Implications on US LNG and Fracking Industry of Lifting Russian Gas Sanctions
Introduction
Russia’s war in Ukraine reshaped global gas markets, with Europe pivoting sharply from Russian pipeline gas to imported LNG. US liquefied natural gas (LNG) exporters benefited as Europe became their biggest customer, supporting high export volumes and prices. Now, proposals to lift sanctions on Russian gas – allowing Russian pipeline flows to Europe to resume – raise critical questions for the US LNG and shale gas (fracking) industry. This report analyzes short- to medium-term (1–5 year) impacts on supply-demand dynamics, US LNG market share, pricing power, infrastructure utilization, and the financial viability of US gas producers. It incorporates fresh data (April 2025) on EU gas imports and presents scenario forecasts (status quo vs. sanctions lifted). The US LNG and fracking industry should worry about any Russia deal. Out of all the sanctions levied against Russia, lifting sanctions on Russian gas is Moscow’s top priority. If a Russia deal happens, it will include lifting gas sanctions. Russia likely will not agree to it without some relief to their gas sector (and damage to US industry).
Global and Regional LNG Supply-Demand Dynamics
Figure: European Union imports of Russian natural gas via pipeline (orange area) have collapsed since 2022, while LNG imports (red area) have partly filled the gap. EU imports of Russian gas in Q1 2025 were ~70% lower than pre-invasion levels, with pipeline volumes down 90% and offset by a 67% surge in LNG supply. Notably, this drastic shift occurred without formal EU gas sanctions – pipeline flows fell due to Russia’s cutoff (payment disputes, pipeline sabotage, and an expired transit deal) rather than EU policy.
Europe’s scramble to replace Russian pipeline gas turned it into the world’s premium LNG market virtually overnight. In 2022, Europe absorbed nearly 70% of US LNG exports, up from ~37% in prior years, as cargoes diverted from Asia to Europe’s higher prices. This surge made the EU the primary destination for US LNG and pushed US export terminals to full throttle. By early 2023–2024, Europe and Turkey still accounted for over half of all US LNG exports. EU nations like France, Spain, the UK, and the Netherlands led imports, together taking ~5 Bcf/day of US LNG in 2022.
However, global LNG supply is rapidly expanding. A “massive wave” of new liquefaction projects comes online starting late 2024, increasing global capacity by ~40% by 2028. The US and Qatar drive this growth with mega-projects, alongside new capacity in Canada, Russia, and Africa. Such a surge risks oversupply: LNG prices plunged in the last glut (2017–2020), and supplier profits evaporated. A repeat is anticipated mid-decade – demand growth is lackluster while supply jumps, likely pushing the LNG market into oversupply by 2025–2026. Analysts already foresee a “downward global LNG price trajectory” with heightened volatility as the market becomes structurally oversupplied. IEEFA projects global LNG capacity will reach ~666 MTPA by 2028, exceeding even high-demand scenarios and creating a buyer’s market in the late 2020s. In short, even under the status quo (Russian gas mostly absent from Europe), LNG suppliers face increasing competition and softer prices ahead.
US LNG Exports to Europe: Record Highs and Reliance on EU Demand
Figure: EU imports of US LNG (monthly, in thousand tonnes) from Jan 2021 to Mar 2025. Shipments rose steeply after Russia’s invasion (Feb 2022) and hit an all-time high in March 2025, reflecting Europe’s reliance on American gas. However, total US LNG deliveries to the EU in Apr 2024–Mar 2025 were ~14% lower than the prior 12 months, hinting at a slight demand dip as European storage and mild winter weather eased pressure.
The United States has become Europe’s largest LNG supplier, a cornerstone of the EU’s gas security since 2022. US LNG exports to Europe broke records – peaking in early 2025 – amid Europe’s effort to replace ~155 bcm/year of pre-war Russian gas. By March 2025, EU imports of US LNG reached their highest monthly volume. Over the years, volumes have moderated somewhat (the latest 12 months were ~14% below the previous year), partly due to a milder winter and conservation efforts that trimmed EU gas demand. Even so, Europe remains a critical market: in 2024 it still took ~53% of US LNG exports, and in 2022, it was dominant with ~70% share.
This heavy reliance means US LNG fortunes are tightly linked to Europe’s gas needs. European import terminals have been running at high utilization to accommodate LNG cargoes, and US export facilities likewise have operated near capacity. Multiple new US LNG projects (Plaquemines, Golden Pass, etc.) are slated for 2024–2026 startups, predicated mainly on continued European demand growth and the absence of Russian pipeline gas. Contracts underpinning some projects involve European buyers – for instance, Germany’s SEFE contracted with Delfin LNG, and France’s TotalEnergies invested in NextDecade’s project – signaling European commitments to US LNG for the mid-term.
Yet, there are signs of European demand volatility. EU gas consumption has fallen ~10–15% since 2021 due to high prices and efficiency measures, and EU climate goals aim to cut gas use further. Moreover, EU imports of Russian LNG (from Yamal LNG, etc.) rose 9% year-on-year in 2024, even as US LNG imports dipped – a reminder that some European buyers still opt for Russian LNG if it’s available. Russia earned $8.5 billion from LNG sales to Europe in the third year of the war, and over 50% of Russia’s LNG export revenue now comes from the EU. In other words, Europe’s LNG demand has been met by Russia’s seaborne LNG, not only by the US. This dynamic underscores a risk: if pipeline sanctions were lifted, Russian gas could rapidly regain market share in Europe, directly at the expense of US LNG.
Impact of Renewed Russian Gas Flows on US LNG Market Share and Pricing
If Russian pipeline gas returns to Europe in volume, the impact on US LNG would be swift and significant. Europe’s gas balance would shift, displacing the highest-cost or most flexible supplies first – namely, spot LNG cargoes, many of them from the US. Key impacts would include:
Lost Sales Volumes & Market Share: Russian pipeline capacity to Europe is large (before the war, over 150 bcm/year flowed). Even partially utilized, it could replace a substantial portion of LNG. For example, reviving Nord Stream 2 or Ukrainian transit routes could supply ~70 bcm/year to the EU – equivalent to all projected 2025 US LNG exports to Europe. In a complete sanctions-lifting scenario, Wood Mackenzie estimates up to 50 bcm/year of Russian pipeline gas could flow to Europe within a few years. This surge of supply would directly eat into US LNG sales. US exporters could see European volumes fall by tens of bcm, losing significant market share to Gazprom. The US went from supplying 0% to nearly half of Europe’s gas in two years; that trend could sharply reverse if Europe pivots back to cheaper Russian pipelines. US LNG might need to find alternative buyers in Asia or Latin America, likely at lower prices, or to idle capacity. In effect, unwinding Russia’s gas sanctions would “reduce the market for US LNG” dramatically, according to S&P Global, endangering US energy dominance in Europe.
Price Erosion & Reduced Pricing Power: An influx of Russian gas would flood the European market, likely driving down the European gas price (TTF) significantly. During 2022’s cutoff, TTF spiked above $30–50/MMBtu; a normalization with Russian supply could send TTF back to pre-war levels or lower. Wood Mackenzie’s stable peace scenario sees Dutch TTF falling below $8–9/MMBtu by 2028–29 with Russian flows restored – a far cry from recent crisis prices. Such a price collapse would undermine US LNG economics. Many US LNG contracts allow destination flexibility or have Henry Hub-linked pricing. Low TTF/European spot prices could lead buyers to defer or cancel US cargo liftings when uneconomic. Indeed, US LNG contracts’ flexibility means an extended period of low global prices “could leave the US [LNG] fleet underutilized”. With weaker pricing, US exporters lose bargaining power in both spot and long-term contract negotiations, as buyers have alternate supply options. Lower revenues per cargo translate to thinner margins for US projects and potentially less attractive terms for new projects (e.g., buyers demanding lower tolling fees).
Underutilized Infrastructure: US LNG terminals, some newly built or expanded at hefty cost, could see capacity go idle. Wood Mackenzie projects that with a significant Russian return, about 25 MTPA of US LNG capacity (≈34 bcm/yr) could become unused over the next five years. This amount is roughly 20–25% of current US LNG capacity sitting idle, a stark shift from the near-100% utilization during 2022’s shortage. LNG plants operate optimally at high utilization; underuse would raise unit costs and reduce export earnings. Europe’s import terminal, too, would see lower throughput, stranding some of the regasification capacity added in the rush to import LNG (e.g., Germany’s new FSRUs might run below capacity if pipeline gas surges). In short, costly infrastructure on both sides of the Atlantic could be underused, hurting returns on investment. US pipeline operators that feed LNG terminals might also see reduced volumes.
Deferred or Cancelled Investments: Perhaps most critically, a sustained resurgence of Russian gas would jeopardize new US LNG projects and expansions. Investors and buyers would question the need for additional US capacity if pipelines serve Europe – the most significant growth market – again. S&P Global Commodity Insights warns that up to 29 MTPA of planned US LNG capacity (roughly one-third of projects in advanced development) could be at risk depending on Europe’s policy on Russian gas. In a scenario where sanctions are lifted (“Opening the Taps”), S&P projects new US LNG projects in 2025–27 could shrink to just 16.5 MTPA (from ~33.7 MTPA expected under current trends) – implying roughly $70 billion less investment in the US gas sector. The collapse in European demand growth would mean fewer LNG export terminals reaching Final Investment Decision (FID).
In contrast, if Russian gas is further phased down or banned, US projects could increase to 45+ MTPA (an extra $48 billion investment). The swing is giant: policies on Russian gas could drive a ±$120 billion shift in US LNG capital expenditure. As Carlos Pascual of S&P said, “Any changes to restrictions on Russian gas flows to Europe would dramatically impact US LNG in market share and investment”. US project developers, particularly second-wave ventures without firm contracts, could struggle to secure financing or customers if the European market appears saturated by Russian supply.
European Energy Security Considerations: From a geopolitical angle, re-opening the door to Russian gas could also undermine the energy security narrative that favored US LNG. European officials have stressed the risks of relying on Russian supplies after the 2022 supply cut and price shocks. A return to Russian gas might be seen as a security risk, so it’s possible not all EU countries would participate uniformly. Some nations (e.g., Germany or Central/Eastern Europe) might still prioritize non-Russian gas for strategic reasons. However, others might jump at cheaper Russian contracts if sanctions lift. This uneven response could further fragment the market, but overall, even partial renewal of Russian flows would ease the supply tightness that gave US LNG its recent strategic leverage.
Global Market Ripples: In the global context, additional Russian volumes to Europe free up LNG cargoes to go elsewhere (or force them to). Excess LNG could flow to Asia, pushing Asian spot prices down as well. Key LNG producers like Qatar, Australia, and the US would compete in a more buyer-friendly Asian market. US LNG, often priced on Henry Hub plus fees, might lose competitiveness if oil-indexed LNG (from Qatar, for instance) falls in price or if Russian LNG (from Yamal, Arctic LNG 2) seeks buyers in Asia at discounts. Thus, a Russian pipeline comeback in Europe could create a global gas glut, benefiting importers but hurting producers’ margins worldwide.
Lifting gas sanctions on Russia would likely flood Europe with cheaper gas, erode LNG demand, slash prices, and directly hurt US LNG exports in volume and value. It would undo much of the post-2022 market shift that advantaged US suppliers. As S&P and Wood Mackenzie analyses conclude, such a scenario would “undermine investment” in future US projects and even threaten the utilization of existing capacity. US LNG’s hard-won market share in Europe could vanish almost overnight, with American cargoes forced to compete elsewhere at lower prices. A far more challenging market environment would replace the bullish case for endless LNG export growth.
Viability of US Gas Fracking Under Low-Price Scenarios
The US shale gas industry – the upstream source for LNG – would face a severe stress test if global gas prices fall and export growth stalls. Key factors affecting frackers’ viability include debt levels, breakeven costs, and financial resilience:
Price Sensitivity and Breakevens: US fracked gas is abundant but not always cheap to extract. Many shale gas operators require prices around $2.50–$3.00 per MMBtu (Henry Hub) to break even on new drilling. In early 2023, prices plunged below $3, prompting production curtailments. Analysts note that a sustained Henry Hub ~$3.00 would be a notable improvement from the lows of 2024 and is almost a minimum for comfortable profitability across major basins. At ~$2 or lower, several gas plays (especially those with higher transport or extraction costs, like parts of Haynesville or Appalachia) become unprofitable. If Russian gas undercuts global prices, US domestic gas prices would stay lower for longer. Indeed, Wood Mackenzie warns that renewed Russian exports would cause a structural drop in US LNG exports, which would weigh on Henry Hub prices by increasing domestic supply surplus. Cheaper gas might cheer US power producers and consumers, but it squeezes frackers’ margins. Lower prices reduce cash flow for drilling new wells, potentially sending the shale gas sector back into boom-bust distress.
Production Cuts and Slowdown: US gas drillers are already responding to price signals. By late 2024, US shale gas output had begun to decline (~1% year-on-year) – the first annual drop in two decades – as companies pulled back on drilling amid soft prices. If LNG demand disappoints, this retrenchment would deepen. Shale wells have steep decline rates, so constant drilling is needed to maintain output. In a weak price environment, producers will likely idle rigs and let production fall to rebalance the market. Lower output eventually lifts prices, but in the interim, it means layoffs, idle equipment, and hardship for oilfield service firms. Regions heavily tied to gas fracking (like parts of Texas, Louisiana, and Pennsylvania) could see economic impacts if drilling slows. The EIA projects Henry Hub recovering to around $3–4 in 2025, but that assumes continued LNG export growth. If instead exports are curtailed, domestic prices could remain depressed, delaying that recovery. Shale gas CEOs have emphasized “discipline” – they are likely to cut spending rather than drill unprofitable wells, which protects balance sheets but means overall US gas output would stagnate or decline until prices rebound.
Financial Health and Debt: The fracking industry has a checkered financial history. From 2010 to 2019, US shale companies burned through ~$300 billion more cash than they earned, accumulating debt in a rush to grow production. Dozens of gas-focused producers went bankrupt during the past price crashes (e.g., 2019–2020). However, The recent 2021–2022 boom dramatically improved the sector’s finances. Sky-high gas prices in 2022 generated record profits – US shale firms made an estimated $200 billion in 2022, cash they primarily used to pay down debt. By late 2022, analysts even predicted the industry could be debt-free by 2024 if windfall profits continued. Indeed, many companies now carry much lower debt loads than a few years ago and have prioritized shareholder returns over reckless expansion. Less debt means better resilience: most surviving players can endure a period of lower prices without immediate insolvency. However, their investors also demand capital discipline – if revenues plunge, companies will cut expenditures (and distributions) to preserve financial stability. Smaller or more indebted operators could still face distress if prices stay very low for multiple years. Overall, the shale gas sector is leaner and less leveraged now, but also more averse to growth-for-growth’s sake.
Breakeven Inflation and Costs: It’s worth noting that oilfield inflation has raised costs for drilling and fracking (rig rates, labor, steel, etc.). So the breakeven threshold for many gas producers may have inched up. If $2.50 was profitable pre-pandemic in core Marcellus, perhaps now $3 is needed for the same returns. One industry analysis finds that a Henry Hub price rise to $3.00 in 2025 would “spur breakeven viability” across US shale gas basins, suggesting current prices (around $2–2.5) are suboptimal for full-cycle economics. Thus, a scenario that keeps prices pinned near $2 – as might happen if Russian gas glut leads to global oversupply – could erode shale producers’ profitability and force further belt-tightening.
Strategic Shifts: With uncertain demand, US gas producers might pivot strategies. Some may target domestic markets (e.g. gas for petrochemicals, fertilizers, or power generation) to reduce reliance on export growth. Others may double down on hedging to lock in prices and safeguard revenue. There could also be consolidation: stronger players acquiring weaker ones to streamline operations and cut costs. The industry’s focus may shift from rapid growth to survival and efficiency. If Russian gas resurgence appears likely, US producers and LNG developers might lobby US and EU governments to discourage a full return to Russian dependence – not just for geopolitical reasons, but to protect the domestic industry from another price-crushing glut.
In essence, the viability of US fracking in the next 1–5 years hinges on maintaining adequate demand and price. LNG exports have become a lifeline for absorbing shale gas output; if that outlet narrows, the oversupply will crash prices until production falls. While today’s shale sector is financially stronger (having paid down debt with wartime profits), its breakevens still require moderate gas prices. An extended period of $2 gas would revive talk of bankruptcies and stranded assets. US frackers can survive a downturn by cutting activity – but that means no growth, and it could mean ceding ground to OPEC+ (for oil-focused companies) or simply leaving gas in the ground. In short, lifting Russian gas sanctions could re-create the conditions that led to the last shale bust: oversupply, low prices, and financial strain on an industry that only recently climbed out of a debt-fueled cycle.
Scenario Forecasts: Status Quo vs. Lifting Sanctions (2025–2030)
To illustrate the divergent outcomes, we compare two scenarios for the next five years: (A) Status Quo (Russian pipeline gas to Europe remains largely offline, current sanctions and self-sanctioning continue) vs. (B) Sanctions Lifted (Russian-European gas trade normalizes, with significant pipeline flows restored). The differences in supply mix, prices, and investment are stark.
Figure: US LNG expansion plans vary dramatically under European policy scenarios (S&P Global analysis). If Russian gas pipelines are reopened (“Lifting Sanctions”), new US LNG capacity additions by 2025–2027 could drop to ~16.5 MTPA (million tonnes per annum), about half of the ~33.7 MTPA expected under current trend policies. Conversely, a stricter policy that further phases down Russian gas would encourage up to ~45.5 MTPA of new US LNG projects. A phase down would represent a potential $120 billion swing in investment between the high and low cases.
Scenario A – Status Quo (Russian Gas Absent/Minimal): Europe continues to largely forgo Russian pipeline gas (aside from a trickle via Turkey’s TurkStream and the Ukraine-Slovakia corridor). Russian gas makes up only ~10–15% of Europe’s imports (mostly LNG). In this scenario, Europe sticks with its REPowerEU strategy of diversifying away from Russian fuel by 2027 (though this is aspirational). Global LNG Demand: Europe’s need for LNG stays elevated – the EU remains the “buyer of last resort,” balancing the market. High European imports (at or near record levels of ~120 bcm/year) persist through mid-decade, supporting international prices. Asia’s LNG demand grows slowly (tempered by high prices and competing fuels), so Europe’s intake is vital for keeping the market tight. Prices: European gas prices (TTF) moderate from 2022 highs but remain in a mid-range, say $10–15/MMBtu during peak winter demand, and $7–10 in off-peak – high enough to keep most US LNG profitable. Henry Hub prices in the US are in the $3–4/MMBtu range by 2025, as substantial LNG export volumes help absorb supply. US LNG Volumes: US exports grow as new projects come online (possibly reaching ~14–15 Bcf/d by 2027, from ~12 Bcf/d in 2023). US LNG to Europe stays robust, though Europe may not need much more than current levels if demand is flat – so US volumes plateau rather than continue surging. Infrastructure Utilization: LNG export terminals stay highly utilized; new ones (Venture Global, Cheniere expansions, etc.) proceed as planned to meet anticipated demand. European regas terminals, including new FSRUs, operate at healthy capacity to offset declining pipeline imports. Investment Climate: Ongoing need for non-Russian gas underpins investment in US LNG expansions. Roughly ~30–35 MTPA of new US LNG capacity reaches FID by 2027, aligned with S&P’s “Current Trend” case. US gas producers remain optimistic, investing in production growth to supply these LNG plants (with caution to avoid overproduction). Financial returns are solid; while prices aren’t sky-high, they’re sufficient for profitability, and the industry maintains discipline. Geopolitics: Europe incrementally reduces the remaining Russian LNG imports via policy measures (e.g, potential import bans or a price cap as recommended by CREAfile-ljptsqzwu3kbyh6lgkrh9l), further securing long-term market share for US and other alternative suppliers. Under the status quo, the US LNG industry enjoys a stable, if not booming, market – Europe’s reliance ensures demand, although increasing global supply still pressures prices downward gradually.
Scenario B – Sanctions Lifted (Russian Gas Returns): A diplomatic breakthrough (perhaps a Ukraine peace deal) leads to a thaw in energy relations. European governments (and the US) allow or even encourage the resumption of Russian gas flows as part of normalization. Key pipeline routes (potentially the intact Nord Stream 2 line, increased flows via Ukraine, or reopening the Yamal-Europe line through Poland) come back into play over 1–3 years. By 2026, Russian pipeline supply to the EU could reach 50–70 bcm/year (subject to infrastructure constraints and political willingness). In addition, Russia’s Arctic LNG 2 project also comes online, boosting LNG availability (unless specifically sanctioned). Global LNG Demand: Europe’s LNG import demand slumps markedly. Much of the ~70 bcm of returning pipeline gas directly displaces LNG that Europe would have imported. EU LNG imports could drop back to 2019 levels (~80 bcm/year or less) as pipeline gas covers marginal demand and refills storage. This would leave a lot of LNG cargoes seeking buyers. Asian markets would absorb some surplus, but not all – Asia’s demand would increase with lower prices, yet structurally it can’t rise fast enough to soak up tens of bcm overnight. Thus, global LNG demand growth falls behind capacity growth, creating a persistent surplus. Prices: With oversupply, European gas prices could collapse to the high-single-digits ($5–7/MMBtu) in off-peak and maybe $10 at winter peaks – roughly half the levels seen under the status quo, and far below what many new LNG projects need for viability. S&P warned that unwinding Russia sanctions would curtail future US projects and “simultaneously undermine European efforts to diversify” – effectively, cheap Russian gas undercuts the business case for diversification. Henry Hub in the US would also feel the hit: more gas stays at home, and unless producers drastically cut output, domestic prices stay low (perhaps $2–3 for an extended period, barring extreme weather). Wood Mackenzie’s scenario foresaw Henry Hub under pressure due to extra domestic supply when US LNG exports drop. US LNG Volumes: US export volumes stagnate or decline slightly. Export terminals will compete on price to place cargoes; some capacity, as noted, could go underutilized (~25 MTPA idle). In extreme cases, we could see a repeat of 2020 when US cargoes were canceled en masse due to a lack of demand. Even contracted volumes might be resold by buyers if not needed in Europe. By 2030, US LNG exports might be lower than expected, as new terminals are delayed and older ones operate below full throttle.
Infrastructure Utilization: Some planned US LNG projects are shelved indefinitely; existing terminals might run at 80% utilization instead of 95 %+. European LNG terminals could see significant idle capacity – e.g., Germany’s new terminals might hardly be needed if Russian gas flows via pipeline. Billions invested in new infrastructure yield suboptimal returns. Investment Climate: Frigid. Few new LNG projects reach FID because the market doesn’t need them – S&P’s “Opening the Taps” scenario implies only ~16.5 MTPA of new US capacity by 2027, mainly those already under construction. That’s a 50% cut in growth plans. The $70+ billion that would have gone into LNG terminals and associated upstream development is either redirected or lost. US gas producers see lower long-term demand, prompting lower capital spending in shale plays. Smaller or speculative ventures (lacking strong buyers or competitive advantage) likely collapse. Consolidation may accelerate in both the LNG sector (some projects canceled or merged) and upstream (weaker firms acquired or going bankrupt if they can’t cover costs). Geopolitics: Europe becomes re-dependent on Russian energy, which could have its long-term security implications (risking another cutoff). However, in the short run, the EU industry enjoys lower gas costs, potentially undermining the political will to reverse course. The US–EU energy partnership formed in 2022 (to supply an extra 15 bcm LNG, etc.) loses momentum. US influence in European energy diminishes accordingly.
The status quo scenario sustains a viable growth path for US LNG (though tempered by new global supplies). In contrast, a sanctions-lifted scenario spells oversupply, lower prices, stalled projects, and intense pressure on US gas producers. The contrast is evident in the figure above and industry studies: one path secures ongoing investment in US LNG (even expanding it if Russian gas is further reduced), while the other path severely undercuts US LNG’s future. Maintaining restrictions on Russian gas is thus pivotal for the US gas industry’s prosperity in the next 5 years. In contrast, a policy reversal could create a glut reminiscent of pre-2022 conditions – only this time with much more capacity at stake.
Key Consideration for US Producers
In light of these findings, in light of movements on close administration allies on Wall Street to restart Nord Stream 2, and in light of a push from Washington for a Russia deal that will definitely include a reprieve for Russian gas, US LNG exporters and shale gas producers must oppose a Russia deal. Simply vocally supporting policies that keep Russian pipeline gas out of the EU will not suffice. The US LNG industry needs to understand that Russia will not allow a Russia deal without some relief for its gas industry.
Citations:
https://energyandcleanair.org/presentation-russian-lng-exports-to-the-eu-implications-for-the-us-lng-market/
https://www.reuters.com/markets/commodities/us-lng-export-dominance-tested-europes-demand-wilts-maguire-2024-09-04/
https://www.eia.gov/todayinenergy/detail.php
https://www.eia.gov/todayinenergy/detail.php?id=61105
https://ieefa.org/resources/global-lng-outlook-2024-2028
https://www.energy.gov/sites/default/files/2024-06/067
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