Open letter to the Government asks for a ban on all forms of fracking

BROCKHAM, SURREY, 2 November 2019 – The Government’s announcement today to end its support for fracking is welcome news, but the moratorium covers only high volume hydraulic fracturing as defined by the Infrastructure Act 2015. It does not cover other forms of stimulation of oil and gas wells, including acid stimulation.

This is despite studies conducted abroad suggesting that many of the risks and concerns surrounding hydraulic fracturing are the same as for acid stimulation, namely induced seismicity, air and noise pollution and groundwater contamination. This has not been well studied or publicised in the UK, despite a number of communities across the country potentially affected.

So today we are launching a legal briefing that sets out the loopholes and ambiguities that exist in the legal and regulatory position surrounding the use of acid stimulation in England. The briefing is titled Acid Stimulation: Fracking by Stealth (available on request) and co-authored by Brockham Oil Watch and Harrison Grant Solicitors, with scientific Advice from David K. Smythe, Emeritus Professor of Geophysics, University of Glasgow.

We are also launching an open letter to the Government based on the recommendations of the legal briefing. We are asking for 1) an amendment of the definition of fracking in the Infrastructure Act 2015 to include all well stimulation treatments which may enhance the productivity of oil and gas wells by increasing the permeability of the target rock, and 2) a permanent ban on all well stimulation for oil and gas exploration and production. We are inviting signatures from campaign groups, environmental groups, elected representatives in the affected communities, academics, NGOs and other supportive individuals and groups.

One specific recommendation of our briefing is that the traffic light monitoring system to monitor and manage induced seismicity should apply to all well stimulation treatments, not only high volume hydraulic fracturing. This is further supported by the fact that the Preston New Road (PNR) tremors, which have brought about today’s moratorium, were caused by injections of fluid well below the volumes defined in the Infrastructure Act 2015 definition [1,2].

The largest tremor at PNR was 2.9ML whilst the largest tremor registered in Newdigate, Surrey was 3.1ML. Suspicions that the Newdigate tremors are caused by operations at the nearby Horse Hill site could be better understood with the implementation of a well-designed traffic light system and adequate reporting requirements.



Editor’s Notes

Open letter to the Government: Stimulation of oil and gas wells – reforms required is available at and legal briefing: Acid Stimulation: Fracking by Stealth is available on request.

About Brockham Oil Watch:    Brockham Oil Watch (BOW) is a non-political group of local residents concerned about the threat of unconventional hydrocarbon extraction from the Kimmeridge Clay Formation (or other unconventional reservoirs) at Brockham, and gaps in the current legislative/regulatory framework. For more information visit

About Harrison Grant Solicitors:    Harrison Grant provides experience and expertise in public law, planning and environmental law (including international law), human rights and advice on governance for charities and campaign groups. Noted for its role in high profile cases, it is recognised as a leading law firm of leading lawyers. For more information visit

About Professor Smythe: David K. Smythe is Emeritus Professor of Geophysics at the University of Glasgow. He took early retirement from the Chair of Geophysics in 1998 when the Department of Geology & Applied Geology was closed. He lives in France. His main current research interests are fracking, nuclear waste disposal, and nuclear accidents. For more information visit: 

The Newdigate Earthquake Swarm:   As of 2nd November 2019, 57 earthquakes have been registered in Newdigate. The strongest tremor measuring 3.1 ML was recorded on 27th February 2019.



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