Dear BOW Supporter / Follower,
Angus Energy have submitted their long-awaited planning application for the next stage of work at the Brockham Oilfield at Felton’s Farm, Old School Lane. The application is in three parts, and relates to well BRX4 where an unauthorised sidetrack was drilled last January.
Part 1 is for the retention of the BRX4 well. The well was drilled in 2007 under a planning permission that expired in 2008. According to the conditions relating to this permission, the well should have been sealed up and the land returned to its former condition, but this has not happened, and Angus are now applying for permission to retain the well for a further 3 years.
Part 2 is a retrospective application for permission to drill the sidetrack to well BRX4, BRX4Z (the unauthorised drilling that took place last year).
Part 3 is an application for appraisal of the production potential of the sidetrack BRX4Z using the production plant and equipment within the existing site plus some additional plant and equipment. Angus is applying for permission to undertake this work over the next three years, and they say that they plan to produce oil from the well for up to 18 months, during which time they will monitor the pressures and the flow. This information is to be used for a report to the Oil & Gas Authority and to inform a further planning application for production, should the appraisal show that there is oil in commercially recoverable quantities.
What will happen if the planning application (or parts of it) are refused
We do not know what will happen, but it is likely that Angus would appeal. If the appeal is successful then a Planning Inspector will grant planning permission. If it is unsuccessful, then enforcement action could be taken by Surrey to have the well shut down and sealed. However, the other two wells (BRX1 and BRX2Y) have a planning permission to produce oil until 2036, so it is unlikely that the whole wellsite would be restored for some considerable time.
What will happen if the planning permission is granted
The planning permission applied for will have a life of three years, during which time Angus would have permission to undertake the appraisal work on well BRX4Z outlined in Part 3 above. If it is successful, we should expect Angus to submit a planning application for further production in 2021, probably for the period up to 2036.
How you can comment on this planning application
The planning authority that will determine this application is Surrey County Council. You can find details of the application on Surrey County Council’s website here, or on Mole Valley District Council’s website here. Surrey County Council’s consultation period opened on 20 March and closes on 18 April. Representations can be made on the Council’s website, or by email to firstname.lastname@example.org, but remember to include the application no/reference MO/2018/0444 / SCC Ref 2017/0215, your name and address and to state that you are a local resident.
If you wish to make a representation to Mole Valley Council, this should be sent to them by 6 April, but be advised that they will not be determining the application. They simply provide their own response to Surrey.
Key issues that you may wish to consider
Environmental Impact Assessment: Surrey has provided an EIA Screening Opinion that EIA will not be required. We do not agree with this, on the basis that there could be significant environment effects, and that the precautionary principle should apply.
Target strata and extraction methods: Angus’ proposed targets are the conventional reservoir of the Portland Sandstone, and also the Kimmerdge Clay Formation, an unconventional shale reservoir beneath it. All of the oil extracted from Brockham since the 1980s has been from the Portland. However, the main interest of oil companies in Surrey and Sussex more recently has been the Kimmeridge. We believe that, in order to extract oil in commercial quantities from the Kimmeridge, permission to use unconventional methods such as the use of acid stimulation and/or fracking may be sought. However, at this stage, Angus say that they have no plans to use such methods at Brockham and that they will only need to use acid wash (done with smaller volumes and at a lower pressure than stimulation). The planning authority confirmed to us that should Angus decide they wish to frack or acid stimulate after this application has been approved, there will be no requirement for a fresh planning application..
To watch a video recording of recent talk by David Smythe, Emeritus Professor of Geophysics at the University of Glasgow. This talk is mainly about Leith Hill, but Prof Smythe explains why the Kimmeridge is unconventional and why it’s likely to require extraction methods such as acidising or fracking:
Length of the appraisal phase: As mentioned above, this application is for a period of three years, and Angus say that they plan to produce oil from the well for up to 18 months. In our view, the length of time proposed is excessive and completely out of line with the appraisal programmes of other operators in the Weald Basin, who have typically applied for a period of 4 to 6 months for appraisal works. For example, the recently approved well-testing application at Horse Hill was for 150 days (i.e. 5 months). Furthermore, we would draw your attention to the fact that Angus Energy has been telling investors for months that they plan to go straight into production on well BRX4Z. This is also corroborated by the fact their initial submission described the works as “production evaluation” and had to be revised before it was validated.
New plant and equipment: Angus propose to bring new plant and equipment onto site to deal with any gas from the well. They propose a portable generator and an emergency flare stack. The indicative plant proposed in the application is a 375kVA generator, approximately 6m long, 2.4m wide and 2.6m high, and a flare stack and shroud, 12 m high and 2m diameter. This is to convert and burn off excess gas, which is expected to be present in higher quantities in the Kimmeridge.
Road traffic: Angus say that the operations for which consent is sought will result in no more than 12 loads (24 HGV movements) on any single day, and that it is likely that daily movements will be significantly below this figure. These figures should be compared with the figure of 2 tanker movements per week for traffic using the wellsite in recent years. The designated route to the A24 is via Root Hill, Red Lane, Blackbrook Road and Mill Road.
Environmental permitting: Oilfield operations require an environmental permit from the Environment Agency which is a separate regulatory system from planning. Angus has an existing permit, but will require it to be updated before the appraisal operations can commence. The application for an updated permit was submitted in July 2017; a new permit has not yet been issued. We will keep people informed of its progress.
Brockham Oil Watch