New Environmental Permit at Brockham

Dear BOW Followers,

Back in May, we have discovered that Brockham was operating under an old environmental permit that did not regulate or require monitoring of many risky activities, including: waste water reinjection (from Brockham and Lidsey), injection of acid and chemicals, gas flaring or burning in a generator, etc. This was particularly concerning given the plans of Angus Energy to start production from unconventional shale rock, which is likely to require stimulation with acid to flow hydrocarbons, producing significant amounts of associated gas.

We have been campaigning about this issue since, through various avenues including a petition signed by over 27,000 people, to bring pressure onto the Environment Agency to close this loophole. We have a partial success to report.  The Environment Agency have accepted that the old permit didn’t offer sufficient control and have moved to issue a new permit. Crucially, this new permit doesn’t allow acid stimulation or reinjection of contaminated waste water.  

Whilst we are relieved that reinjection of water produced at Brockham and Lidsey is no longer allowed to take place it is very unsettling that this process has been taking place virtually unregulated over the years at Brockham and other sites. There is still no requirement for groundwater monitoring at Brockham under the new permit, which also sidestepped the long anticipated public consultation.  Local people and independent experts have thereby been denied the opportunity to properly scrutinise and comment on the proposals.

There are a number of detailed conditions in the new permit that the operator needs to fulfil before they can start the new work. We will be following this process closely. This also means that Angus have been slowed down somewhat with the new type of extraction, which they had been planning to start before the end of the year.  

You can read a full report on the new permit here.

We remain very concerned about the loophole in the national regulatory regime with respect to the regulation of acid based stimulations. This issue affects Brockham (even under the new permit) as well as other sites in the Weald Basin, and beyond. Now, that the old environmental permit loophole was closed, and the planning permission was granted despite the many objections, we are shifting our focus onto this issue. You can read about it in more detail here.

In the meantime, we have started our own air monitoring regime and collected surface and groundwater samples to establish baseline environmental data before work on the unconventional Kimmeridge shale and micrite layers begins.

 If you would like to donate to our crowdfunder to help with our independent monitoring work, you can do so here.  Any contributions gratefully received.

Thanks so much for your support – it’s making a difference! 

Twitter: @BrockhamWatch


Meeting in Horley Tomorrow 7:45pm / Permitted Development – NSIP Consultation DEADLINE THURSDAY

Dear BOW Followers,

We were very relieved to hear the amazing news that there would be NO drilling at Leith Hill (Holmwood), but the threat to the Weald and south-east England remains and stretches as far as the Kimmeridge rocks the drillers are targeting. If you missed our July public meeting about earthquakes and acidisation, or if you would like to hear more about these hot topics, and about how to get involved, join tomorrow:

“Back to back” wells are Horse Hill?

Catholic Church, 4 Vicarage Ln

Horley RH6 8AR

Tuesday 23 October, 7:45pm


11:45pm this Thursday, 25 October is the deadline for responses to the consultation on the proposals to:

  1. Make non-hydraulic shale gas exploration a permitted development (i.e. not needing planning permission)
  2. Include shale gas production projects in the Nationally Significant Infrastructure Project (NSIP) regime

Frack Free United produced very handy guidelines for folks pressed for time. It really should only take a few minutes to respond! Link to guidelines here.

Why is this directly relevant also in the south-east? Here are our thoughts:

Point 21 of the permitted development consultation document states that the appropriate definition of shale gas exploration could be:

‘Boring for natural gas in shale or other strata encased in shale for the purposes of searching for natural gas and associated liquids, with a testing period not exceeding 96 hours per section test’.”

 We believe that the following interpretation is possible: that strata encased in shale could be micrite (what the drillers incorrectly call limestone) and associated fluid could be oil.

We also don’t see anything that could stop oil companies using the right in the Weald Basin to drill for gas within their licensed areas as a pretext for their real target, which is oil. They could simply follow on from shale gas exploration to oil development appraisal and/or production.

The NSIP consultation document gives a clue on page 9:

The areas in England identified by the British Geological Survey with potentially large reserves of shale gas and oil are the Bowland-Hodder area in northern England and the midlands and the Weald Basin in Southern England.

 So much happened last week.. The first high-volume fracking since Cuadrilla’s foul start in 2011 started last Monday, 15 October at Preston New Road. On Wednesday, the three protesters recently jailed for anti-fracking protest were freed as the appeal judge said their sentences were “manifestly excessive”, while the judge who sent the “Fracking Three” to jail was accused of having links to the oil industry, and is now facing an investigation by the Judicial office. On Friday, a series of tremors was reported around the Preston New Road fracked well. Professor David Smythe posted a blog on this today.

Dorking Advertiser – 16 Aug Article Headline

You may have seen the article on page 7 of the Dorking Advertiser yesterday that bore the headline “Earthquakes NOT linked to oil drilling in the county”.

Whilst the article is factually correct, it omits many things that were said, and the headline is totally misleading.


The article fails to point out that the planning case officer said:

“we’ve had a response back from the OGA (the Oil and Gas Authority) and they have confirmed that they have consulted with the BGS (the British Gelological Survey), and academic experts and at this stage, they find it very difficult to see how the resumption of small volume production and water reinjection at the Brockham field could have triggered the recent seismic events.”

 “the OGA have said they will be auditing the records for the Brockham field regarding the reporting of production and injection volumes, and (…) if they see any evidence that operations at the Brockham field have resulted in seismicity, then they will instruct Angus to change their planned activity.”

This account suggests that a causal link cannot be ruled out at this stage, and is at odds with the statement made by the Deputy Development Planning Team Manager, Stephen Jenkins, which was reported in the Dorking Advertiser. Mr Jenkins said:

“but they” (the OGA) “are preparing a statement along those lines, that there is no causal link between the earthquakes and particularly Brockham. It’s the distance and the low levels of volumes that are important here.”

Mr Jenkins also said, concerning the Oil and Gas Authority:

“We’ve just got an initial email, and they haven’t made a formal statement, but that is coming.” 

But the Dorking Advertiser reporter quoted a spokeswoman for the OGA that

“no statement to the public about the earthquakes had been planned”

 and that

“Based on the evidence it is difficult to see how oil and gas activities in the area could be linked to these seismic events.”

So, according to the spokesperson, the OGA are not ruling out a causal link based on available evidence.

We would also like to refer you to a letter sent by four eminent academic geologists to the Secretary of State, Greg Clark, and the Chief Executives of Surrey County Council, the Oil and Gas Authority, the Environment Agency and the Health and Safety Executive. Its shorter version, copied below, was published in the Times on 6th August 2018. The letter calls for a moratorium on all drilling, re-injection and flow testing until the records of fluid injection and local faulting activity have been comprehensively surveyed and interpreted, and the triggering mechanism for this quake cluster properly understood. One of the signatories is none other than Prof Richard Selley, a resident of Brockham Park.

In the light of this, are you reassured by the statement of Mr Jenkins? Or do you, like us, the BGS and several prominent scientists, think that a causal link is possible and more analysis is needed?



Our thoughts on SCC’s decision to grant permission for 3 years

Surrey County Council Planning Committee has given the go ahead to plans for further oil extraction at Brockham – despite a call by leading geologists for a temporary halt to hydrocarbon exploration in the area in Surrey following a swarm of 12 earthquakes.

The scientists are concerned that activities at either nearby Horse Hill or Brockham may have contributed to the recent earthquake swarm and that the earthquakes might have compromised the safety of existing wells.

We’re shocked and disappointed that the members of the planning committee so blatantly ignored the advice they’ve received from experts.

It appeared that the committee was swayed by a-last minute intervention from the Oil and Gas Authority, who officers said was the regulatory body responsible for monitoring and responding to seismic activity. An unofficial statement from them was read out at the meeting saying that it was unlikely there is a causal link between reinjection at the Brockham site and the earthquakes.

They seem to have ignored the significant increase in volume of reinjected water at Brockham reported for April, which coincided with the onset of earthquakes. We think this is concerning and any relationship between the two needs to be investigated further given that wastewater reinjection has been proven to be the main cause of earthquakes in the Central U.S.

We would also like to point out that the data available on the OGA’s portal is several months old and only an aggregate monthly number of water injected is provided. It is insufficient for any kind of credible analysis. We are calling for detailed and up to date records of injection data at Brockham to be immediately released to allow for independent analysis.

The Oil & Gas Authority can hardly be regarded as independent or impartial. Its objective is to support the industry  in maximising the economic recovery of oil and gas, and it is largely funded by an industry levy. We are disappointed that the planning officers relied on such advice in favour of the recent advice from a group of leading independent geologists.

The planning permission was granted for the full three-year period, even though appraisal phase normally takes weeks not years. Angus Energy explained that this was necessary to test a new geology.

This is a cause concern, as Angus are targeting an entirely new geology that has never been produced from anywhere in the country, whilst operating under an old style environmental permit. Astonishingly, under the existing permit, there is NO monitoring of many of the proposed and ongoing activities. This puts the local environment and people at risk.

The Brockham site is currently going through a re-permitting process by the Environment Agency, a process that started over two years ago. It is unclear when the new permit will be put in place. The EA didn’t submit an objection to the proposals, but they did submit a comment to inform planning officers that a number of issues are still being evaluated and additional data is being sought from the operator, including on the flaring of gas, well stimulation treatments using acid, wastewater re-injection.

We are convinced that Angus will attempt to start commercial production under this appraisal permission, which is what they had consistently told their investors. This is reminiscent of the events in January 2017, when Angus drilled an unauthorised sidetrack whilst openly communicating this to investors. It clearly demonstrates a cavalier attitude from Angus to both the local authority and the local community. The assurances from the planning authority that they will expect the maximum standards of professionalism and transparency gives us no confidence whatsoever.

This permission was given against the objections by the Parish Council, the Mole Valley Council and the local people. When this operation begins, it will make the area less desirable to live in and only Angus board members and investors are set to prosper.


Link to webcast from meeting.

Letter From Four Geologists Calls For a Moratorium on Hydrocarbon Exploration In The Area Affected By Earthquakes (Including Brockham)

Dear BOW Followers,

Please see below an open letter on the recent cluster of earthquakes in Surrey published on Monday (6/8/18) in the Times newspaper. An accompanying article is at this link.
The letter is directly relevant to the current planning application for the Brockham well site, which will be decided on Wednesday morning (8/8/18) at County Hall, Kingston upon Thames, Surrey KT1 2DN. The meeting starts a 10:30am and is open to the public. 
A longer version of the letter was sent to Greg Clark, the Secretary of State for Business, Energy and Industrial Strategy and the chief executives of Surrey County Council, the Oil and Gas Authority, the Environment Agency and the Health and Safety Executive and has been written by four leading academic geologists from both sides of the “fracking” debate, including Professor Richard Selley who resides in Brockham.  
The letter calls for a moratorium on all drilling, re-injection and flow-testing in the affected area be put in place immediately, to remain in force until the records of fluid injection and local faulting activity have been comprehensively surveyed and interpreted, and the triggering mechanism for this quake cluster phenomenon is properly understood, and that, in the interest of safety, a respect distance is made mandatory when drilling near faults.
A related article in Drill Or Drop goes into more depth on the available data on fluid injection.

Also on a related note, the complete set of videos and slides from our recent public meeting discussing the earthquakes and the current application are now available here.




Twitter: @BrockhamWatch


Public Meeting – 25th July

On Wednesday evening, 25th July, we gave a presentation to a crowded Brockham Village Hall Bar concerning this current application as well as recent earthquakes and potential connections with oil & gas activities at Brockham and Horse Hill.  Until the British Geological Survey results are known then no-one can say definitely that the earthquakes were caused by the oil companies activities but there is wider evidence linking oil and gas activities with increased seismicity.


You can view the presentation here


PART 1 – Earthquakes 

PART 2 – Earthquakes Continued

PART 3 – Brockham Planning Application MO/2018/0444

PART 4 – Brockham Planning Application MO/2018/0444 Continued


BROCKHAM DECISION – Wednesday, 8 Aug 2018, 10:30am, Surrey County Council in Kingston

Dear BOW Followers,

After several delays, the Surrey planners have now confirmed that the decision over Brockham (part retrospective) application for unauthorized sidetrack BRX4Z (drilled over 1.5 years ago!), its appraisal, and the retention of donor well (which should have been plugged years ago) is on the agenda for Surrey County Council Planning and Regulatory Committee meeting on 8th August at 10:30am at County Hall, Kingston upon Thames, Surrey KT1 2DN. (Link to Drill Or Drop Report).

Officers are recommending APPROVAL for the entire period of 3 years, which we are particularly worried will allow Angus to move into commercial production under the benefit of this appraisal permission (if granted). Angus have clearly and consistently confirmed this plan to investors via official channels, and we have pointed it out to the officers, but they seem to have ignored it.

So, if granted, this application will allow for the first very long-term testing/commercial production from the unconventional Kimmeridge rocks in the Weald Basin. These rocks have never been produced from anywhere.

This is concerning because, according to expert opinion from David Smythe, Emeritus Professor of Geophysics in the University of Glasgow, these rocks can only be produced with the use of acid stimulation or fracking.

What’s even more concerning is that the Brockham site is operating under an old-style environmental permit (read article on this here), which neither regulates nor monitors many of the activities associated with production from the rocks: gas flaring and operation of an enormous generator*, well stimulation treatments, and also the ongoing practice of water re-injection, which has created so much concern as a potential cause of the recent swarm of earthquakes in Surrey.

The old style permit will be in place for as long as Angus take to provide the Environment Agency with all the information needed to assess the issue of a new permit (this process has already taken well over a year and there is no end in sight). In the meantime, operations at Brockham are allowed to continue, including the new type of processes required when extracting oil an entirely new, tight geology. We think that this is nothing short of shocking.

The officers failed to mention any of this in their report, even though they received Prof Smythe’s expert opinion, and we made them aware of the risk the approval of this application creates for Brockham whilst it operates under an old-style environmental permit.

So we’d like to urge you to comment if you have not yet done so. You can read more about the issues above here (includes instructions) and here.  You can also find our very popular blog on earthquakes and oil & gas operations here.

And if you are planning on attending the meeting on Wednesday, 8th August, please get in touch with Val on 01737 844013 or email us at


*We are very grateful to Frack Free Balcombe Residents Association for their expert submission to SCC regarding emissions to air at Brockham. Angus submitted the relevant technical assessments only in mid-June, at the 11th hour in the assessment of this application. FFBRA point out that the assessments show potential significant impacts of releases of nitrogen dioxide, volatile organic compounds (ex. Benzene, a carcinogen) and H2S (Hydrogen  Sulphide), and that a detailed assessment is needed. Testing of the composition of gas from the Kimmeridge is also needed as much of the assessments are based on entirely unsupported assumptions.


On Wednesday evening, 25th July, we gave a presentation to a crowded Brockham Village Hall Bar concerning this current application as well as recent earthquakes and potential connections with oil & gas activities at Brockham and Horse Hill.  Until the British Geological Survey results are known then no-one can say definitely that the earthquakes were caused by the oil companies activities but there is wider evidence linking oil and gas activities with increased seismicity.

You can view the presentation here and the video (Part 1) here.





Twitter: @BrockhamWatch