Q466. An offshore petroleum and natural gas production facility emits the following during 2011 (note that the facility was NOT operating during 2008 and so no GOADS 2008 data available): (a) 20,000 metric tons CO2e from equipment leaks, vented emissions and flare emissions based on GOADS calculation methodology and (b) 10,000 metric tons CO2e from stationary combustion sources based on 40 CFR 98 Subpart C calculation methodology. Would this facility be required to report GHG emissions during 2011?

A466. Yes. The facility is identified as not being in GOADS in 2008, however, the total emissions from the facility is greater than 25,000 metric tons CO2e. §98.233(s)(4) states that "for either first or subsequent year reporting, offshore facilities either within or outside of BOEMRE jurisdiction that were not covered in the previous BOEMRE data collection cycle shall use the most recent BOEMRE data collection and emissions estimation methods published by BOEMRE referenced in 30 CFR 250.302 through 304 to calculate and report emissions (GOADS) to report emissions". Also, 98.2(a)(2) (as referenced in 98.231(a)) states that "a facility that contains any source category that is listed in Table A-4 of this subpart that emits 25,000 metric tons CO2e or more per year in combined emissions from stationary fuel combustion units, miscellaneous uses of carbonate, and all applicable source categories that are listed in Tables A-3 and Table A-4 of this subpart." Therefore, based on the information provided, this facility is required to report equipment leaks, vented emissions and flare emissions under subpart W and stationary combustion emissions under subpart C for calendar year 2011.