Q467. Can we use 2011 BOEMRE data, rather than the previously available data from 2008, for reporting RY2011 emissions from an offshore petroleum and natural gas production facility?

Q467. For offshore petroleum and natural gas production facilities under §98.233(s)(1)(i), the GHGRP states that these facilities shall report the same annual emissions as calculated and reported by BOEMRE and that any calendar year that overlaps with the most recent study publication year, the most recent BOEMRE reported emissions data should be used. We understand this to mean that for the 2011 reporting year, we can use 2011 BOEMRE data, rather than the previously available data from 2008. Please confirm that this is an acceptable approach.

A467. BOEMRE typically publishes a GOADS study after March 31 of the year following the data collection. Therefore, for Subpart W reporting year 2011, offshore reporters subject to BOEMRE must use the latest BOEMRE published emissions data (which may be 2008, as the 2011 GOADS report may not be available until after the September 28, 2012 reporting for subpart W). As a further clarification, the reporters will report under Subpart W for 2011 using the BOEMRE methodologies published in 30 CFR 250.302 through 304 with the latest BOEMRE emissions data. In subsequent years, reporters in state and non-Gulf of Mexico waters will report using the GOADS methodologies published in 30 CFR 250.302 through 304, which historically have been published along with the GOADS emissions data.