Response to DESNZ Consultation on Scope 3 Emissions Guidance

The IISD response to the DESNZ consultation argues for more rigorous standards in assessing Scope 3 emissions for offshore oil projects, specifically calling for the separate reporting of Category 11 emissions, the use of zero-emission baselines, and the assessment of significance based on 1.5°C science-based scenarios rather than as a proportion of global emissions.

• The draft guidance fails to define 'significance', which IISD argues weakens consistent decision-making. IISD recommends that significance be assessed based on whether a project is consistent with science-based 1.5°C scenarios or carbon budgets, accounting for the demand in the global oil market and the emissions of existing projects.
• IISD recommends that Scope 3, Category 11 emissions—those resulting from the ultimate consumption of the oil—must be reported separately to prevent them from being subsumed under broader headings and to ensure compliance with the Finch ruling.
• The guidance should specify that emission baselines should generally be zero, as there are typically no emissions in the absence of a project. This prevents developers from claiming a project is 'cleaner' than a hypothetical alternative it might displace, a claim IISD notes has been rejected by courts.
• IISD argues that cumulative effects must be assessed at a global level because carbon dioxide emissions have a global cumulative effect, whereas the draft guidance focuses primarily on local cumulative effects such as other projects in the same area.
• The document advises against assessing significance by calculating project emissions as a proportion of British, sectoral, or global emissions, as such figures are often misleadingly small and ignore the cumulative effect of multiple oilfields.
• Regarding mitigation, IISD recommends that emissions and carbon dioxide removals be accounted for separately rather than as a single net figure, and specifically advises ruling out the use of voluntary carbon market offsets due to a lack of integrity.
• The consultation is a response to the British Supreme Court's ruling in Finch v Surrey County Council, which established that planning authorities must assess downstream greenhouse gas emissions as part of the EIA process for fossil fuel projects.

APA

International Institute for Sustainable Development (2025). Response to DESNZ Consultation on Scope 3 Emissions Guidance. https://www.iisd.org/system/files/2025-01/iisd-response-desnz-consultation.pdf

Chicago

International Institute for Sustainable Development. Response to DESNZ Consultation on Scope 3 Emissions Guidance. 2025. https://www.iisd.org/system/files/2025-01/iisd-response-desnz-consultation.pdf.

Wikipedia

{{cite report |author=International Institute for Sustainable Development |title=Response to DESNZ Consultation on Scope 3 Emissions Guidance |date=January 2025 |url=https://www.iisd.org/system/files/2025-01/iisd-response-desnz-consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{internationalinstituteforsustainabledevelopment2025response, author = {{International Institute for Sustainable Development}}, title = {{Response to DESNZ Consultation on Scope 3 Emissions Guidance}}, institution = {International Institute for Sustainable Development}, year = {2025}, month = jan, url = {https://www.iisd.org/system/files/2025-01/iisd-response-desnz-consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }