Consultation Response: Jackdaw Gas Field Development
Carbon Balance Initiative welcomes the opportunity to respond to OPRED's public consultation (D/4260/2021) on whether to grant consent for development of the Jackdaw Gas Field, following Adura's updated Environmental Impact Assessment taking the field's Scope 3 emissions into account.
Our submission finds that Adura's further information does not resolve the fundamental deficiency in the original environmental statement. Its significance assessment compares Jackdaw's Scope 3 emissions against global and UK totals, a comparator Adura itself acknowledged will always make an individual project look small. The emissions intensity figures supporting its "minor adverse" conclusion also stop in 2031, six years before Jackdaw's anticipated cessation of production in 2037. They therefore exclude the late-life years most likely to weaken the result. More fundamentally, Adura shows that Jackdaw performs well against existing arrangements, but not that approving new extraction is compatible with a carbon budget that must shrink to zero.
A pathway nonetheless exists by which Jackdaw could be developed consistently with the Paris Agreement while supporting the Government's North Sea Future Plan. This would require Adura to accept a legally binding, quantified obligation to permanently store a rising share of the Scope 3 (Category 11) emissions from its products, embedded within a broader supply-side carbon management framework such as a Carbon Takeback Obligation.
This submission addresses:
the limitations of Adura's Scope 3 significance methodology;
the committed emissions from existing fields relative to the remaining 1.5°C carbon budget;
gaps in the GHG intensity assessment underpinning the "minor adverse" conclusion;
the difference between compliance with existing arrangements and consistency with net zero;
a geological net zero pathway for conditional consent, and its potential as a replicable model for Paris-aligned production.