Consultation: Cambo Oil Field Development

Carbon Balance Initiative welcomes the opportunity to respond to OPRED's public consultation (D/4261/2026) on whether to grant consent for development of the Cambo Oil Field.

Our submission finds that, in its current form, the Cambo environmental statement does not meet the legal requirements for a production licence. Following the Supreme Court's judgment in Finch v Surrey County Council and DESNZ's June 2025 supplementary guidance, an environmental statement must assess downstream Scope 3 emissions and describe measures to mitigate their likely significant effects. Cambo's statement addresses operational Scope 1 emissions but not the combustion of the hydrocarbons it would produce. This omission is material, given that committed emissions from existing oil and gas fields already exceed the remaining 1.5°C carbon budget more than threefold.

Read the full submission here

A pathway nonetheless exists by which Cambo could be developed consistently with the Paris Agreement. This would require the applicant to amend its environmental statement to include a legally binding Scope 3 mitigation plan, embedded within a broader supply-side carbon management framework such as a Carbon Takeback Obligation. Applied even-handedly across all pending domestic projects, this approach would give the sector greater regulatory certainty, support tax revenues during the transition, and strengthen the business case for domestic CCUS. This submission addresses:

• the statement's compliance with Finch and DESNZ guidance on Scope 3 mitigation;

• the committed emissions from existing fields relative to the remaining 1.5°C carbon budget;

• a geological net zero pathway for conditional consent;

• the potential for a conditional consent to establish an internationally replicable model for Paris-aligned production.