Supplementary EIA guidance on scope 3 for oil and gas

Carbon Balance Initiative submitted a response to the UK Department of Energy Security and Net Zero’s draft Supplementary Environmental Impact Assessment (EIA) Guidance for Assessing the Effects of Scope 3 Emissions on Climate from Offshore oil and gas. Our submission raises concerns about a lack of clarity in defining baseline scenarios and assessment scope, granting excessive discretion to project developers. We argue that the current draft risks undermining the UK Supreme Court’s Finch ruling, which confirmed that full combustion emissions must be considered when evaluating climate impacts.

Read the full submission here

Our Key Recommendations:

1. Enforce full Scope 3 accounting

Assessments must include all carbon embedded in a project’s extracted oil and gas. This follows the Finch ruling, which states that all CO2 will ultimately be combusted and emitted, unless proven otherwise.

2. Ensure Paris alignment

EIA guidance should explicitly assess whether projects are compatible with the UK’s international obligations under the Paris Agreement and geological net zero pathways.

3. Require clear mitigation measures as a condition

EIA guidance must require developers to demonstrate how mitigation measures align with a Paris-compatible pathway. This includes prioritising early, substantial mitigation following a clear hierarchy: first avoiding emissions, then reducing them, and finally addressing any residuals with high-integrity, geological carbon storage. Developers should show how their projects contribute to achieving net zero by 2050 through permanent storage, not low-quality offsets. Mitigation plans must be detailed, project-specific, and enforceable.

4. Close regulatory loopholes

Clearer definitions and standards are needed to avoid inconsistent applications and uphold the integrity of environmental law.