Jackdaw consultation response | NY Climate Coalition

North Yorkshire Climate Coalition

Submission to the OPRED consultation on Jackdaw

Reference: D/4260/2021

North Yorkshire Climate Coalition, representing 24 climate and environmental groups across North Yorkshire, wishes to make the following representations in response to the OPRED consultation on the proposed Jackdaw gas field.

At a moment when the devastating consequences of climate change are becoming ever more visible across Europe and even in our own region of North Yorkshire, we believe that any decision to approve significant new fossil fuel developments would seriously undermine the UK’s long‑term national interest, our international obligations and our ability to fully harness the economic opportunities emerging from the transition to a low-carbon economy, while having little or no impact on energy bills, energy security, jobs or the cost of living.

The case against the Jackdaw proposal is clear.

International commitments and credibility of UK climate leadership

Any expansion of fossil fuel extraction would directly undermine the UK’s legally binding national and international climate commitments (including the Climate Change Act and the Paris Agreement).

In this context, we also note the joint letter recently signed by the UK Foreign Secretary and the Spanish Foreign Minister, explicitly acknowledging that climate change is ‘now a national security emergency facing Europe and threatening our way of life’, The letter reaffirms UK support for the UNFCCC and stresses the importance of fulfilling the international commitments contained in the Paris Agreement, ‘underlining in particular the urgency of increasing global efforts to limit the increase in temperature to 1.5°C above pre-industrial levels’.

Yet, drawing on the latest climate science, highly authoritative and independent analyses (including reports by the Climate Change Committee, the International Energy Agency and the International Institute for Sustainable Development) show that new gas (and oil) fields are incompatible with pathways that keep global warming within safe limits.

Furthermore, any decision to approve Jackdaw would send a very damaging signal. The UK has long been regarded as a climate leader, but its future credibility among international partners depends on aligning domestic decisions with its stated ambitions. Authorising new fields risks weakening diplomatic influence at a time when global cooperation is essential.

Shell’s updated Environmental Statement for Jackdaw

In our view, Shell’s assessment of the field’s projected downstream (Scope 3) emissions in its updated Environmental Statement is misleading, methodologically flawed and non‑compliant with legal requirements.

It sets projected emissions (nearly 36 million tonnes of CO2 equivalent over the project’s lifetime) from the field in the context of the huge volume of global fossil fuel projects and concludes that the emissions are therefore ‘‘minor adverse and not significant’. This is misleading as there is an obvious difference in scale between individual projects and global emissions.

Reflecting the fact that the global climate responds to cumulative GHG volumes, the supplementary guidance issued by DESNZ for assessing the effects of downstream scope 3 emissions on climate from offshore oil and gas projects clarifies that Environmental Statements must consider the cumulative effects of the proposed project with other existing and planned future projects, in a global context’.

The Environmental Statement is non-compliant with the applicable EU EIA Directive, reinforced by the UK Supreme Court’s Finch ruling, as it fails to:

Assess cumulative combustion emissions from all national petroleum activities.
Assess compatibility with remaining 1.5°C carbon budgets.
Quantify indirect climate impacts (health, ecosystems, infrastructure).

The tie-back and displacement arguments

As noted by Professor Kevin Anderson in an open letter to the Prime Minister, the argument that permitting Jackdaw (and Rosebank) would not technically breach Labour’s previous commitment to stop issuing new oil and gas licences is ‘immaterial to the physics of climate change’, which ‘responds to the cumulative quantity of greenhouse gases released into the atmosphere. If these developments proceed, they will ultimately result in the release of hundreds of millions of tonnes of additional carbon dioxide.’

Research conducted by Uplift highlights that any displacement of imported LNG would be minimal (approx. 2% for Jackdaw). By contrast, Government and independent energy research cited by Carbon Brief shows that expanding renewable energy capacity (such as offshore wind) would displace significantly larger volumes of imported LNG than new North Sea drilling can achieve.

Environmental and social costs

The extreme weather events unfolding across Europe and worldwide this summer illustrate the urgency of accelerating the shift away from reliance on burning fossil fuels. Wildfires have devastated large areas of Europe, displacing communities, destroying ecosystems, and placing enormous strain on emergency services. These fires are widely and authoritatively reported, e.g. in the 26 June report by the World Weather Attribution Group, as being intensified by prolonged heatwaves linked to climate change, and they serve as a stark reminder of the escalating risks associated with continued fossil fuel dependence, including prolonged drought, excess heat-related deaths, the widespread destruction of habitats and cherished landscapes, the drying out of soils, and not least large-scale crop disruption and the associated risk to food supplies.

With specific regard to excess mortality, we note that the projected scope 3 emissions associated with Jackdaw equate to approximately 8,000 human deaths from climate effects before 2100, according to the IPCC-derived ‘mortality cost of carbon’ or ‘thousand tonne rule’. In financial terms, based on Greenpeace estimates and the Treasury Value of Prevented Fatality (VPF, £2 million per death), the value of not going ahead with Jackdaw is over £16.1 billion.

Any properly evidence-based decision must demonstrate strategic foresight by taking full account of these actual, projected and estimated impacts and costs.

Economic rationale and cost of living

The economic rationale for new extraction is weak. The recent CBI report highlights the strength and resilience of the UK’s net‑zero economy, which grew significantly even during periods of wider economic stagnation. According to the report, sectors aligned with the transition – renewable energy, green manufacturing, clean tech and low‑carbon services – are expanding rapidly, attracting investment, creating skilled jobs and strengthening the UK’s global competitiveness. This evidence suggests that permitting further extraction from a largely depleted basin – with minimal job creation benefits in the case of Jackdaw – would be not only environmentally damaging but economically short‑sighted, misdirecting crucial investment away from the low-carbon sector.

Equally, greenlighting the Jackdaw project would offer no meaningful relief to UK consumers. As widely noted by energy analysts, the extracted resources would be sold to the highest bidder on international markets, with prices determined globally. As the highly respected economist Mariana Mazzucato puts it, ‘Drilling the North Sea won’t help people across the UK struggling with their energy bills’. Nor would the resulting production enhance energy security in a way that compares to accelerating investment in renewables, storage and efficiency.

A 2025 report by the LSE’s Grantham Institute finds that any decision to approve the development of Jackdaw (and Rosebank) would ‘lead to confusion about the direction of travel and undermine investment into the clean transition. This might be justified were there to be clear economic benefits but, in fact, such investment risks generating low returns and would be against the UK’s strategic economic self-interests’.

We agree with the report’s conclusions that approval would:

lock in further reliance on volatile oil and gas markets while losing out on productivity and efficiency gains of domestic clean energy
risk putting money into stranded assets which will require taxpayers to bail out decommissioning costs

distract from the growth opportunity of the 21st century

fail to capture broader benefits such as cleaner air

undermine the UK’s credibility, i.e. its ability to convince other countries to act.

In conclusion, for all these reasons – environmental, social, human, economic and diplomatic – we believe the Jackdaw proposal should be rejected and that Government should instead focus on accelerating the UK’s transition to a clean, secure and future‑proof energy system while ensuring that the current oil and gas workforce is offered all the support needed to find high-quality and well-paid jobs in the clean energy sector.

Yours sincerely,

North Yorkshire Climate Coalition

August 2026