Dear BOW Supporter,
PROFESSOR DAVID SMYTHE’S EXPERT OPINION
We are very grateful to David Smythe, Emeritus Professor at the University of Glasgow, who submitted his expert technical commentary in support of our representation to Surrey County Council on the current application. Prof Smythe highlights that inadequate information has been shared with the council for a reliable assessment to be made. His analysis of the available detail concludes that sidetrack BRX4Z was drilled close to a major fault possibly targeting the damage zone of the fault to increase the flow (to emulate the results at Horse Hill-1, nick-named the Gatwick Gusher). This carries an environmental risk, because if any kind of stimulation is applied, the fault zone may become permeable and therefore be a ‘fast track’ to the near surface environment.
Prof Smythe says also that the applicant’s arguments that stimulation of the Kimmeridge Clay Formation (the target of BRX4Z), whether by acidisaton or by fracking, will not be necessary are incredible, because they run counter to the known geomechanical properties of the KCF, and because they conflict with the extensive experience of similar unconventional plays in the USA.
Angus Energy admit that the target Kimmeridge layers are an interbedded shale and limestone hybrid reservoir, yet they describe themselves as a ‘conventional’ oil & gas company at every opportunity, and re-iterate that there will be no hydraulic fracturing because the Kimmeridge is naturally fractured. Professor Smythe points out that the natural fractures (which are visible in the outcrop at the Kimmeridge Bay) are vertical, so it is difficult to see how lateral drainage (from a near vertical well) of the reservoir can be achieved. In any case, even if an unconventional reservoir is naturally fractured, it will still require the drilling of back-to-back wells in order to drain the fractures efficiently, and it will likely require acid stimulation. (1)
Acid stimulation is a type of fracking performed on limestone or sandstone-rich shale that dissolves the rock enlarging or creating new fractures. Unfortunately, acid stimulation, like hydraulic fracturing using fluid volumes below the arbitrary threshold set out in the Infrastructure Act 2015, is exempt from the Government definition of ‘associated hydraulic fracturing’, and from the regulations introduced by the IA2015.
ENVIRONMENT AGENCY AND RE-PERMITTING OF BROCKHAM
Meanwhile, we’ve also been in close communication with the local Environment Agency team, who shared their comments to SCC on the current planning application with us. The EA is currently reviewing the existing environmental permit at Brockham as part of a national review to bring all permits to a modern standard. This process started some time ago for Brockham, and there was already one public consultation in July 2017; but because of gaps in information provided by the applicant, the EA has had to request more detail and so the re-permitting process continues. There will be a second consultation once the additional information is submitted, and the earliest this can happen is July 2018. The permit would not be issued until the results of the consultation are evaluated and the assessment is complete.
There is therefore a mismatch between the timescales for the consideration of the planning application to be decided on 20th June and the re-permitting process currently being undertaken by the EA. The EA do not yet have the information that they need to assess the activities proposed by Angus, to decide whether to grant a permit, and to set the terms and conditions for such a permit.
In particular, the EA lists the following items that are yet to be determined:
- Whether what Angus Energyis proposing constitutes appraisal or production from the Kimmeridge Clay Formation.
- How much gas will be produced from the Kimmeridge formation, and whether the flare falls into the emergency only category or if it may be used for gas disposal.
- Whether any stimulation is proposed (stimulation includes processes such as matrix acidising, acid fracturing or hydraulic fracturing) to appraise the Kimmeridge Clay Formation and what activities are underway in the Portland Formation.
- What is the composition of fluids to be re-injected at Brockham (is it produced water, or flowback from stimulation activities; is it from Brockham only, or from other wellsites, such as Lidsey as well)
Until the new permit is in place, the site operates under the old-style permit, under which none of the above is either clarified or monitored. This means that Angus can carry out stimulation (with acid or hydraulic fracturing) so long as the volumes of fluids injected are below the levels specified as ‘associated hydraulic fracturing’ in the Infrastructure Act 2015, and they will not even need to notify the EA of what they are doing. This is all the more worrying because there is no groundwater monitoring in place at the moment, even though it will be required going forward because of the risk of pollution from re-injection. There is no air quality monitoring in place either, but this will also be required as part of the new permit. Until then, monitoring of site activities can only be carried out via site inspections and verbal interaction with Angus staff. Given the track record of Angus Energy, we are very concerned about this.
With decision on this application postponed again until 11th July, comments are received until 12 noon on 10th July. Please see here on how to object.