Submission on Supplementary EIA Guidance for Assessing the Effects of Scope 3 Emissions on Climate from Offshore Oil and Gas Projects

The submission is in response to the UK Department of Energy Security and Net Zero’s draft supplementary Environmental Impact Assessment (EIA) guidance on assessing scope 3 emissions from offshore oil and gas projects. We argue that the guidance lacks clarity, particularly in defining the baseline scenario and the extent of assessment, allowing project developers too much discretion. Our submission highlights that the guidance risks undermining the Supreme Court’s Finch ruling, which establishes that full combustion must be considered in project evaluations. It calls for a transparent, science-based approach to assessing alignment to the Paris Agreement temperature goals, rejecting substitution arguments and emphasising the need for robust mitigation measures, including full geological net zero alignment. The authors recommend strengthening the EIA framework to ensure that oil and gas projects align with geological net zero pathways, prevent regulatory loopholes, and uphold international and domestic environmental legal principles.