Q466. Would an offshore petroleum and natural gas production facility that was not included in BOEM's most recent emissions inventory that emits 30,000 metric tons CO2e from subpart W and subpart C sources combined be required to report?

Q466. Would an offshore petroleum and natural gas production facility that was not included in BOEM's (formerly BOEMRE) most recent emissions inventory that emits 20,000 metric tons CO2e from subpart W sources based on BOEM calculation methodology and 10,000 metric tons CO2e from stationary combustion sources (subpart C) be required to report to the GHGRP?

A466. Yes. 40 CFR 98.2(a)(2) (as referenced in 40 CFR 98.231(a)) states that reporting is required by "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," and offshore petroleum and natural gas production facilities are part of the Petroleum and Natural Gas Systems source category listed in Table A-4.

For Reporting Year (RY) 2024 and earlier, if the facility was not included in BOEM's most recent OCS emissions inventory, 40 CFR 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."

For RY 2025 and later, per either 40 CFR 98.233(s)(1)(i) if the facility reports to BOEM's OCS emissions inventory, (s)(2)(i) if the facility does not report to BOEM's OCS emissions inventory, or (s)(4) if it is the facility's first year of reporting to the GHGRP, the facility must use the "most recent monitoring and calculation methods published by BOEM as referenced in 30 CFR 550.302 through 304" to calculate and report annual emissions.

Note: The Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) replaced the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) in October 2011.  Additionally, BOEM has replaced the GOADS database with the Outer Continental Shelf Air Quality System (OCS AQS) beginning with its 2021 emissions inventory. The applicable regulatory citation is now 30 CFR 550.302 through 304 instead of 30 CFR 250.302 through 304.