Application SCC Ref 2021/0165; MO/2021/2103

Dear All

The planning application we highlighted in our last update is under public consultation until 20 December.

It seeks consent to perforate the upper section of the BRX4 well to produce oil from the Portland sandstone reservoir until 2036 as well as to abandon the controversial sidetrack BRX4Z, drilled in 2017 without planning permission.

See the application here and a summary in Drill Or Drop? here.

To comment on the application online click on the link below or email your comments to mwcd@surreycc.gov.uk, including either SCC Ref 2021/0165 or MO/2021/2103 as well as your name and full postal address – your comments won’t be accepted without these details. Email a copy of your comment to all levels of your elected representatives (find them here) and Helyn Clack, Surrey County Councillor for Dorking Rural helyn.clack@surreycc.gov.uk

https://planning.surreycc.gov.uk/plancomment.aspx?AppNo=SCC%20Ref%202021/0165

We offer three reasons to object to this application (with thanks to the Weald Action Group for helping pull together detail for reason 3):

1. Production = Waste reinjection

As stated numerous times by Angus Energy, in order to restart production from the depleted Portland reservoir, Angus will have to reinject waste fluids in the BR3 well to maintain pressure support in the reservoir (see here, here and here). The company said the volume of produced water from Brockham alone was “insufficient to restore reservoir pressure to the target pressure” and therefore waste from all over the Weald Basin would need to be trucked into Brockham to restart production.

This would mean truckloads of toxic, radioactive and salty waste fluids coming through local country roads to be disposed of at Brockham. This also means a real risk of groundwater pollution, which is the reason why the Environment Agency (EA) prohibited reinjection of waste at Brockham in 2018. In addition, science tells us that reinjection of fluids can cause earthquakes and Brockham is located in a recently seismically active area.

A proposal to allow reinjection at Brockham again is currently under review by the EA. In our view, a positive decision would be a major retrograde step. See our detailed Q&A for the EA consultation here as well as detailed reviews by geophysicist David Smythe and hydrologist David Walked accessible from here.

Angus would also need a planning consent for reinjection, but as far as we’re aware, they’ve not applied for this yet.

In summary, as reinjection of waste fluids is necessary to provide pressure support to enable continued oil extraction from the conventional Portland Sandstone reservoir, we are opposed to any plans to restart production from this layer due to the associated unacceptable environmental risks. This means that the current application should be refused and that all wells at Brockham should be properly plugged and the site restored.

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

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 criticised by the Oil and Gas Authority for lack of clarity and documentation of the drilling operations, and by the Environment Agency for their operating procedures not being up to the required standard. Tim Hall, who is the chair of Surrey County Council’s Planning and Regulatory Committee called Angus “the least reliable hydrocarbon applicant we have dealt with” and expressed his frustration at how Angus and other firms are playing the regulators off against each other. Another Surrey councillor accused the company of repeatedly betraying trust. 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. Climate change & No need for oil

Last but not least, restarting long-term oil production from a field which has been unproductive for years goes against the policy direction to reduce climate change impacts, as highlighted by recent developments (see below). Contrary to the applicant’s assertions, there is no mention of the strategic importance or need for further onshore conventional oil and gas exploration in current Government energy policy. Below is a summary of main points, please see a detailed objection highlighting these issues filed by the Weald Action Group.

• Mole Valley District Council resolved at a recent Council meeting to take a stand against the extraction and use of fossil fuels in the district and Surrey County Council declared a ‘climate emergency’ in 2019
• The International Energy Agency has said there is no room for new oil if we are to limit warming to 1.5°C: “There is no need for investment in new fossil fuel supply in our net zero pathway.” International Energy Agency, May 2021
• Boris Johnson said at COP26 on 10 November 2021: “What we want to do is move beyond hydrocarbons completely in the UK and do it as fast as possible.”
• The UK Climate Change Committee’s Sixth Carbon Budget, (Dec 2020) said: “Our Balanced Pathway sees an 85% reduction in UK oil demand”

Also of note:

• A recent briefing by the Weald Action Group Why we don’t need more onshore oil in the UK argues that we don’t need new oil for the UK’s energy security
• Ken Cronin, then chief exec of UK Onshore Oil and Gas (UKOOG), sent a statement to the Horse Hill judicial review hearing in 2020 which said: “the UK exports 85% of the oil produced here”