The Faulty Logic at the Heart of Environmentalist Opposition to BAAJA

Scary Emissions Numbers Depend on Energy Pessimism

In the weeks since the text of the Bipartisan American Affordability and Jobs Act (BAAJA) was released, environmentalist opponents have scrambled to develop their oppositional talking points to the permitting package. After some awkward attempts at messaging discipline, the green groups have settled on a strategy: deny the clean energy benefits, and fixate instead on how BAAJA will lock-in fossil fuel infrastructure going forward through its permitting certainty provisions.

The Center for Biological Diversity—a hyperactive litigant against clean energy, transmission, forest management, and more—called BAAJA “a climate kill shot” that “would provide massive long-term structural advantages to the fossil fuel industry.” Tyson Slocum, Energy Program director at Public Citizen, suggested the bill would “guarantee increased domestic oil and gas fracking to feed [ever-increasing] fossil fuel exports.” Jeremy Symons, President of the Center for Energy and Environmental Analysis, argued that BAAJA could “permanently block future administrations from undoing Trump’s efforts to gut health, safety, and climate protections across the government.” And there has been a quieter push from environmental groups, who after early public criticism of BAAJA, have gone to their allies on the Hill with their narrative of the Bill’s climate doom.

Since these reflexive pronouncements, more modeling has been released, which shows the ways in which BAAJA’s passage is likely to lower, not raise, emissions. Fresh modeling from Resources for the Future and the Solar Energy Industries Association pegs power sector emissions benefits at around 114 million and 300 million tons of CO2 reductions per year over the next decade, respectively.

Of these estimates, vocal BAAJA opponent Pete Sikora tweeted “a model will spit out whatever you want based on various plausible assumptions.” That is indeed a fair caution to keep in mind when evaluating any modeling or forecasting exercises. It’s with this caution in mind that we revisited Jeremy Symons’ 2024 anti-permitting reform modeling which, true to form, spits out whatever Symons wants, though the assumptions are far from plausible.

When the Energy Permitting Reform Act of 2024 (EPRA) was being debated, Symons used worst-case assumptions and outright motivated reasoning to make eye-popping estimates of the bill’s emissions implications. When such motivated reasoning is corrected, the emissions conclusions drop by as much as 80% even within Symons’s own baroque modeling framework.

His fingerprints betray a clear fixation on maximally pessimistic oil and gas effects from permitting reform, while willfully ignoring the clear upsides for clean energy, transmission, and decarbonization. So as analysts and lawmakers debate BAAJA’s passage in the coming weeks, they should consider that many permitting critics have little interest in the full range of policy outcomes—but rather only in results that provide cover for their preferred arguments.

Garbage Assumptions In, Garbage Results Out

In his critique of EPRA, Symons estimated that, through 2050, accelerated approvals for new LNG export capacity under EPRA would increase annual global emissions by between 273 and 413 million metric tons of CO2 equivalent (reported using the 20-year global warming potential of methane).

Those are not insignificant numbers. At the upper end, they would amount to a little under 7% of current annual U.S. fossil greenhouse gas emissions. But the finding depends on a series of assumptions about how much LNG capacity EPRA would have actually enabled, how that capacity would be utilized, and what fuels American natural gas would displace overseas.

But as it turns out, those methodological assumptions were heavily and pessimistically skewed.

Symons speculated that all proposed US LNG capacity in final and mid-stage permitting would be approved directly as a result of EPRA, and that all those projects would enter operation in 2030 at a consistent 83% utilization rate, putting a total of 10.26 billion cubic feet per day (Bcf/d) of LNG into global markets for the whole 20-year analysis period.

When it comes to setting defaults for those net emissions levers, Symons assumes that U.S. LNG exports heavily displace clean energy production, without ever displacing coal or Russian gas. In a higher-end “Net Change from 1.5C Scenario” net emissions case where the world aggressively targets net-zero emissions by 2050 with high clean energy adoption, he assumes that 91% of exported U.S. LNG from 2030-2050 would displace clean energy, while only 9% will displace gas in the global market, and none will replace either Russian gas, or new coal consumption.

In 2022 the power sector accounted for only 39% of global gas consumption. In the same IEA Net Zero Emissions scenario that Symons references, the power sector accounts for 42% of global gas demand in 2030, falling to 12% of global gas demand in 2050. In 2050 the same scenario envisions 55% of global gas consumption occurring in conjunction with carbon capture, with 36% of total gas demand supplying low-carbon hydrogen production. So according to the same aspirational IEA pathway that Symons himself picked as a yardstick to judge US LNG approvals against, a large global gas market still exists in 2050, integrated closely with a low-carbon economy and extending well beyond the power sector.

Figure 1: Comparison of analyzed pending U.S. LNG export volumes relative to global annual average gas and LNG demand in IEA scenarios over the 2030-2050 period.

In an aggressive 1.5C decarbonization scenario where clean electricity is cheap and abundant—providing 99% of global power generation by 2050—the far more likely outcome would be that permitted LNG export volumes would simply go unused, stranding the terminal infrastructure. At the same time, even this 1.5C scenario allows for an average 2030-2050 LNG trade of 30 Bcf/d, leaving more room for US LNG to displace other global gas supplies than Symons accounted for.

Meanwhile, Symons’s justification for why U.S. gas never displaces coal amounts to a fig leaf. He handwaves that China is the biggest offtaker and financier of U.S. LNG projects and asserts “there is no evidence that LNG has displaced coal globally or in China,” pointing to the 2015 to 2023 period when China’s electricity generation from wind and solar grew 12%, while coal’s share decreased by 9%, and the share of natural gas generation remained unchanged. But, Symon’s statistics only indicate that wind and solar electricity is growing faster in China than electricity from coal and natural gas. It does not mean that LNG-fired electricity generation in China isn’t increasing in place of some coal, or that LNG isn’t displacing Chinese coal in other sectors like heavy industry.

Even still, Chinese trends are separate from LNG’s ability to displace coal in the EU, other East Asian countries, or markets like India or Southeast Asia.

Similarly, Symons assumes US LNG exports will never displace Russian gas. Even considering Russian LNG exports alone, the EU has consumed 49% of Russian LNG exported since the start of EU sanctions on Russia in December 2022, with another 24% purchased by China, 18% by Japan, and 6% by South Korea. As such, continued opportunities exist for US LNG to displace Russian shipments in the global market, particularly for US allies like Japan and Korea.

The decisive factor is that Symons’s emissions calculations are not remotely robust to different assumptions regarding global consumption patterns of exported U.S. LNG. Modest tweaks to the Symons model dramatically slash emissions impact from fossil fuels estimates from ~7% to just 1% of current U.S. annual emissions. This high sensitivity of Symons’s model in fact testifies to how permitting reform’s benefits for clean energy deployment can very easily start to dominate the balance of outcomes.

First, we assumed, given an aggressively decarbonizing “1.5C pathway” where clean energy technologies are cheap and highly competitive, that some U.S. LNG capacity will start failing to secure buyers and become stranded. In this case, LNG utilization drops to an average of 66%.

We also assumed that the U.S. controls methane leakage to 1.9% by 2050, a rate approaching the current global average, resulting in an average leakage rate of 2.35% from 2035-2050.

Our pessimistic Case 1 assumes only half of U.S. exports displace clean power while allowing for 5% of exports to displace Russian gas. With a methane leak adjustment, Case 1 is 55% lower than Symons’s original net emissions result. A bolder Case 2 assumes that of every 10 export units, only 2 units displace clean power with 1 more unit displacing coal. This drops annual net emissions 80% lower than Symons’s original result.

Figure 2: Symons Public Affairs claimed annual net emissions impacts attributed to U.S. LNG exports enabled by EPRA relative to a “Net 1.5C Scenario”, versus lower calculated emissions impacts using more realistic global LNG market assumptions. Annual net emissions contrasted against multiple quantifications of clean energy benefits associated with nationwide transmission expansion. All emissions values in GWP100.

Factoring in the Clean Energy Benefits of Permitting

Symons’s original analysis highlighted results framing emissions from U.S. LNG exports in terms of “Renewable Transmission Negated.” Presumably, he used this statistic to argue to policymakers that emissions enabled by the EPRA permitting reform bill would vastly outweigh climate benefits. But if more reasonable assumptions dramatically reduce the calculated harms from U.S. LNG, what happens to the net balance?

Symons used an environmental impact statement for the TransWest Express Transmission Project, a 3000 MW, 732-mile transmission line “that will deliver renewable energy from Wyoming to southern Nevada,” with the Bureau of Land Management estimating that the line could reduce emissions by 12.2 million metric tons of CO2 per year, assuming the line were to carry around 80% renewable energy. This headline calculation, which Symons advertises as a primary output of his analysis, implies that every 1000 GW-miles of renewable transmission capacity displaces 5.56 million metric tons of CO2 per year.

Past analysis by Princeton’s REPEAT project estimated that relative to the constrained transmission status quo, an unconstrained transmission scenario might build 30,000 GW-miles of additional transmission by 2030, rising to a delta of 50,000 GW-miles by 2035, to accommodate added renewable energy buildout under the Inflation Reduction Act (IRA). Even just the lower figure of 30,000 GW-miles of additional transmission capacity by 2035 would imply an annual emissions reduction of 167 million metric tons of CO2 by Symons’s own conversion factor—swinging the calculus of the LNG versus transmission permitting tradeoff strongly towards a net climate benefit.

Or consider two DOE studies from 2024: The National Transmission Planning study (NTP) and Transmission Impact Assessment (TIA). Both modeled emissions in a transmission-constrained intraregional scenario and under an unconstrained scenario with interregional transmission. The NTP and TIP estimate, respectively, that interregional transmission could avoid an average of 359 and 190 million metric tons of CO₂ annually between 2030 and 2050. Even as rough upper bounds for BAAJA’s transmission benefits, these more than negate potential emissions from Symons’s modeled LNG projects.

Our thought experiments regarding emissions reductions from U.S. transmission buildout are imprecise and only marginally more sophisticated than Symons’s, but they underline the importance of considering the positive impacts of permitting reform. Symons’s analysis was framed around EPRA, but LNG remains a central point of debate regarding the currently-available permitting proposal, BAAJA. Yet this recalculation produces results that suggest a net climate-favorable outcome—even before considering the fact that BAAJA, unlike EPRA, contains no explicit provisions aimed at LNG terminal projects, while offering countless other positives to clean energy projects.

Overblaming Fossil Projects on Permitting Reform

Finally, opponents to permitting reform who argue that legislation like EPRA or BAAJA will result in fossil fuel infrastructure being built ignore the likelihood of that infrastructure being built with or without the passage of a permitting package.

Take Symons’s model. He calculated the carbon footprint of eight LNG projects likely to be impacted by EPRA—a total of 12.37 billion cubic feet per day of capacity. These eight projects were impacted by the Biden Administration’s “pause” on approving requests to export LNG to non-free trade agreement countries. EPRA would have required DOE to approve or deny them within 90 days.

A rigorous policy analysis measures its impacts by asking, “what activity does this policy enable that wouldn’t have happened otherwise?” So when Symons and company assumed that passing EPRA would generate emissions equal to those generated from approving eight LNG export permits, they logically ceded the belief that, if EPRA were to not pass, they’d expect DOE to not approve any of them!

In our present timeline, EPRA did not become law. Since Symons released his analysis, DOE nevertheless approved non-FTA export permits for five of the eight LNG projects in two years, implicating up to 65% of Symons’s projected emissions which he had attributed to EPRA. Four projects are under construction, and one is already in service.

Figure 3: Present-day status of the eight LNG terminal projects whose LNG export capacity Symons attributed to the potential passage of EPRA.

The Mid-Transition Is Messy

Blocking permitting reform will not stop the fossil fuel infrastructure that environmentalists fear. That infrastructure, such as the LNG export capacity approved by the federal government despite EPRA’s failure in Congress, continues to move through the permitting process. Stonewalling BAAJA will instead preserve obstacles impeding the clean energy buildout, by maintaining the permitting, interconnection, and regulatory barriers that effectively handicap clean energy relative to fossil fuels.

BAAJA would begin to level the permitting playing field. It includes provisions to accelerate power plant interconnection queues, grant onshore and offshore wind protection from arbitrary federal obstructionism, facilitate small hydropower projects, streamline permitting for geothermal energy, accelerate solar and wind permitting on federal lands, and establish wholesale electricity market access for distributed solar and wind resources. Many of these provisions could produce not only national but global emissions benefits that would be foreclosed by blocking the package.

Thus, the climate case opposing permitting reform is weaker than its advocates claim. The level-headed diagnosis is that the most affordable electricity system in the mid-transition—where we are now—is a mix of renewables, gas generation, and clean firm power. Gas plants will likely need to continue to operate, although progressively less and less as the share of clean power and storage rises. That leaves a continued means for natural gas exports to displace coal over time, as emerging economies leverage clean power sources alongside gas generation to decisively push coal plants into retirement. According to Symons’ own model, all it would take for US LNG exports to be net decarbonizing would be for around 30% of exported volumes to displace coal, with 70% displacing other gas in the global market.

The exact net climate benefits of permitting reform are not preordained. As the impressive declines in renewable prices over the last two decades, the AI-driven boom in energy demand, and the supply shocks caused by conflicts in Ukraine and the Gulf all demonstrate, the energy and emissions future is likely to be far messier than Symons, Resources for the Future, or any other forecaster would suggest. But what matters is less the precise forecast two decades from now, and more which way credible assumptions point, and here they point toward reform.

Congress should pass BAAJA. Environmental groups serious about deploying clean energy at the scale the climate requires should be fighting to strengthen the bill, not to kill it.