On May 19, 2025, the Department of Energy (DOE) finalized its 2024 LNG Export Study: Energy, Economic and Environmental Assessment of U.S. LNG Exports (the 2024 Study) through the release of a Response to Comments on the 2024 Study. The Response to Comments concludes that the 2024 Study, as augmented through public comments submitted on or before March 20, 2025, supporting a finding that liquefied natural gas (LNG) exports serve the public interest. With the comment process complete, DOE will move forward with final orders on pending applications to export LNG to non-free trade agreement (non-FTA) countries.
Under Section 3(a) of the Natural Gas Act (NGA), the DOE must approve export requests to non-FTA countries unless it finds that the proposed export will not be consistent with the public interest. The 2024 Study was the most recent study commissioned by the DOE to inform its statutory public interest findings. The DOE’s Response to Comments addressed over 100,000 public comments on the 2024 Study, which were submitted by LNG industry stakeholders, natural gas industry participants, the general public, academics, think-tanks and environmental non-governmental organizations. It concluded that the United States has sufficient natural gas supply to support growing LNG exports without significantly affecting domestic prices. It found that increased exports are projected to boost gross domestic product, create jobs, improve the trade balance, and strengthen both global and domestic energy security with no discernable impact to global greenhouse gas (GHG) emissions. The 2024 Study initially had been commissioned under former President Biden after his administration had paused LNG exports pending further study. 1
General Study Scope
The Response to Comments clarified that the 2024 Study does not redefine the scope of the DOE’s public interest review under NGA Section 3(a). Rather, it states that DOE will continue to operate under a rebuttable presumption favoring LNG exports, consistent with the agency’s long-standing precedent, including its 1984 Policy Guidelines, 2 with the 2024 Study serving as one input among many. These factors include the domestic need for the natural gas proposed for export, economic impacts, and the energy security of U.S. allies and partners. DOE also affirmed that its consideration of economic and energy security factors aligns with Executive Order 14154.
Global Energy and GHG Implications
In response to concerns about the emissions and fuel displacement modeling in the 2024 Study, DOE underscored that its scenario-based approach is designed to reflect a wide range of plausible global policy and market conditions. Environmental organizations challenged the plausibility of long-term LNG demand forecasts in certain regions and warned of “lock-in” effects if LNG displaces renewables. Meanwhile, industry stakeholders argued that the study underestimated long-term demand growth driven by data centers, population growth and fuel-switching in Asia and Europe. DOE emphasized that modeled emissions increases were relatively small as a percentage of total global emissions and emphasized the uncertainty inherent in projecting complex market effects decades into the future. The agency found that increased U.S. LNG exports are more likely to displace other sources of natural gas, coal, and oil than to replace renewable energy, with all modeled scenarios showing greater displacement of fossil fuels than of resources like wind and solar. While the 2024 Study provides insights into potential emissions implications, DOE concluded in the Response to Comments that it cannot definitively determine whether GHG emissions would increase with higher levels of U.S. LNG exports. Furthermore, DOE stated that the emissions outcomes described in the 2024 Study are not expected to affect its public interest determinations in pending or future non-FTA export authorizations.
Domestic Energy Economic Assessment
The Response to Comments addressed criticism of the 2024 Study’s models, which assessed the impacts of LNG exports on domestic natural gas prices emissions under various scenarios. While defending the models themselves, the DOE acknowledged that different inputs not present in the modeling, such as limitations on available pipeline infrastructure, may influence pricing outcomes, and could be a primary driver of localized price effects more than export volumes alone. DOE agreed with certain commenters that more efficient interregional pipeline connections could reduce regional price differences. DOE also recognized that natural gas development and LNG export infrastructure contribute to economic growth, job creation and tax revenues, and confirmed that household energy cost increases are projected to be modest and within the model’s margin of error.
Consequential GHG Analysis
The 2024 Study’s consequential emissions analysis received significant attention, and DOE reiterated in the Response to Comments that it does not intend to use these estimates as a binding element in export determinations. DOE responded to criticism from environmental groups that the 2024 Study’s reliance on bottom-up methane leakage resulted in lower modeled emissions estimates than top-down research indicates. It stated that the agency’s assumptions are consistent with available data and that top-down studies cannot easily isolate natural gas-related emissions, particularly in oil-and-gas co-producing basins. Natural gas producers, on the other hand, highlighted modeling that showed U.S. LNG displacing coal and fuel oil globally, yielding net reductions in emissions. DOE emphasized the uncertainty and scenario-dependence of displacement effects and concluded that the emissions outcomes, while informative, are not dispositive for public interest determinations.
Energy Security
DOE affirmed that energy security considerations remain a central element of its public interest analysis. The agency recognized that U.S. LNG exports enhance the energy resilience of allies, especially in the wake of geopolitical disruptions such as Russia’s invasion of Ukraine. DOE agreed with commenters who emphasized that LNG exports reduce reliance on adversarial suppliers, enhance market flexibility through destination-free contracts and bolster the strategic influence of the United States. DOE reiterated that market forces decide which projects are developed.
Key Takeaway and Next Steps
The release of DOE’s final response to comments on the 2024 LNG Export Study follows a series of recent actions from the agency to accelerate LNG project approvals and reduce regulatory barriers, some of which have been discussed in prior Akin posts. In addition to issuing conditional authorizations earlier this year for major United States Gulf Coast export projects, DOE rescinded a 2023 policy that had imposed strict criteria for extending commencement deadlines. With the 2024 Study finalized and DOE concluding that LNG exports “will not be inconsistent with the public interest,” DOE reaffirmed its view that LNG strengthens U.S. energy security, supports domestic production, improves the trade balance, and enhances the resilience of allied nations. DOE added that it is now positioned to issue final orders on pending applications to export LNG to non-FTA countries. Since January 2025, DOE has issued two conditional authorizations for exports from LNG terminals, both of which were conditioned on the outcome of the 2024 Study. 3
1 See Akin’s client alerts, The US Department of Energy Releases its Long-Awaited Energy, Economic and Environmental Assessment of US LNG Exports (December 19, 2024) and Implications of US Department of Energy Decision to ‘Pause’ Authorizations of Liquefied Natural Gas Exports May Extend Beyond Delays to Pending Projects (January 31, 2024).
2 U.S. Dep’t of Energy, New Policy Guidelines and Delegations Order Relating to Regulation of Imported Natural Gas, 49 Fed. Reg. 6684 (Feb. 22, 1984).
3 See Golden Pass LNG Terminal LLC, DOE/FE Order No. 3147, as amended (Docket No. 12-88-LNG) (issued Mar. 5, 2025); see also Commonwealth LNG, LLC, DOE/FE Order No. 5238 (Docket No. 19-134-LNG) (issued Feb. 14, 2025).
