Dear BOW supporters,
We alerted you recently about a new planning application from Angus Energy at Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – SCC/2017/0089 (MO/2017/0916). This application is for installation of on-site facilities and it is retrospective.
Surrey County Council decided to have a public consultation on this application. It is running until 31st of July so there is plenty of time to comment. It can be done via this link or by emailing firstname.lastname@example.org. You might also wish to send a copy of your comment to Mole Valley planning team at email@example.com as they will also be discussing this application in early August.
When commenting on an application, please make sure to include your full postal address. If you live outside of Surrey, you can still comment and it would be best if you could give a reason e.g. ‘I have family/friends in Brockham’ or ‘I am very concerned over acidisation’ or ‘I believe in sustainable energy not hydrocarbons/fossil fuels and believe that the UK should be implementing the Paris Agreement’, etc.
We have included below the BOW objection. Please feel free to use this to inform your comment, but do make sure to you use your own words and present your own concerns.
Subject: Planning Application SCC/2017/0089 (MO/2017/0916) Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – Installation of on-site facilities
We write to register a representation regarding the above planning application.
We wish to object to the application on the grounds of lack of need, and further request that its consideration be deferred until such time that the applicant has submitted a retrospective planning application for drilling of sidetrack BR-X4Z and an application for production from this well. It is a requirement for all planning applications to demonstrate the need for the development (indeed it is a material consideration). In this case, we consider that the applicant has not adequately demonstrated that there is a need for the development proposed. The application is for the installation of on-site facilities comprising hardstanding, site office, site toilet facilities, site security office and mess facility, storage containers, lighting units incorporating CCTV equipment, 2.4 metres high palisade fence and gates, electrical control buildings, 2 No site generators and a parking area for car/van until 31 December 2036, with restoration to agriculture.
With the exception of the CCTV installation and the parking area, all of the other items listed are essentially items of maintenance and renewal of existing site facilities which do not need a new planning application. Furthermore, planning permission MO/2006/1294 under which the continued use of general facilities for the production, treatment and export of crude oil on the site were authorised until 2036, included a condition (condition 4) that required the applicant to obtain Surrey County Council’s prior written agreement to erect, extend, install or replace any fixed plant or machinery, buildings, structures or private ways on the site. So the CCTV installation and the parking area could have been authorised by a simple submission under this condition of MO/2006/1294.
On close examination, we think that you will find the proposed new site office, site toilet facilities, site security office and mess facility, storage containers, 2.4 metres high palisade fence and gates, electrical control buildings and site generators proposed in the current application represent a considerable upgrade of the existing facilities, and we would contend that this upgrade can only possibly be needed to support a new drilling operation or increased oil production. (Furthermore, in their public information update on Brockham operations dated 26 June, Angus Energy says the upgrade works are ‘in preparation for the new oil production planned from the recent Brockham operations’, i.e. from the new sidetrack well BR-X4Z drilled in January of this year).
But the applicant has no valid planning permission whatsoever for drilling of any kind or for production from BR-X4 – the donor well sidetracked in January. Well BR-X4 was drilled in July 2007 – after permission MO06/1294 for production and export of oil until 2036 was granted (in May 2007), and therefore MO06/1294 does not cover production from well BR-X4.
We therefore maintain that, while there is no valid existing planning permission for the further drilling for hydrocarbons of any kind from well BR-X4, and no other planning application lodged for further drilling, there is no need at all for the upgrade of the site facilities which are the subject of this planning application. The application should, therefore, fail on the grounds of lack of need.
This position is even more important when taken in the context of the ongoing dispute between the applicant and Surrey County Council Planning Department over the drilling of sidetrack well BX-4Z. The applicant claims (and stated this numerous times to press and via the London Stock Exchange’s regulatory news service) that he has a permission for the drilling on the basis of previous planning permissions, but Surrey County Council is understood to disagree, and have asked him to submit a retrospective planning application to regularise the planning situation. Furthermore, the applicant has publicly stated in press releases that he has taken legal advice and that he believes that he also has a planning permission to produce from the recently drilled sidetrack, and that he has no intention to apply for retrospective planning permission. Again Surrey County Council disagrees, and has informed the applicant that he does not have a planning permission for the recently drilled sidetrack, for production from it, or to drill any more wells for any purpose.
It is also important to note that Surrey County Council informed the applicant prior to the drilling of sidetrack BR-X4Z that there was no planning permission for drilling operations. Despite this, the applicant continued with their plans, and when queried by the planning officers on the nature of the work as it was being carried out in December 2016 and January 2017, provided evasive answers, openly admitting to drilling only after it was completed. We are therefore of the opinion that the applicant abused the trust that is required between the public, the local authority and the operator to carry out subsurface oil drilling operations, and that this should be addressed first, before any other issue is considered. In addition, according to the applicant’s argument that drilling of sidetrack BR-X4Z was covered by previous planning permission for crude production, treatment and export until 2036, he seems to imply that he is allowed to drill any number of sidetracks from the existing wells (so long as they are subject to certain conditions) without the need for any additional planning permissions, which again contradicts the position of Surrey County Council.
In these circumstances, we believe that it would wrong to grant this planning application, and that it should be deferred until such time that the applicant has submitted a retrospective planning application for drilling of sidetrack BR-X4Z, as well as a further planning application for production from this same well, and that the current application be considered and determined together with, and at the same time as these two additional planning applications.