Resource Development Council

RDC Comment Letter:
Alaska LNG Project

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November 5, 2014

Mr. John A. Anderson
Office of Fossil Energy
United States Department of Energy
Docket Room 3F-056, FE-50
Forrestal Building
1000 Independence Avenue, SW
Washington, D.C. 20585

Re: Alaska LNG Project, Docket No. 14-96-LNG

Dear Mr. Anderson:

The Resource Development Council (RDC) is writing in strong support of the application filed by the Alaska LNG Project LLC to export LNG to both Free Trade Agreement and Non-Free Trade Agreement countries.

RDC is a statewide, non-profit, business association comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism and fisheries industries. Our membership also includes Native regional and village corporations, local governments, organized labor and industry support firms. RDC’s mission is to help grow Alaska’s economy through the responsible development of natural resources.

No other single project in any industry is as important to Alaska’s economy as this $45 billion to $65 billion project, the largest integrated natural gas/LNG project of its kind. The project would provide significant economic benefits to Alaskans from the Arctic coast to the rainforest of the Southeast Alaska panhandle. Benefits include thousands of new job opportunities and access to a generation of domestically-produced natural gas for homes and businesses in the 49th state. The project is expected to generate 15,000 jobs during construction and 1,000 jobs for operation. The Alaska LNG project would have major economic benefits not only for Alaska, it would also have a positive impact on the United States as a whole.

The Alaska LNG Project faces unique challenges which set it apart from other projects in the Lower 48 states. As a result, the requested authorization of 20 million metric tons per year of LNG for a term of 30 years to support a project of this scope and size is necessary. There is no existing infrastructure for the Alaska LNG Project and each component must be built from the ground up. The project will face severe Arctic conditions and other unique challenges that may require a 12-year period to study, design, and build.

Given Alaska and its Arctic natural gas fields are geographically separate from the Lower 48, the Alaska LNG Project application should not be subject to the Department of Energy’s (DOE) existing Order of Precedence for Processing Non-FTA LNG Export applications nor should it be subject to any new procedures adopted as a result of DOE’s proposed procedural change for processing Non-FTA LNG export applications. This is consistent with DOE’s statement in Footnote 5 of the proposal that “this notice does not address the treatment of applications to export natural gas from Alaska.” The many unique factors facing the Alaska LNG Project require a conditional authorization that will allow the project to proceed with the commercial and engineering work necessary for development and construction of the project.

In addition, the existing Presidential Finding Concerning Alaska Natural Gas satisfies the Section 12 requirement of the Alaska Natural Gas Transportation Act that export of natural gas from Alaska “will not diminish the total quantity or quality nor increase the total price of energy available to the United States.” This Presidential Finding is valid and applicable to the Alaska LNG Project.

RDC believes that the export authorization the Alaska LNG Project is seeking is consistent with the public interest. We urge you to expeditiously approve this application.

Resource Development Council for Alaska, Inc.

cc: Governor Sean Parnell, Senator Lisa Murkowski, Senator Mark Begich, Congressman Don Young