pause and the plans for the report, even going so far as to accuse the DOE of hiding a past LNG report they claim was conducted months before this year’s pause.
In October, House Committee on Oversight and Accountability Chairman James Comer (R-KY) claimed the committee learned that a study also looking at the economic and environmental impacts of LNG exports was, in fact, conducted in 2023. Comer said the DOE failed to provide information about this study, instead telling the committee that it did not find a “final LNG export study” earlier that same month.
However, Comer insisted that department officials did previously admit in September that documents may exist in response to a FOIA request about any LNG study.
“Transparency on this issue is essential,” Comer said. “DOE’s action has thrown vital U.S. businesses—companies that invest billions in capital in long-term projects, support tens of thousands of U.S. jobs, and bolster the energy security of our allies—into turmoil as they grapple with uncertainty from politically-motivated federal actions.”
It remains unclear how much of an impact the report will have on the incoming administration, as Trump has repeatedly proclaimed his intentions to reverse the Biden administration’s pause on export approvals. On whether it would have an effect at all, Anne-Sophie Corbeau, a global research scholar with the Center on Global Energy Policy at Columbia University, told the Washington Examiner via email, “I very much doubt so.”
Corbeau suggested the incoming administration will likely ask the DOE to still expedite approval for LNG projects or even suggest foreign nations purchase U.S.-produced LNG “in exchange of a better treatment in terms of tariffs.”
“That still does not solve the methane emission problem … but I don’t think this administration cares, and whatever issue it may create for future LNG exports to Europe will be felt after their time (2030+),” Corbeau said.
Still, others have said the administration will not be able to ignore its findings. Senior associate with the Energy Security and Climate Change Program at the Center for Strategic and International Studies Ben Cahill told the Washington Examiner that the report may affect the speed at which Trump implements his oil and gas agenda.
“It’s going to be a very substantial study,” Cahill said. “I don’t think the Trump administration can ignore it. It may complicate the desire of the Trump administration to make big changes on Day One and return full speed ahead permitting as many projects as possible.” (5)
O&G and business groups, including the Marcellus Shale Coalition, panned the study:
The American Petroleum Institute (API), the Marcellus Shale Coalition (MSC), and the U.S. Chamber of Commerce on Tuesday called on the Biden administration to lift its temporary pause on liquefied natural gas (LNG) exports from the United States, just as U.S. Energy Secretary Jennifer Granholm warned that increasing those exports could be economically detrimental to America’s consumers and manufacturers.
Responding to the U.S. Department of Energy’s (DOE’s) newly released study on the impacts of such exports, the organizations say the time is now for the federal government to move forward with exports of U.S. LNG.
“It’s time to end this blatant political charade from the Biden administration and start processing LNG export permits,” said MSC President David Callahan on Tuesday, referring to the permit freeze issued in January. “Lifting the permit freeze helps the U.S. achieve both domestic and international policy goals.”
“Abroad, U.S. LNG exports enhance energy security and environmental advancement,” Callahan added. “At home, exports promote jobs across the natural gas value chain and deliver energy savings for consumers.”
API President and CEO Mike Sommers agreed, saying it’s time to restore American energy leadership around the world.
“After nearly a year of a politically motivated pause that has only weakened global energy security, it’s never been clearer that U.S. LNG is critical for meeting growing demand for affordable, reliable energy while supporting our allies overseas,” said Sommers.
Multiple independent studies have proven the net benefits of continued LNG exports for strengthening the economy, driving climate progress, and bolstering global energy security, Sommers said.
The DOE’s report, entitled “2024 LNG Export Study: Energy, Economic, and Environmental Assessment of U.S. LNG Exports,” is a multi-volume study that updates DOE’s understanding of the potential effects of U.S. LNG exports on the domestic economy; U.S. households and consumers; communities that live near locations where natural gas is produced or exported; domestic and international energy security, including effects of U.S. trading partners; and the environment and climate.
The report is not intended to serve as a forecast of U.S. LNG exports and impacts, according to the report’s 58-page summary. Rather, it is an exercise exploring alternative conditional scenarios of future U.S. LNG exports and examining their implications for global and U.S. energy systems, economic systems, and greenhouse gas (GHG) emissions.
Granholm said Tuesday that the Energy Secretary, with authority from the Natural Gas Act, has the responsibility to evaluate whether authorizations for the export of LNG to non-free-trade-agreement countries is consistent with the public interest.
The DOE analysis, she said, exposes “a triple-cost increase to U.S. consumers” from increasing LNG exports: the increasing domestic price of the natural gas itself, increases in electricity prices (natural gas being a key input in many U.S. power markets), and the increased costs for consumers from the pass-through of higher costs to U.S. manufacturers.
“Special scrutiny needs to be applied toward very large LNG projects,” Granholm said. “An LNG project exporting 4 billion cubic feet per day — considering its direct life cycle emissions — would yield more annual [GHG] emissions by itself than 141 of the world’s countries each did in 2023.”
The demand for LNG in the People’s Republic of China (PRC) — already the world’s largest importer — is expected to nearly double between now and 2030 and become the highest of any country by 2050, she added, noting that PRC entities have already signed several contracts with operating or proposed U.S. LNG projects.
“In the decade to come, we will see strong and mounting pressure within our democratic system to ensure that the United States uses its market position in a way that truly advances our national interest and energy security, which must include the needs of American workers, American families, and our responsibility to address the climate crisis,” said Granholm. “In our view, the question is not whether U.S. export policy will be forced to respond to those interests, but when and what that response is.”
Differing perspectives
According to the U.S. Chamber, the DOE study conflicts with independent data and analyses confirming U.S. LNG exports are key to global decarbonization and have little to no impact on domestic prices.
“We will thoroughly review the DOE report, but it appears to rely on questionable methodology and puts a thumb on the scale to downplay the clear economic, environmental and security benefits of U.S. LNG,” said U.S. Chamber of Commerce Senior Vice President of Policy Marty Durbin. “This contradicts many other analyses that detail the benefits of LNG exports—including Phase 1 of the Chamber-supported study released today by S&P Global.”
S&P Global says in its report, A U.S. LNG Impact Study – Phase 1 , released Dec. 17, that U.S. LNG exports have had no major impact on domestic natural gas prices.
In fact, the report says, America’s tremendous natural gas resources have supported U.S. domestic natural gas production growth of over 40 bcf/d since 2010, dwarfing LNG export growth by a 3 to 1 ratio, while driving a sustained reduction in U.S. prices.
“These significant reserves were unlocked by the combined effect of two technologies: hydraulic fracturing and horizontal drilling (collectively referred to as the Shale?Revolution),” the report says. “U.S. domestic wholesale gas prices have continued their downward trend, interrupted only temporarily by the combination of rapid post-COVID growth and Russia’s invasion of Ukraine in 2022.”
Importantly, the S&P report says, is that the U.S. LNG industry is critical to serving the world’s energy needs and has rapidly become an integral contributor to the U.S. economy.
For example, it is the source of $408 billion in GDP contribution since 2016, supporting an average of 273,000 direct, indirect, and induced U.S. jobs, and as of 2023, U.S. LNG has larger revenues than U.S. corn and soybean exports, roughly double U.S. movie and TV-related exports, and half of U.S. semiconductor exports.
It is also the No. 1 global supplier meeting the world’s energy needs, including replacing almost half of lost Russian gas into Europe.
S&P Global also reported that U.S. LNG industry growth is expected to double its U.S. economic footprint through 2040 with $1.3 trillion in GDP contribution supporting an average of 495,000 direct, indirect, and induced U.S. jobs; $2.5 trillion in revenues for U.S. businesses, over $900 billion in expenditures, $165 billion in tax revenue, and $250 income per year per household.
“However, an array of regulatory and legal risks is jeopardizing more than $250 billion in incremental GDP and over 100,000 jobs annually through 2040,” says S&P Global. “Furthermore, if U.S. export growth potential were not to materialize, 85 percent of the resulting gap would be filled by fossil fuels from outside the U.S.”
“Regulatory and legal uncertainty, beyond potential lifting of the LNG pause, is putting growth at?risk,” the firm says.
Conversely, Energy Secretary Granholm said that U.S. LNG exports have already tripled over the past five years, will double again by 2030, and could double yet again under existing authorizations.
“The quantities already approved for export equate to roughly half of the U.S.’s total current natural gas production today,” she said. “In four of five modeling scenarios included in today’s study, the amounts that have already been approved will be more than sufficient to meet global demand for U.S. LNG for decades to come.”
And while these “dramatically increasing LNG exports” generate wealth for the owners of export facilities and create jobs across the natural gas supply chain, Granholm said the DOE’s updated study finds that a wide range of domestic consumers of natural gas — from households to farmers to heavy industry — would face higher prices from increased exports. Specifically, the DOE study found that “unfettered exports of LNG” would increase wholesale domestic natural gas prices by over 30 percent, she pointed out, while unconstrained exports of LNG would increase costs for the average American household by well over $100 more per year by 2050.
The U.S. Chamber underscored that S&P Global’s study, in contrast, stated that continued export growth will have a negligible impact on U.S. residential natural gas prices (less than 1%).
“LNG exports are not only in America’s national interest, but also in the world’s interest, including our European allies seeking to break free from dependence on Russian gas,” said the U.S. Chamber’s Durbin. “From the beginning, the White House moratorium on new LNG export facilities was a politically-driven exercise with harmful impacts on the U.S. economy and the energy security of America’s allies. It should end immediately.”
The DOE study will have a 60-day comment period that will begin once published in the Federal Register. (6)
You may have read (several times) in the articles above about a second study also released yesterday by S&P Global. We discuss that countering study in our next post—a study that crushes the study issued by the DOE.
(1) Ronald Reagan Presidential Library & Museum (accessed Dec 18, 2024) – Inaugural Address 1981
(2) U.S. Department of Energy (Dec 17, 2024) – U.S. Department of Energy Completes LNG Study Update, Announces 60-Day Comment Period
(3) Reuters/Timothy Gardner (Dec 17, 2024) – Biden administration releases LNG export study, urging caution on new permits
(4) Washington (DC) The Hill/Zack Budryk (Dec 17, 2024) – Energy Department says unrestricted natural gas exports would spike prices
(5) Washington (DC) Examiner/Callie Patteson (Dec 17, 2024) – Biden administration makes late bid to curb LNG exports with long-awaited report
(6) Pennsylvania Business Report/Kim Riley (Dec 17, 2024) – Dueling positions contradict effects of lifting pause on U.S. LNG exports
