Emera CNG LLC, a would-be exporter of compressed natural gas to the Caribbean, has applied at the U.S. Department of Energy (DOE) for export authorization employing a “little guys to the front of the line” rationale.

Emera CNG, a unit of Nova Scotia-based Emera Inc., is seeking free trade agreement (FTA) and non-FTA export authorization. The former is routinely presumed to be in the public interest. For the latter, Emera CNG said the volume of gas it wants to compress and export is so small that it should be excused from the queue of much larger non-FTA liquefied natural gas (LNG) applicants cooling their heels in the hallways of DOE’s Office of Fossil Energy.

Emera wants to export up to 0.025 Bcf/d, or 9.125 Bcf per year, for a term of 20 years.

“Emera’s proposed export level is de minimis compared to the quantities studied in the 2012 LNG Export Study [conduced by DOE (see Daily GPI, Jan. 20, 2012)], but these exports and the facility itself will still have a positive economic impact, consistent with the NERA [Economic Consulting] Study’s analysis [see Daily GPI, Dec. 7, 2012],” Emera told DOE in its recently released late-November filing [13-157CNG]. “The quantity of natural gas to be exported is so minimal — approximately 0.036% of all domestic consumption based on 2012 data — as to have no practical impact on natural gas prices or supply in the U.S.”

Emera wants to export CNG via truck and oceangoing carriers from a compression and loading facility to be constructed within the Port of Palm Beach, FL. The facility would be served by the Riviera Lateral, a Chesapeake Utilities Corp. intrastate pipeline with an upstream connection to interstate pipeline Florida Gas Transmission.

The primary purpose of the project is to supply gas to power plants owned by an Emera affiliate in Grand Bahama, a trading partner of the United States. However, Emera said it “…anticipates a number of potential customers for CNG from the facility, all of whom are expected to be located within the Caribbean.”

Because the project would use trucks and oceangoing carriers for export, it is beyond the jurisdiction of FERC, Emera said in its DOE filing.

“The construction and operation of the facility will benefit the Palm Beach County economy in a number of ways,” Emera told DOE. “The facility will enhance the value of existing pipeline infrastructure and add to the local property tax base. During the development phase, the facility will generate jobs in the construction industry. During the initial operational phase, the facility will create a number of long-term jobs…”

Emera’s is not the only small-scale gas export project potentially held up by much larger projects in the DOE queue. DOE’s “order of precedence” for considering non-FTA export applications has tripped Carib Energy, a unit of Crowley Marine Corp.

Carib has been awaiting a non-FTA approval for small-scale containerized LNG export to the Caribbean. In an October filing at DOE, Carib’s lawyers said the DOE’s “order of precedence” for considering non-FTA export applications has disadvantaged Carib relative to other applicants. Carib’s application was next in line based upon the chronological order in which applications were filed. However, the order of precedence gives priority to applications for projects that received by Dec. 5, 2012 approval to use FERC’s pre-filing process, putting Carib about six places back in the queue, the company told DOE (see Daily GPI, Oct. 25).

In the latest turn of events in that case, a Nov. 18 letter to Carib’s lawyers from DOE said the agency “…intends to give further consideration to your request…” to process Carib’s application “next rather than taking up the application in the order of precedence…”