Consultation Response: Rosebank Oil Field Development

Carbon Balance Initiative welcomes the opportunity to respond to OPRED's public consultation (ES/2022/001) on whether to grant consent for development of the Rosebank Oil 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 methodology compares Rosebank's Scope 3 emissions against national, sectoral and global totals. Measured against any of these, a single field will always look small. A test that returns the same "not significant" verdict whether or not the world is on track for net zero cannot serve the purpose the EIA Regulations require. Adura's reliance on production forecasts that already assume Rosebank's output also makes its "no incremental effect" conclusion circular.

Read the full submission here

A pathway nonetheless exists by which Rosebank 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;

• the circularity of testing Rosebank against a baseline that already includes it;

• a geological net zero pathway for conditional consent, and its potential as a replicable model for Paris-aligned production.