The UK government is developing new guidance on environmental impact assessments for new offshore oil and gas projects. This is a direct result of our win in the Supreme Court.
Thanks to our campaign on the Horse Hill oil extraction site in Surrey, fossil fuel developers and regulators can no longer ignore the huge climate pollution caused by burning the oil and gas they produce. And that applies equally to the North Sea fields. From now on, when companies apply to develop oil and gas fields, they must include a full assessment of these emissions (called “Scope 3”) in their Environmental Statements, and OPRED (the Offshore Petroleum Regulator for Environment and Decommissioning) must take them into account before approving any new drilling. The UK is not approving new offshore oil and gas fields while the new guidance is being developed.
The government consulted on its draft and the Weald Action Group submitted a response to the consultation.
Sarah Finch, who brought the brought the legal case on Horse Hill, on behalf of the Weald Action Group, also submitted a response.
We said:
- The baseline scenario for EIA must be the complete absence of the proposed project – in most cases, this will mean a baseline scenario of zero GHG emissions.
- The starting point for calculating scope 3 emissions should be the assumption that all the oil and gas that is extracted will be combusted, unless the developer can prove otherwise for the specific project in question.
- The Finch ruling confirmed that combustion emissions must always be assessed as part of the EIA for an oil and gas project. The task for developers is to quantify the social and environmental effects of those emissions.
- Developers must not be allowed to avoid assessing emissions based on speculative assumptions that there will be a reduction in oil and gas production elsewhere as a result of the proposed project going ahead.
- We strongly recommend that the guidance states that proposed projects should be considered within the context of all global cumulative GHG emissions, including “committed emissions” from the oil, gas and coal to be extracted from existing fields and mines.
- Developers must certainly not be allowed to rely on technologies such Carbon Capture, Usage and Storage, or on unregulated voluntary carbon markets to ‘mitigate’ emissions.
- The assessment should take into account global environmental protection objectives including the Paris Agreement, and international principles and treaties.
- The draft guidance is intended to apply to applications for offshore oil and gas projects. The onshore environment must not be ignored! Under the existing regulatory environment, civil society groups and local communities face an uphill battle in stopping these developments. For example, the National Planning Policy Framework still unfortunately (and despite its recent review) encourages Mineral Planning Authorities to “plan positively” for onshore oil and gas developments which is entirely out of step with the overall thrust of the government’s intention to transition away from fossil fuels. It is important that the government issues similar guidance regarding onshore fossil fuel projects.
Kirsty Barnett from the Weald Action Group said, “There are billions of barrels of oil and gas left in the North Sea. If this fuel is allowed to be extracted and burned, it will have a catastrophic impact on the climate. The science is clear: keeping global average temperature rise below 1.5°C requires that no new oil and gas fields are developed. We believe that proper assessment of the climate impacts of new oil and gas means that none can be approved. The government must put in place a robust regime which will end new oil and gas field approvals.”
The Government also plans to consult shortly on its manifesto position not to issue new oil and gas licences to explore new fields, and this will consider both onshore and offshore licensing.
Read more:
WAG EIA scope 3 guidance response
A response from Sarah Finch, who brought the legal case on Horse Hill, on behalf of the Weald Action Group