IEMA advice regarded as central to government guidance on assessing offshore oil and gas scope 3 emissions

IEMA is pleased to publish its response to the Department of Energy Security and Net Zero’s consultation on their draft supplementary guidance for assessing the effects of scope 3 emissions on climate from offshore oil and gas projects. Here, Rufus Howard, IEMA’s policy and engagement lead for impact assessment, discusses the key aspects of the Institute’s response.

The proper consideration of climate change and GHGs through impact assessment is a critically important tool for decision makers. This is increasingly essential in light of the Climate Change Act, Net Zero targets, Paris Agreement and advice of the Climate Change Committee.

IEMA has already published good practice in our impact assessment guides on Climate Change Resilience and Adaptation (2015, updated 2020) and Assessing Greenhouse Gas Emissions and Evaluating their Significance (2017, updated 2022). These guides have proved instrumental in raising the quality of consideration of climate and GHGs in environmental impact assessments in support of planning.

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The quality of this existing guidance was recognised by its use in numerous planning and Secretary of State decisions, including the landmark Supreme Court Case, Finch vs. Surrey County Council 2024. The existing guides are mentioned in the supplementary guidance on which this consultation is based, and so IEMA experts were able to make a number of very important, robust recommendations in this consultation based on a strong existing foundation of understanding and communication.

IEMA Impact Assessment and GHG experts recommended the following:

  • Use a baseline scenario including the ‘do nothing’ or ‘no action’ scenario and clearly state the additional total GHG emissions arising from the proposed project, including scope 3 emissions.
  • Embed existing good practice by explicitly recommending the use of the IEMA GHG quantification principles and recognised good practice guidance as well as the application of reasonable worst-case scenarios.
  • Transparent reporting of limitations and uncertainties.
  • Provide better guidance on the criteria for contextualising significance by considering emissions with respect to UK decarbonisation policies, net zero trajectory, carbon budgets and related legislation and international commitments.
  • Clarify the limitation of mitigation more explicitly, for example, by acknowledging that with scope 3 emissions via combustion, avoidance (the apex of the mitigation hierarchy) is only realistically achievable by not extracting the oil and gas. Prevention and reduction mitigation options are severely limited for scope 3 combustion, and therefore any mitigation proposed is likely to be focused on compensation and offsetting, which, according to the mitigation hierarchy, should be matters of last resort and may lie outside of the control of developers and consent authorities.
  • Include an assumption that substitution will not occur, since the science and practice regarding substitution effects is not well developed, and in many cases can be misleading, inaccurate or unproven. If a case for substitution effects is made, it should be fully evidenced and made after the presentation of total GHG emissions arising.
  • Assume that the GHG emissions are released in the UK. Consistent with the polluter pays principle, rectification at source, and proximity principle, oil and gas arising from the UK should be considered in a UK context, even if subsequently exported and combusted outside UK territory. The atmosphere as a shared global resource is still affected if the combustion occurs internationally and the UK should take ownership and responsibility for managing the international and transboundary effects arising from developments within its territory.

The role of Impact Assessment in shaping the proper consideration and contextualisation of scope 3 emissions for offshore oil and gas projects is crucial in ensuring that the proper checks and balances are taken into account by decision makers. In this case, and many others, Impact Assessment is the rational and realistic process by which good outcomes can be obtained for communities, governments and the planet, and IEMA’s experts in the IA Network will continue to highlight the good that IA does in the continuing transformation of the world to sustainability.

To read the IEMA consultation response in full click here.

To learn more about the IEMA EIA Quality Mark click here.

Special thanks to Tom Dearing and members of the Impact Assessment Network GHG Working Group for assistance in the preparation of the response.


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Rufus Howard FIEMA

Policy and Engagement Lead

Dr Howard is the policy and engagement lead for Impact Assessment at IEMA and a leading professional in EIA, with two decades of international experience across renewable energy and major infrastructure. A Fellow of IEMA and Chartered Environmentalist, Rufus holds degrees in Biodiversity Conservation and Environmental Law, and a doctorate in Management. A trusted advisor, Rufus has directed environmental projects for major organisations such as the World Bank, The Crown Estate, Natural Resources Wales, the EBRD, Statkraft, Orsted, National Grid, and the Environment Agency. Rufus lives in Kent with his wife and three daughters and enjoys walking in nature, cooking, music, kayaking and archery.