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Monday, 11/24/2025 1:08:19 PM

Monday, November 24, 2025 1:08:19 PM

Post# of 59476
Rarely do I disagree with Senor C on anything other than politics, but the "EXTENSION" request is not just an extension request. To review, the DOE approved the original order for FTA and NFTA extensions back in March of '25.

The May 2nd, 2025 request for an EXTENSION also changed the number of FLNG's from 4 to 3 and while on the surface that might seem like a no brainer, the new design for the 3 FLNG's allowed Delfin to produce the same volume as the 4 FLNGs with all sorts of environmental improvements such that they did not request a change to the volume that would be produced and originally granted. They noted that MARAD had been informed of the design changes but that they had not incorporated the changes into the DOE request that was approved by the DOE in March which still referenced 4 FLNG's

From the May 2nd, 2025 request for extension to the DOE:

As a result of these refinements, Delfin modified its Project as presented to MARAD to include only three,
rather than four, new-build FLNGVs that would each process in the nominal design case of
approximately 4.0 MTPA. In the optimized design scenario (reflecting an annual average based
on seasonal fluctuations in ambient temperature, partial contractor margins, and an estimated
production unit availability of 99 percent), each of the three FLNGVs would produce 4.4 MTPA
of LNG for export, for a total Project output for the three FLNGVs of 13.2 MTPA. This is
essentially the same LNG production capacity previously proposed and authorized for the
Project, but produced using three FLNGVs rather than four smaller ones producing 3.3 MTPA
each.

So, Delfin told MARAD about the changes to the number of FLNG's but did not incorporate that change into the DOE request that was approved in March, '25.


As previously noted, Delfin submitted to MARAD on January 27, 2025, a description of
all the refinements to the Project and their probable environmental impacts as detailed in a
revised and updated EIA, including the change to three FLNGVs. For DOE/FECM’s reference,
Delfin provides as Attachment 1 to this Request a chart from the public version of the EIA
summarizing the design refinements and the related conclusion (detailed in the rest of the EIA)
that the refinements overall reduced impacts and there were no significant new circumstances or
adverse environmental consequences that substantially differ from those originally evaluated in
the previously completed Final Environmental Impact Statement for the Project.

But then Delfin made another mistake of telling DOE that since MARAD had evaluated the environmental impact assessments, DOE need not consider it when approving the two-year extension request. Anyone think that that was a good strategy, that DOE wouldn't be a tad bit PO'd and that therefore the DOE might just be extra careful when reviewing the request resulting in an extended review process beyond the norm? Trust us, all good! Brass balls and a faux pas if you ask me.

This environmental conclusion, recently evaluated by MARAD as part of the DWPA License issuance, need not be considered by DOE in connection with this Request for an extension of time.

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