Q471. How are new offshore facilities that are subject to GOADS supposed to report in 2012? Since published GOADS data are not available, should they be using the GOADS methodologies to calculate the emissions?

A471. New facilities, whether or not under GOADS jurisdiction, have to follow 98.233(s)(4), which states, “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.”

Therefore, if the facility is subject to the rule and is under BOEMRE jurisdiction but is a new facility that is not included in the most recently published GOADs report, then you must calculate calendar year 2011 emissions for equipment leaks, vent, and flare emission sources using the GOADS methodologies in the most recently published GOADS report.