Q2. Why should I respond to this consultation if the Environment Agency is reviewing the proposals?

1. Weak regulations and monitoring means public scrutiny and pressure is needed

The Environment Agency prohibited reinjection of waste fluids at Brockham in November 2018 because of concerns over risk to groundwater. Reinjection had been allowed at the site for well over a decade (since 2002 and since 2007 also from Lidsey)  with very little regulation and no monitoring of groundwater. In particular, during their assessment of Angus Energy’s operation in 2018 the EA found and/or confirmed that: 

• There was no cement bond log available for the reinjection well so its integrity could not be verified (leaky wells mean risk of pollution discharge directly into the aquifers).

• Angus did not have procedures in place to monitor well integrity during reinjection. In response to the EA’s queries, a new procedure was created, specifying that well pressures would be monitored once a quarter(!) instead of in real time during an injection (which is how it should be done).

• There has never been any groundwater monitoring by the oil companies or the regulators at Brockham.

• The EA did not require the reporting of information as basic as the volumes of waste fluid reinjected at Brockham in a given period.

Regulations have improved, but there are still areas where we have doubts about the robustness of pollution control mechanisms. Monitoring of oil and gas operations relies heavily on self-reporting by the operating companies. The Environment Agency’s monitoring is limited mainly to periodic site visits and checking documentation during those visits. Important areas are completely exempt from regulation, such as for example monitoring the toxicity and radioactivity of waste fluids (see pt. d here). 

A recent peer-reviewed academic paper, which includes a case study on Brockham, highlighted the failure of regulation of the geological aspects of unconventional oil and gas sites. This has potentially severe implications for environmental safety because geological pathways – if not properly understood and mitigated – may lead to long-term pollution of groundwater and surface water. 

It is because of these regulatory weaknesses that it is so that important that local (and all concerned) people show their interest and apply pressure to make sure all aspects are properly considered. It works, as you can see from the comment in 2018 EA’s decision:

2. Angus Energy’s record of brazen non-compliance and dishonesty

The EA should be reminded of this as often as possible – they do take it into consideration!

Angus Energy first became known in the local community when it made it to national papers for drilling an unauthorised sidetrack well in 2017. Angus have been repeatedly criticised by the regulators: the Oil and Gas Authority, the Environment Agency and Surrey County Council. The company made it to national titles again in early 2019 because of a boardroom power struggle involving high-profile individuals and irregular share dealings. Read more on our website.

3. Angus Energy’s record of questionable competence, specifically around reinjection 

As above – the EA takes these concerns into consideration.

We already mentioned above that in 2018 the Environment Agency discovered that Angus did not have procedures in place to monitor well integrity during reinjection. This was after reinjection had been going on for years at the site. In response to the EA’s queries, a new procedure was created. This appeared to show that Angus did not understand how well integrity should be monitored. The procedure specified that well pressures would be monitored once a quarter(!) instead of in real time during an injection. If you think this sounds extraordinary, we agree. See for yourself the comment in the Environment Agency’s decision document from November 2018.