We are disappointed with the decision of Mole Valley Development Control Committee on 2nd August to vote “no objection” to Angus Energy’s retrospective application for onsite facilities upgrades at Brockham and that Cllr Muggeridge (who is also a Brockham Parish councillor) spoke in favour of this application despite the stated position of the Parish Council that consideration of this application should be deferred until the legal dispute over recently drilled sidetrack is settled. (Surrey County Council said that sidetrack BR-X4Z was drilled without planning permission and that it is not permitted for production.)
We think that by passing the current application as “no objection”, MVDCC appears to be accepting Angus Energy’s attitude of contempt and disregard for local planning and local people, and it is enabling them to carry on with business as usual. MVDC’s decision is important because it is one of the consultees whose opinion the Surrey Council will take into account when making final decision on this on 13 September.
We wish to thank Cllr Wellman and others who raised the above issue and voted to object. You can see the webcast here (from 1:18). BOW has submitted the following to SCC to supplement our original representation.
Brockham Oil Watch
REF: Planning Application SCC/2017/0089 (MO/2017/0916) Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – Installation of on-site facilities
We wish to comment on the decision of the Mole Valley Development Control Committee on 2 August to pass this application as “no objection” and we would like these comments to be taken into account in the Surrey Council Officers’ Report. The arguments given in favour at the MVDCC meeting were that the upgrades will support production from other wells, that are not subject of a dispute, and that the site has a long term production license until 2036 so it was responsible of the operator to upgrade facilities.
It is true that production license is valid until 2036, but the site has not been operational since January 2016, and Angus stated on several occasions through official investor channels (1 p.21, 2) that the upgrades were made in preparation for the new oil production planned from sidetrack BR-X4Z, which is the subject of the current planning dispute. There is only one other production well on site, which had only produced small amounts of oil before being suspended in January 2016 to allow for the upgrade works. The third well is a water injector well, and it depends on production from the other wells.
Therefore, there is a direct link between the current application and the disputed sidetrack. We believe that no application should be considered until the dispute is resolved, but this direct link should certainly not be ignored. Despite several of the councillors raising the above issue and MVDCC meeting, this application was passed because the majority of voting members and the Officers’ Report did not make the connection..
On the point of Angus being a responsible operator, their track record at Brockham suggest otherwise:
- Angus bought the Brockham field in 2012, but has not focused on this site until 2016, when they raised £3.5M for planned works.
- During 2016 Angus carried out surface upgrades without planning permission (this is the subject of the current retrospective planning application).
- In Dec 2016/Jan 2017 Angus drilled sidetrack BR-X4Z without planning permission (according to Surrey Council). They did so against repeated advice from the council before drilling and despite site visits from the council enforcement officers just before drilling. They misled the council and the local community when drilling was underway by telling them they were only doing maintenance works.
- During the drilling operations, Angus were understood to be carrying out maintenance under an existing planning permission. Angus breached a condition on that permission as well by working at night for over a week. The locals also observed HGV vehicles not following the designated route to site.
- Angus confused the well numbering and reported to Surrey that they were re-entering Brockham-X1, when in reality it was BR-X4.
- Angus breached a condition of their environmental permit (regarding containment of stored materials) when they were on site in Dec 2016/Jan 2017 (CAR 403648/0278191 issued 3 Feb 2017)
- Angus refused to apply for retrospective permission for drilling or for production from BR-X4Z. They insist that they had all the required permissions and promise to investors to be in production by the end of the summer. Surrey County Council disagrees but they have not taken enforcement action and still awaiting legal advice.
- Angus also indicated the intention to drill more wells at Brockham. They maintain that they have permission for 6 wells (so additional 3 to what’s already on site). Surrey County Council disagrees.
Angus Energy are planning to start production from the Kimmeridge limestones, which have not been produced from before (presumably because there was no technology that would make it viable). The Kimmeridge limestones were first tested in 2016 at Horse Hill – nick-named the Gatwick Gusher after flowing over 1,350 bopd. This level of production would have significant planning consequences at Brockham (the site recently produced only c.35 bopd and the production license granted in 2001 refers to 195 bopd.)
The Kimmeridge Limestones are a tight-oil reservoir of very low permeability and commercial extraction will likely require acid stimulation (3). Acidisation* involves pumping of large quantities of acids and other chemicals below ground to dissolve the rock and release oil. There are few studies on health and environmental effects of this technique and it is poorly regulated in the UK. Acidisation has a longer history of use in the US: in California it is regulated in the same way as hydraulic fracturing, and in Florida, many counties and municipalities have passed ordinances to ban it (4). This is even more of a reason to make sure that the rules in place are followed.
We maintain our position 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.
*By acidisation we mean “matrix acidising” and “acid fracking” – well stimulation treatments used to extract oil. Acidisation can also refer to a routine well maintenance process used by the industry to clean out boreholes, which is also known as an “acid wash.” This confusion in definitions is part of the reason why we think that regulation is not good enough.