We have submitted a damning response to the government consultation on the revised Environmental Impact Assessment (EIA) for the Rosebank oil field, a reassessment triggered when the Scottish courts ruled the previous approval unlawful. This was a direct consequence of our 2024 Supreme Court win (Finch v Surrey County Council), which established that downstream “scope 3” emissions must be fully assessed for fossil fuel developments.
Equinor’s revised Environmental Statement now accepts that Rosebank could generate 254 million tonnes of CO₂ equivalent over its lifetime. OUR submission warns that the oil giant has still failed to assess how these emissions would affect people and ecosystems, and has not considered the cumulative effects when the emissions of all other existing and planned oil, gas and coal sites are taken into account. This is despite clear legal duties under the Offshore EIA Regulations and recent judgments from both the European Court of Human Rights and the International Court of Justice (ICJ). The submission also notes that the ICJ has confirmed that states that permit activities causing significant climate harm may be committing an internationally wrongful act.
WAG’s submission also highlights that Equinor’s own Environmental Statement concedes the project’s emissions “would be significant” if global climate efforts fail to keep global average temperature rise below the 1.5°C target. The latest analysis from Climate Action Tracker indicates that the world is currently on track for around 2.6°C of warming by 2100.
Sarah Finch, co-author of the submission and who brought the Supreme Court case on behalf of WAG, said: “The Supreme Court ruling on our case was clear: developers must provide comprehensive and high-quality information about the effects of their projects. Equinor has not done this. The public deserves clarity about what Rosebank’s emissions would mean for people and for a liveable climate. Equinor’s claim they would not cause significant harm is dishonest. The Secretary of State cannot grant consent on the basis of this misleading statement.”
Kirsty Clough, co-author of the submission, said: “The Supreme Court made it clear that combustion emissions are always significant. For Equinor to rely on ‘other regimes’ to deal with its pollution repeats the very legal error that saw Rosebank’s last consent overturned. This consultation has become the litmus test of the government’s climate policy and its respect for the rule of law.”
