Rosebank consultation response | NY Climate Coalition

North Yorkshire Climate Coalition

Submission to the OPRED consultation on Rosebank

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 Rosebank oil and 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 figures – Rosebank reserves and associated emissions

Rosebank holds more than 480 million barrels of oil. Its total lifetime emissions are estimated at 254 million tonnes of CO₂ equivalent. This figure is nearly 70% of the UK's entire annual emissions in 2024 based on the latest DESNZ figures. Indeed, research by Uplift shows that production (upstream) emissions alone at the site – before even factoring in the associated downstream (scope 3) emissions – would significantly exceed the oil and gas industry’s share of the statutory carbon budget for 2028-32.

For context, if Rosebank’s oil and gas reserves were to be extracted and therefore inevitably burned, the resulting climate pollution would be greater than the combined annual CO₂ emissions of the 73 lowest-emitting countries and territories, representing over 114 million people and equivalent to running 67 coal-fired power stations for a year. Source: Rosebank oil field: the complete guide - Blogpost from Uplift (News).

The case against the Rosebank proposal is clear.

National and international obligations and credibility of UK climate leadership

Any expansion of fossil fuel extraction – whether oil or gas – 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’.

In considering its decision on Rosebank, we also urge the government to consider the recent landmark advisory opinion issued by the UN’s top court, the International Court of Justice (ICJ), which stated that nations have a binding legal duty under international law to protect the Earth from greenhouse gas emissions and prevent climate harm.

Furthermore, any decision to approve Rosebank 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.

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 oil (and gas) fields are incompatible with pathways that keep global warming within safe limits.

Equally, according to UCL research, opening any new North Sea oil and gas fields would be inconsistent with commitments to limit warming in line with the temperature thresholds in the Paris Agreement – which the UK has ratified.

Equinor’s revised Environmental Statement for Rosebank

Based on our research, Equinor’s revised assessment of the field’s projected downstream (Scope 3) emissions in its updated Environmental Statement (ES) is misleading and therefore non‑compliant with legal requirements.

The revised ES sets projected emissions (254 million tonnes of CO2 equivalent over the project’s lifetime, see source above) from the field in the context of the much greater volume of global fossil fuel projects and concludes that the emissions are therefore ‘not significant when viewed in the context of international climate commitments, sector-specific Net Zero strategies, and UK government policies’ (p1.7.2). This characterisation is highly misleading and contrary to the supplementary guidance (see next paragraph).

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 guidance also states that ‘characterising scope 3 emissions from a project solely in numeric terms against global GHG emissions would not on its own provide a meaningful expression of the global effect of those scope 3 emissions, because of the obvious difference in scale between individual projects and global emissions levels.’

With reference to the Paris Agreement targets, Equinor’s Environmental Statement concedes in section 1.7.4 that ‘In future climate scenarios where these targets are not met, emissions from all sources, including the Rosebank Development, could significantly impact the climate due to its high sensitivity and cumulative effects.’ Given that the latest analysis from Climate Action Tracker indicates that the world is currently on track for around 2.6°C of warming by 2100, it appears highly likely that Equinor’s own criterion for ‘significant’ impact will be met.

Furthermore, both the Offshore EIA Regulations Guidance and the new supplementary guidance specify that the Environment Statement should describe the reasonable alternatives studied by a developer for a proposed project. While Equinor has previously examined alternative field development options, it has not considered alternatives to oil production such as alternative energy generation methods, e.g. offshore wind.

The tie-back, energy security and displacement arguments

As noted by Professor Kevin Anderson in an open letter to the Prime Minister, the argument that permitting Rosebank (and Jackdaw) 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.’

In terms of energy security, Research conducted for Uplift highlights that 90% of Rosebank’s reserves are oil destined primarily for international markets and that Rosebank's minimal gas reserves could reduce UK gas import dependency by just 1% on average – and only if none is exported.

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 gas than new North Sea drilling can achieve. True energy security comes from homegrown renewable energy, power that cannot be disrupted by geopolitical events, and whose price does not swing with global markets. Renewables supplied more of the UK’s electricity than any other source in 2025.

With regard to costs and benefits, we note further that the primary financial beneficiaries of approval would be Equinor and Shell, both of which paid ‘essentially zero UK tax’ in 2024, while UK taxpayers would reportedly shoulder over 80% of Rosebank's development costs through generous tax relief.

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.

Any properly evidence-based decision must demonstrate strategic foresight by taking full account of these actual, projected and estimated impacts, harms 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 would be not only environmentally damaging but economically short‑sighted, misdirecting crucial investment away from the low-carbon sector.

Equally, greenlighting the Rosebank 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 Rosebank (and Jackdaw) 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, diplomatic and legal – we believe the Rosebank 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