23rd June 2025
The UK Government has set new rules for companies applying for consent to drill for oil and gas that requires them to declare the amount of emissions that will be released from the oil and gas they extract. The new guidance is an important milestone in recognising the incompatibility of new oil and gas fields with climate targets.
The new guidance comes at a critical time. It was published on the same day as 60 of the world’s leading climate scientists warned the earth could breach the target set by the Paris Agreement to limit warming to 1.5C in as little as three years. The climate scientists warned that countries have continued to burn record amounts of fossil fuels, despite commitments to reduce emissions and that climate change has already worsened many weather extremes, global heating and sea level rise.
Also, on the same day, the Royal College of Physicians published a report warning that air pollution affects almost every organ in the human body, could contribute to about 30,000 deaths in the UK in 2025 and cost more than £27 billion annually. Publication of the report coincided with a letter signed by 400 health professionals demanding the government set air pollution limits consistent with World Health Organization guidelines.
The new guidance for oil and gas companies was produced following a Supreme Court ruling in June 2024 which found the decision to grant planning permission for an oil development in Surrey to be unlawful because the end-use emissions from burning the extracted oil (scope 3 emissions) were not assessed as part of the Environmental Impact Assessment. Only the scope 1 and 2 emissions had been considered (i.e. those produced during the extraction process).
This was followed in January 2025 by a Scottish court ruling against development of the Rosebank and Jackdaw oilfields in the North Sea, which found that the Environmental Impact Assessments associated with the fields had not taken into account the downstream emissions of the oil and gas produced at the fields.
These rulings led the government to revise the guidance for offshore oil and gas production to include the assessment of end-use emissions, which has now been published. The introduction of these rules means that new oil and gas projects, which were being held up while the guidelines were being created, can now progress. This includes Rosebank and Jackdaw, which must reapply for permission taking account of the new guidance if they want to develop the fields.
This will be an important test for the UK Government, which has pledged to cut carbon emissions by 81% by 2035 relative to 1990 levels compatible with the 1.5C target. Rosebank is the biggest undeveloped oilfield in the North Sea with the potential to produce 500 barrels of oil, which would produce emissions incompatible with climate targets.
The UK Health Alliance on Climate Change has spoken out repeatedly about the need to transition away from fossil fuels due to concerns about the significant harms to the climate and health posed by the Rosebank and Jackdaw oilfields in the North Sea. These oil and gas fields in the UK would be at odds with the Government’s clean energy and health missions and its commitment to deliver clean power by 2030 and to shift from sickness to prevention.
The health impacts of burning fossil fuels are already being seen, from increasing risk of pregnancy complications and increasing incidence of children with asthma, to greater risk of stroke, acute kidney injury, and premature death in older adults. A new report published by UKHACC has highlighted the wider impact of climate change on the health system. Recent polling has found that almost half of UK health workers have already experienced NHS services being disrupted because of extreme weather and more than two thirds have been unable to get to work because of extreme weather.
Our health systems will see increasing patient demand as a consequence of climate change risk factors, and our health infrastructure is at risk from over-heating, flooding and other unpredictable extreme weather events.
The UK also has a global obligation to account for cumulative emissions and historical contributions by cutting emissions more rapidly and to meet commitments made at COP28 to transition away from fossil fuels. If the UK consents to new fields, it both weakens its diplomatic standing and threatens the health of millions.
The UK Government now has the opportunity to demonstrate its ambition to reform the UK’s energy system to one driven by clean power. It is a chance to deliver on its global commitments to phase out fossil fuels by rejecting any calls from the energy companies behind the fields to issue new licences. This would send a powerful signal to the world and signal the UK’s position on a green energy future. Failure to do so would fly in the face of achieving emissions reduction targets to limit global heating, weaken the UK’s influence globally, and threaten the lives and livelihoods of millions.