
International Institute for Sustainable Development Response to DESNZ Consultation on Scope 3 Emissions Guidance
In a landmark decision, the British Supreme Court ruled in Finch v Surrey County Council that planning authorities must assess "downstream" greenhouse gas emissions as part of the environmental impact assessment (EIA) process for fossil fuel projects. The case specifically concerned oil extraction at Surrey's Horse Hill site, where planning permission was granted without considering emissions from burning the extracted oil (Scope 3 emissions).
Policy Recommendations
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The guidance should specify that the significance of emissions should be assessed in terms of the need for the project, in addition to other existing fields, within science-based 1.5°C scenarios.
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The guidance should specify that Scope 3, Category 11 emissions must be reported separately (i.e., the emissions from ultimately consuming the oil).
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The guidance should clarify that baselines for assessing emissions should usually be zero (as there are no emissions in the absence of a project), except in cases where an EIA is for an adaptation of an existing extraction facility.
The British government announced on 29 August 2024 that it would develop updated EIA guidance to help offshore operators understand the practical implications of the judgment. In late 2024, the government consulted on this draft guidance.
This brief is IISD's response to the consultation. IISD recommends that the guidance should
- specify that the significance of emissions should be assessed in terms of the need for the project, in addition to other existing fields, within science-based 1.5°C scenarios,
- specify that Scope 3, Category 11 emissions must be reported separately (i.e., the emissions from ultimately consuming the oil), and
- clarify that baselines for assessing emissions should usually be zero (as there are no emissions in the absence of a project), except in cases where an EIA is for an adaptation of an existing extraction facility.
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