Response to a letter from Stephanie Loo, Myles Allen & colleagues to the DESNZ Secretary of State about offsetting continued fossil fuel production with future CCS and engineered removals

A letter compiled by Stephanie Loo, Myles Allen and a small team of colleagues, and countersigned by a long list of academics and others, has called for any further North Sea oil and gas development to be conditional on producers taking responsibility for the permanent geological storage of the resulting CO₂, creating a direct link between fossil-fuel extraction today and carbon disposal tomorrow. It presents this as a way to mobilise private investment in CCS and carbon removal, reduce reliance on public subsidy, and ensure storage capacity develops in line with the UK’s carbon budgets.

The original open letter is available here.

My response to the letter was submitted to the Science Media Centre (the SMC) and is copied below, with the headline points highlighted before the main text.

Headline critiques of the letter:

• The ‘test’ is preventing dangerous climate change, not net zero by 2050.
• Every year of delay makes the required emissions cuts steeper.
• “Capture it later” must not become a licence to expand fossil fuels now.
• CCS/CDR remain unproven at anything like the required scale.
• Investment should accelerate fossil-fuel phase-out, not prolong dependence.
• “Difficult-to-abate” must not become a loophole for high-carbon consumption.
• The real question is how fast fossil fuels must be phased out.

Full response

The letter is right that limiting warming to “well below 2°C” requires fossil-fuel use to decline rapidly in the near term. What it does not confront is what “rapidly” now means. With global temperatures already at or around the more stringent Paris 1.5°C threshold, the remaining carbon budget for “well below 2°C” – taken as an 83% chance of not exceeding 2°C – requires global CO₂ emissions to fall by around 8% year-on-year. Against reductions of this order, the UK’s 2050 net-zero target is not the climate test the letter takes it to be. The relevant test is the original UNFCCC obligation to prevent “dangerous” interference with the climate system, given quantitative expression through the Paris Agreement and reinforced by the ICJ’s recent climate opinion. The question, therefore, is not how to make continued fossil-fuel development compatible with net zero by 2050, but how rapidly fossil-fuel emissions must now be cut, and ultimately eliminated altogether.

The timeframe should not be fixed at 2050: every year emissions fail to fall at the necessary rate, the required transition becomes more rapid. Since the Paris Agreement was signed in 2015, annual global emissions have continued to rise and are now over 10% higher than they were in 2015, yet policymakers and many ‘experts’ remain stubbornly wedded to the 2050 end date.

The proposed storage obligation in the letter risks giving the oil and gas industry precisely the get-out clause it has repeatedly sought: expand fossil-fuel production today and promise to capture the consequences tomorrow. After decades in which senior executives from across the industry have actively undermined and delayed serious climate action, giving them another route for postponing emissions reductions is profoundly dangerous.

With North Sea rig decommissioning, around half of the costs are ultimately borne by the taxpayer, in part because companies receive substantial tax relief for meeting their environmental obligations. Moreover, decommissioning liabilities are often agreed decades before expenditure is incurred, with assumptions about future inflation that can further reduce the industry’s eventual contribution by hundreds of millions of pounds. It is therefore not clear how far an obligation of the kind proposed in the letter would actually reduce public expenditure compared with state-funded CCS. While the idea may appear superficially attractive, it underestimates the industry’s longstanding ability to negotiate, defer and externalise the costs of environmental regulation.

Added to this, CCS is nowhere near the scale implied by the letter. After almost three decades of promises that affordable CCS is just around the corner, global CCS currently captures and, importantly, stores less than 0.1% of current fossil-fuel emissions. It is proving far more technically, energetically and economically challenging than its advocates have acknowledged. The assumptions around engineered carbon dioxide removal (CDR) are even more extraordinary. Yet CDR is increasingly embedded in climate scenarios as though it were an established technology, when, beyond laboratories and small pilot projects, large-scale engineered removal simply does not yet exist. Even if these technologies do prove scalable, relying on them to deliver at the necessary scale within the very tight remaining carbon budget for “well below 2°C” effectively amounts to an overshoot-and-return strategy: assuming temperatures can be allowed to rise while we cross our fingers that removals arrive at scale before climate tipping elements are triggered.

There is also a basic opportunity cost: every pound invested in extending fossil-fuel supply is a pound that cannot be invested in genuinely zero-carbon alternatives, whether reducing demand or developing clean energy. We should be accelerating that transition, not constructing mechanisms to prolong fossil-fuel dependence.

Finally, the letter’s reference to “difficult-to-abate” emissions needs much closer scrutiny. A significant part of the residual fossil-fuel demand envisaged in such scenarios is aviation, a highly unequal form of consumption disproportionately undertaken by wealthier citizens. Using scarce carbon budgets and speculative technologies to preserve high levels of aviation therefore risks privileging the consumption of the wealthy while shifting the costs and risks onto everyone else. CCS may well have an important role in genuinely impossible-to-abate industrial process emissions, such as those from cement production. But that cannot become a back door for maintaining high-carbon patterns of fossil fuel consumption for a select few.

The key question for journalists is therefore: why are we discussing mechanisms to make new oil and gas development compatible with a 2050 net-zero target, rather than asking how rapidly existing wells and fields need to be phased out to meet the much more fundamental obligation to prevent dangerous climate change?