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Protest of Carib Energy Application to Re-Export LNG From Puerto Rico

By Tyson Slocum

The September 7 Request for Amendment and the September 21 Supplemental Information Supporting Request for Export Authorization Amendment filed by an affiliate of Crowley Holdings, Inc. requests a nearly 200% increase in its authorized export volume of previously imported foreign-sourced LNG, from 0.48 Bcf to 1.4 Bcf.[1] Crowley Holdings re-exports LNG that has been imported into Puerto Rico via its Truck Loading Facility adjacent to the EcoEléctrica LNG Terminal in Peñuelas, PR,[2] with the Federal Energy Regulatory Commission noting that “70% of the natural gas that is imported into Puerto Rico comes through” the EcoEléctrica facility.[3]

The Commonwealth of Puerto Rico is beset by acute shortages of natural gas essential for its domestic power and energy needs, as the island “consumes almost 70 times more energy than it produces”[4]. Crowley proposes a nearly 200% increase in diverting LNG supplies from the EcoEléctrica LNG Terminal, despite EcoEléctrica serving as the island’s largest LNG import facility. Shortages of natural gas in Puerto Rico force the island to increase its reliance on oil-fueled power. DOE is aware of Puerto Rico’s challenges with securing adequate LNG supplies for its domestic needs, as it was consulted last year on the Department of Homeland Security’s decision to grant a waiver from the Jones Act to allow critical supplies of LNG to reach the island.[5]

The U.S. Department of Energy is tasked by Congress to only permit exports of natural gas to non-FTA countries which are “not inconsistent with the public interest.”[6] Crowley’s Request and Supplement fail to establish that its proposed 200% increase in LNG exports is consistent with the public interest.

The Request and Supplement fail to demonstrate whether Crowley’s proposal for a nearly 200% increase in the redirection of LNG supplies from Puerto Rico will interfere with the island’s ability to procure adequate gas supplies for its domestic needs. Re-exporting LNG away from Puerto Rico could contribute to physical shortages on the island and cause price spikes for the island’s consumers. Crowley’s Request and Supplement only provide a generic discussion of total U.S. natural gas supply and demand with omission of any data on how its proposal to remove LNG supplies will impact Puerto Rico.[7]

Indeed, both Puerto Rico Governor Pedro R. Pierluisi and Government of Puerto Rico Electric Power Authority (PREPA) noted the importance of EcoEléctrica LNG storage tanks to fuel the on-site power plants that provide 40% of the island’s electricity. These letters are attached as Exhibits A and B, respectively.

Furthermore, the lone operating LNG import terminal in New England—Constellation’s Everett facility—competes with Puerto Rico for LNG imports from Trinidad and Tobago.[8] During last year’s Winter Storm Elliott, the New England power market was forced to rely on oil as the largest source of fuel (more than 30%) in part because it couldn’t procure adequate LNG supplies.[9] Crowley’s Request and Supplement neglects to provide any assessment of whether diverting LNG supplies from Puerto Rico may compete with Constellation’s Everett facility, and lead to higher oil use and more expensive LNG for new England ratepayers.

The full filing is available here: Carib

[1] www.govinfo.gov/content/pkg/FR-2023-10-06/pdf/2023-22297.pdf

[2] Supplement, at page 3.

[3] August 28, 2023 Order Approving Request To Increase Storage Tank Level, Docket No. CP95-35, at ¶ 5, https://elibrary.ferc.gov/eLibrary/filedownload?fileid=21D1831A-7879-C47D-9783-8A3E1F100000

[4] www.eia.gov/state/?sid=RQ

[5] www.dhs.gov/news/2022/09/28/statement-secretary-mayorkas-approval-jones-act-waiver-puerto-rico

[6] 15 USC § 717b(a).

[7] Supplement, at page 5.

[8] www.energy.gov/sites/default/files/2023-10/LNG%20Monthly%20August%202023.pdf

[9] https://twitter.com/naurtorious/status/1607205245779591170