Q465. An offshore petroleum and natural gas production facility reported in the GOADS 2008 report, GHG emissions were <25,000 metric tons CO2e from equipment leaks, vented emissions and flare emissions AND stationary combustion sources (i.e., sum of all GHG CO2e - Subpart W and Subpart C sources). Assume that actual 2011 GHG emissions were >25,000 metric tons of CO2e (Subpart W - GOADS method and Subpart C sources) for the facility. Does this facility have to report GHG emissions for 2011 reporting year?
A465. If emissions in 2011 are 25,000 tons CO2e or more for all sources covered by the greenhouse gas reporting rule, in this case sources under subparts C and W, then the facility must report. §98.233(s)(1)(i) also indicates that if the calendar year does not overlap with the most recent BOEMRE emissions study publication year, the reporter must use the most recent BOEMRE reported emission data and “adjust emissions based on the operating time for the facility relative to the operating time in the most recent BOEMRE published study.” Therefore, if reported 2008 emissions, adjusted for any differences in 2011 operating time, are 25,000 tons CO2e or more, then the facility must report for calendar year 2011.