Awaiting Planning Application for BRX4Z

Dear BOW Supporter,

We have not been in touch in a while, but things are picking up again.

Angus Energy has recently made two important announcements relating to the Brockham Oilfield. On 25 Oct it announced that it will “submit a normalisation application for the continued surface activities of the production plant required for well BR-X4 and notably, its inclusive sidetrack BR-X4Z.” It remains to be seen whether this will include a retrospective application for the drilling of sidetrack BR-X4Z, and/or an application cover any further exploration, testing or production from that or other wells, as Surrey County Council have requested.
In the meantime, on 23 Oct Angus announced that it has received final approval from the Oil and Gas Authority to begin production from the Kimmeridge shale and limestone layers from well BR-X4Z. This is despite the national planning policy guidance suggesting that such consent should only be issued once planning application is in place.

Angus is planning to start production from the Kimmeridge layers in the first quarter of 2018, i.e. by the end of March. This will require the erection of a tall rig on the site, even if further drilling is not required, so that they can do further work on the well. If it goes according to plan, Brockham will be the first site in the country, where this unconventional reservoir will be put into production. They have also announced that they plan to generate electricity at the wellsite using a compression ignition (i.e. diesel) generator supplied with gas and volatiles drawn from the producing well.  Surrey County Council have informed us that this may need a further planning permission, but to date, no such application has been submitted.

Brockham Oil Watch is in regular communication with the Council, the Environment Agency and Health and Safety Executive regarding the planned operations at Brockham. The Environment Agency is in the process of evaluating Angus’ application for a variation of their existing environmental permit to produce oil and gas. We also understand that the EA will be issuing guidance on how the Agency classifies acidisation processes, and how it monitors oilfield wellsites to ensure that only the operations that are allowed within the scope of a valid permit are actually performed.
Please see more in the “news” and “blog” sections of our website.



Facebook Page


BOW Update – EA Consultation and SCC Planning Meeting

As you may know, the Environment Agency consultation period for Angus Energy Weald No 3 Ltd’s permit application for the Brockham wellsite has been extended and now closes on Thursday, 7th September 2017.  Responses can be submitted online on the EA’s Citizen Space website here:

We would like to share our response and invite you to use any part of it to formulate your own comment to the EA. It is available here.

You may also be aware that the County Council Planning and Regulatory Committee will be considering Angus’ recent retrospective planning application for the installation of new buildings, fencing, lighting etc. at its meeting at County Hall, Kingston at 10.30am on Wednesday 13th September.  Comments can be registered up until the date of the meeting. See our blog posts on this application here and here. Members of the public can also register to speak at the meeting.

On a related note, Surrey County Council recently confirmed that they received the Counsel’s opinion, which confirms the view of planning officers that the sidetrack drilled in January is unauthorised.

We would also like to share a brief letter by geologists David Smythe & Stuart Haszeldine published in Nature at the end of last month. It is relevant to Brockham and other well sites located in the UK Weald Basin.



Facebook Page

Mole Valley Development Control Committee

We are disappointed with the decision of Mole Valley Development Control Committee on 2nd August to vote “no objection” to Angus Energy’s retrospective application for onsite facilities upgrades at Brockham and that Cllr Muggeridge (who is also a Brockham Parish councillor) spoke in favour of this application despite the stated position of the Parish Council that consideration of this application should be deferred until the legal dispute over recently drilled sidetrack is settled. (Surrey County Council said that sidetrack BR-X4Z was drilled without planning permission and that it is not permitted for production.)

We think that by passing the current application as “no objection”, MVDCC appears to be accepting Angus Energy’s attitude of contempt and disregard for local planning and local people, and it is enabling them to carry on with business as usual. MVDC’s decision is important because it is one of the consultees whose opinion the Surrey Council will take into account when making final decision on this on 13 September.
We wish to thank Cllr Wellman and others who raised the above issue and voted to object. You can see the webcast here (from 1:18). BOW has submitted the following to SCC to supplement our original representation.


Brockham Oil Watch


Facebook Page


REF: Planning Application SCC/2017/0089 (MO/2017/0916) Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – Installation of on-site facilities

We wish to comment on the decision of the Mole Valley Development Control Committee on 2 August to pass this application as “no objection” and we would like these comments to be taken into account in the Surrey Council Officers’ Report.  The arguments given in favour at the MVDCC meeting were that the upgrades will support production from other wells, that are not subject of a dispute, and that the site has a long term production license until 2036 so it was responsible of the operator to upgrade facilities.

It is true that production license is valid until 2036, but the site has not been operational since January 2016, and Angus stated on several occasions through official investor channels (1 p.21, 2) that the upgrades were made in preparation for the new oil production planned from sidetrack BR-X4Z, which is the subject of the current planning dispute. There is only one other production well on site, which had only produced small amounts of oil before being suspended in January 2016 to allow for the upgrade works. The third well is a water injector well, and it depends on production from the other wells.

Therefore, there is a direct link between the current application and the disputed sidetrack. We believe that no application should be considered until the dispute is resolved, but this direct link should certainly not be ignored. Despite several of the councillors raising the above issue and MVDCC meeting, this application was passed because the majority of voting members and the Officers’ Report did not make the connection..

On the point of Angus being a responsible operator, their track record at Brockham suggest otherwise:


  • Angus bought the Brockham field in 2012, but has not focused on this site until 2016, when they raised £3.5M for planned works.
  • During 2016 Angus carried out surface upgrades without planning permission (this is the subject of the current retrospective planning application).
  • In Dec 2016/Jan 2017 Angus drilled sidetrack BR-X4Z without planning permission (according to Surrey Council). They did so against repeated advice from the council before drilling and despite site visits from the council enforcement officers just before drilling. They misled the council and the local community when drilling was underway by telling them they were only doing maintenance works.
  • During the drilling operations, Angus were understood to be carrying out maintenance under an existing planning permission. Angus breached a condition on that permission as well by working at night for over a week. The locals also observed HGV vehicles not following the designated route to site.
  • Angus confused the well numbering and reported to Surrey that they were re-entering Brockham-X1, when in reality it was BR-X4.
  • Angus breached a condition of their environmental permit (regarding containment of stored materials) when they were on site in Dec 2016/Jan 2017 (CAR 403648/0278191 issued 3 Feb 2017)
  • Angus refused to apply for retrospective permission for drilling or for production from BR-X4Z. They insist that they had all the required permissions and promise to investors to be in production by the end of the summer. Surrey County Council disagrees but they have not taken enforcement action and still awaiting legal advice.
  • Angus also indicated the intention to drill more wells at Brockham. They maintain that they have permission for 6 wells (so additional 3 to what’s already on site). Surrey County Council disagrees.


Angus Energy are planning to start production from the Kimmeridge limestones, which have not been produced from before (presumably because there was no technology that would make it viable). The Kimmeridge limestones were first tested in 2016 at Horse Hill – nick-named the Gatwick Gusher after flowing over 1,350 bopd. This level of production would have significant planning consequences at Brockham (the site recently produced only c.35 bopd and the production license granted in 2001 refers to 195 bopd.)

The Kimmeridge Limestones are a tight-oil reservoir of very low permeability and commercial extraction will likely require acid stimulation (3). Acidisation* involves pumping of large quantities of acids and other chemicals below ground to dissolve the rock and release oil. There are few studies on health and environmental effects of this technique and it is poorly regulated in the UK. Acidisation has a longer history of use in the US: in California it is regulated in the same way as hydraulic fracturing, and in Florida, many counties and municipalities have passed ordinances to ban it (4). This is even more of a reason to make sure that the rules in place are followed.

We maintain our position to object to the application on the grounds of lack of need, and further request that its consideration be deferred until such time that the applicant has submitted a retrospective planning application for drilling of sidetrack BR-X4Z and an application for production from this well.  

*By acidisation we mean “matrix acidising” and “acid fracking” – well stimulation treatments used to extract oil. Acidisation can also refer to a routine well maintenance process used by the industry to clean out boreholes, which is also known as an “acid wash.” This confusion in definitions is part of the reason why we think that regulation is not good enough.





As you are probably aware, Angus Energy and Surrey County Council are in a dispute over the drilling of sidetrack BR-X4Z in January 2017, which the Council said was drilled without planning permission. The news broke on BBC London News on 9th March and reached the front page of the Times. A week later DrillOrDrop reported that Angus drilled against the advice given by the Council prior to drilling.

Whilst Angus were working on site in December and January, a number of individuals reported concerning events such as a large delivery of drill pipes (documented by the ‘protection camp’, see picture above) and night working for over a week; however, the Council as well as members of the public were assured by Angus that it was only carrying out maintenance activities…

Despite its position, the Council has not taken any formal enforcement action with respect to the drilling of BR-X4Z. Council Officers had invited Angus to apply for retrospective planning, but the company refused saying they did not need it and that they had valid permission for six wells (so additional three to what’s already on site) and for production! Since there’s been no formal action, the dispute remains only that, a difference of opinions. Meanwhile, Angus continue their promises to investors that Brockham will be in production by the end of this summer. Their share price has gone from 10.75p to 32.6p in one month and HGV traffic was recently recorded arriving at the well site.

What can you do?

Despite claiming no need for any permission, Angus applied for retrospective planning for on-site facilities (but not for the drilling). The Council decided to run a public consultation on this seemingly minor application, perhaps because of the ongoing dispute. This consultation is open until 31 July.

We would like to urge you to comment on this application and support the position taken by both Brockham Oil Watch and the Parish Council that, as the current situation is the subject of legal dispute any consideration of the current application for the upgrade of site facilities should be postponed until this dispute has been settled.

You can comment via this link or by emailing also send a copy of your comment to Mole Valley planning team at commenting on an application, make sure to include your full postal address and reference SCC/2017/0089 (MO/2017/0916).  If you live outside of Surrey, you can still comment and it would be best if you could give a reason why this is relevant to you.

Is Angus Energy Back?

On July 9th a Grampian Continental flatbed contracted by Angus Energy was seen travelling through Brockham village. Surrey Council’s Monitoring Officer visited the well site on 13 July and reported that approximately 6 larger pipes, a pallet and some wooden crates have been delivered and were stored on site (picture below).



Council Officers are in communication wit Angus Energy’s solicitor regarding this recent activity, and the first one since January 2017, when Angus drilled sidetrack BR-X4Z – the subject of the current dispute.

We are keeping a close eye on Felton’s Farm well site and we would also like to ask all local residents (as well as those further away who have relevant information) to alert us as soon as possible if any HGV traffic is witnessed arriving or leaving the site, or any other activity related to the well site. Please see contact details below.

Note that, except in the case of emergency, no commercial vehicle should enter or leave the site except between the hours of 07.00-08.00, 09.00-15.30 or 18.00-19.00 on Monday to Friday and 08.00-13.00 on Saturday, and no traffic should be through Brockham Village (the correct route is Old School Lane, Bushbury Lane, Roothill Lane, Red Lane, Blackbrook Road and Mill road to the A24).

P.S. Another consultation, for an updated environmental production permit to be issued by the Environment Agency, is expected to come online very soon and we will be contacting you separately when it is out and we have had the chance to digest.



Facebook Page

Phone: 07376 791932

Brockham Oil Watch is a group of local residents concerned about plans for unconventional production at Brockham oil site. The Kimmeridge inter-bedded limestone and shale layers currently targeted by Angus Energy are a tight-oil reservoir, meaning commercial extraction will likely require acid stimulation.

Acidisation* involves pumping large quantities of acids and other chemicals below ground to dissolve the rock and release oil. There are very few studies on health and environmental effects of this technique and it is poorly regulated in the UK. Acidisation has a longer history of use in the US; In California it is regulated in the same way as hydraulic fracturing, and many Florida counties and municipalities have passed ordinances to ban it.

*By acidisation we mean “matrix acidising” and “acid fracking” – well stimulation treatments used to extract oil. Acidisation can also refer to a routine well maintenance process used by the industry to clean out boreholes , which is also known as an “acid wash.” This confusion in definitions is part of the reason why we think that regulation is not good enough. 


Planning Application SCC/2017/0089 (MO/2017/0916) – OBJECT BY 31 JULY!

Dear BOW supporters,

We alerted you recently about a new planning application from Angus Energy at Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – SCC/2017/0089 (MO/2017/0916). This application is for installation of on-site facilities and it is retrospective.

Surrey County Council decided to have a public consultation on this application. It is running until 31st of July so there is plenty of time to comment. It can be done via this link or by emailing You might also wish to send a copy of your comment to Mole Valley planning team at as they will also be discussing this application in early August.

When commenting on an application, please make sure to include your full postal address. If you live outside of Surrey, you can still comment and it would be best if you could give a reason e.g. ‘I have family/friends in Brockham’ or ‘I am very concerned over acidisation’ or ‘I believe in sustainable energy not hydrocarbons/fossil fuels and believe that the UK should be implementing the Paris Agreement’, etc.

We have included below the BOW objection. Please feel free to use this to inform your comment, but do make sure to you use your own words and present your own concerns.

Best wishes,
Subject: Planning Application SCC/2017/0089 (MO/2017/0916) Brockham Oilfield, Feltons Farmhouse, Old School Lane, Brockham – Installation of on-site facilities

We write to register a representation regarding the above planning application.

We wish to object to the application on the grounds of lack of need, and further request that its consideration be deferred until such time that the applicant has submitted a retrospective planning application for drilling of sidetrack BR-X4Z and an application for production from this well. It is a requirement for all planning applications to demonstrate the need for the development (indeed it is a material consideration). In this case, we consider that the applicant has not adequately demonstrated that there is a need for the development proposed. The application is for the installation of on-site facilities comprising hardstanding, site office, site toilet facilities, site security office and mess facility, storage containers, lighting units incorporating CCTV equipment, 2.4 metres high palisade fence and gates, electrical control buildings, 2 No site generators and a parking area for car/van until 31 December 2036, with restoration to agriculture.

With the exception of the CCTV installation and the parking area, all of the other items listed are essentially items of maintenance and renewal of existing site facilities which do not need a new planning application. Furthermore, planning permission MO/2006/1294 under which the continued use of general facilities for the production, treatment and export of crude oil on the site were authorised until 2036, included a condition (condition 4) that required the applicant to obtain Surrey County Council’s prior written agreement to erect, extend, install or replace any fixed plant or machinery, buildings, structures or private ways on the site. So the CCTV installation and the parking area could have been authorised by a simple submission under this condition of MO/2006/1294.

On close examination, we think that you will find the proposed new site office, site toilet facilities, site security office and mess facility, storage containers, 2.4 metres high palisade fence and gates, electrical control buildings and site generators proposed in the current application represent a considerable upgrade of the existing facilities, and we would contend that this upgrade can only possibly be needed to support a new drilling operation or increased oil production. (Furthermore, in their public information update on Brockham operations dated 26 June, Angus Energy says the upgrade works are ‘in preparation for the new oil production planned from the recent Brockham operations’, i.e. from the new sidetrack well BR-X4Z drilled in January of this year).

But the applicant has no valid planning permission whatsoever for drilling of any kind or for production from BR-X4 – the donor well sidetracked in January. Well BR-X4 was drilled in July 2007 – after permission MO06/1294 for production and export of oil until 2036 was granted (in May 2007), and therefore MO06/1294 does not cover production from well BR-X4.

We therefore maintain that, while there is no valid existing planning permission for the further drilling for hydrocarbons of any kind from well BR-X4, and no other planning application lodged for further drilling, there is no need at all for the upgrade of the site facilities which are the subject of this planning application. The application should, therefore, fail on the grounds of lack of need.

This position is even more important when taken in the context of the ongoing dispute between the applicant and Surrey County Council Planning Department over the drilling of sidetrack well BX-4Z. The applicant claims (and stated this numerous times to press and via the London Stock Exchange’s regulatory news service) that he has a permission for the drilling on the basis of previous planning permissions, but Surrey County Council is understood to disagree, and have asked him to submit a retrospective planning application to regularise the planning situation. Furthermore, the applicant has publicly stated in press releases that he has taken legal advice and that he believes that he also has a planning permission to produce from the recently drilled sidetrack, and that he has no intention to apply for retrospective planning permission. Again Surrey County Council disagrees, and has informed the applicant that he does not have a planning permission for the recently drilled sidetrack, for production from it, or to drill any more wells for any purpose.

It is also important to note that Surrey County Council informed the applicant prior to the drilling of sidetrack BR-X4Z that there was no planning permission for drilling operations. Despite this, the applicant continued with their plans, and when queried by the planning officers on the nature of the work as it was being carried out in December 2016 and January 2017, provided evasive answers, openly admitting to drilling only after it was completed. We are therefore of the opinion that the applicant abused the trust that is required between the public, the local authority and the operator to carry out subsurface oil drilling operations, and that this should be addressed first, before any other issue is considered. In addition, according to the applicant’s argument that drilling of sidetrack BR-X4Z was covered by previous planning permission for crude production, treatment and export until 2036, he seems to imply that he is allowed to drill any number of sidetracks from the existing wells (so long as they are subject to certain conditions) without the need for any additional planning permissions, which again contradicts the position of Surrey County Council.

In these circumstances, we believe that it would wrong to grant this planning application, and that it should be deferred until such time that the applicant has submitted a retrospective planning application for drilling of sidetrack BR-X4Z, as well as a further planning application for production from this same well, and that the current application be considered and determined together with, and at the same time as these two additional planning applications.

Yours sincerely,

Felton’s Farm – Planning Application SCC Ref 2017/0089 / MO/2017/0916

Angus Energy recently put in a new planning application – MO/2017/0916 (…). It’s a retrospective application for changes to the buildings, storage and fencing that was updated last year without getting the prior approval of the Surrey County Council, as required by a condition of an earlier planning permission (MO/2006/1294).

This application is separate from any retrospective application for drilling of a side-track, and that has not at this stage been submitted. The dispute over side-track drilling remains unresolved. According to Surrey County Council drilling was unauthorised, whilst Angus Energy maintain they had all the required permits and approvals. SCC said they’re awaiting legal opinion on this matter before taking formal action.

The reason we are concerned about expansion of operations at Brockham is because the operator, Angus Energy, are targeting the Kimmeridge tight oil for production. This will likely require the use of acidisation – fracking-like technology that involves injecting acids and chemicals underground. Our position is that there should be a moratorium until all risks have been identified and regulation is in place.

To comment on the recent planning application, please email quoting SCC Ref 2017/0089 / MO/2017/0916. Please remember to provide your full postal address.


Brockham Oil Watch


Find us on Facebook:


Newsletter 2 – 6 June 2017

We have not written for a while but we have been working in the background liaising with the various authorities over why the drilling of side-track BR-X4Z was allowed to happen despite letters from the Council to Angus Energy informing them there was no planning permissions for it, and what this means going forward. Here is an update:

1. The dispute between SCC and AE continues. The Council’s position is that drilling of the side-track was unauthorised whilst AE maintain they had all the required permissions. SCC said they sought the advice of legal Counsel (we have shared this back in March) and that they would not proceed with any formal steps until this has been received. We continue to wait. You can read an excellent summary recently published on DrillOrDrop here and if you’d like to dig deeper, here is a link to the freedom of information request containing letters exchanged between Angus Energy’s legal representative and Surrey County Council.

2. In the meantime, on 11th May, Angus Energy submitted proposals to the Oil and Gas Authority to produce oil from Kimmeridge rocks at Brockham.

We understand that the OGA is well aware of the difference of opinion with the SCC over the side-track. The OGA issued consent to drilling side-track BR-X4Z back in December 2016 even though according to Onshore Oil And Gas Exploration in the UK guidance “OGA grants consent to drill only once all permits are in place and all relevant consultees have been notified”.

The OGA recently said they issued their consent on the basis of this letter sent by the SCC to Angus on 12 December 2016. This letter references the wrong well (no 2 and not 4), uses unclear wording open to interpretation, and we think it should be read in the context of SCC’s earlier letter to Angus Energy, sent in September 2016.

The SCC Head of Planning (Alan Stones) clearly does not accept that the SCC letter of 12 December 2016 materially alters the position in any way.  Whether Angus has planning permission or not is a matter of fact in planning law, based on the history of planning permissions granted and their conditions.  It cannot be changed by the wrongful interpretation of a letter by the applicant.  What is of major concern is that SCC’s actions going forward are now being controlled by their legal department and not their planning department.  There is a serious risk that they will take no further enforcement action or will not take Angus to task, despite the fact that the planning department is clearly of the opinion that Angus do not have planning permission to drill a new production well, and did not have permission to drill the BRX4Z sidetrack in the first place.

3. The Environment Agency confirmed last week that Angus Energy have applied for a variation of their production permit to bring it up to standard as part of the re-permitting process. We are awaiting the consultation to go online and will be emailing you about this again when we have more detail.

4. With regards to the Weald-wide risk of potential back-to-back development of oil wells across the Weald of Sussex and Surrey:

New Environmental Impact Assessment Regulations for individual projects were made in April this year, and they weaken the requirements for the assessment of cumulative impacts of oil and gas projects.  A cumulative assessment now only has to consider the impact together with other wells that are already consented, whereas previously it had to consider it together with all possible developments.

Furthermore, the Strategic Environmental Assessment Regulations, which came into effect in 2004, assess the environmental impacts of government plans and programmes, and require the continuous monitoring of the environmental impacts of all emerging programmes, only became effective for onshore oil and gas licensing in 2015, and only cover the licence blocks issued since 2015. (That is only 2 out of the 25 license blocks where oil companies are currently active.)  In order for it to cover the Brockham Oilfield, which was licensed in 1983, this legislation should be applied retrospectively to all licenses. At present, the Government has no plans to do this, and so the Brockham Oilfield will continue to be omitted from environmental monitoring under SEA.

Best wishes,

Brockham Oil Watch



P.S. As the general election approaches, we would like to share a letter written by a fellow campaigner in Balcombe commenting on the Tory proposals regarding oil drilling.

If the Conservatives are re-elected, you’d need no more planning permission to drill an oil well than to put up a modest conservatory or shed. The Conservative manifesto proposes to make any ‘non-fracking’ drilling for oil and gas ‘a permitted development’ – one of those minor works you don’t need to bother the planners about. And that would fire the gun that would pepper the Weald of Sussex and Surrey with oil wells.

‘Non-fracking’ is what is currently proposed across the South East of England. It covers any oil or gas prospecting that does not fall under the new definition of fracking. In the 2015 Infrastructure Act, fracking was strategically redefined by an oil and gas-friendly government according to the amount of water used. (It should be defined as the act of fracturing the rock with pressurised fluid.) 44 per cent of the thousands of wells that have been fracked in the USA would not be counted as fracked under this new UK definition!

If it doesn’t count as fracking, then none of the UK’s fracking regulations and ‘safeguards’ apply. When ‘not fracking’, you can drill shallower wells (as at Balcombe) and, as the government recently confirmed, ‘non-fracking’ activities can take place from wells drilled from the surface of protected areas, such as National Parks and Areas of Outstanding Natural Beauty.

One oil company CEO has talked of wells ‘back to back’ across the Weald of Sussex and Surrey, drilled down and out horizontally, over and over again. The targets are an unyielding shale called Kimmeridge limestone, or micrite. Geologists call such rocks ‘tight’ or ‘unconventional’ because the oil can’t flow through them at a worth-while rate. Oil men talk of ‘stimulating’ them – by hydraulic fracturing (fracking), acidising or acid fracking (injecting hydrochloric acid and other chemicals to dissolve passageways through ‘tight’ limestone-rich rock). Acidising the Weald would bring the same negatives as fracking, heavy traffic, air and water pollution risk, a great many wells…

The oil and gas industry wants to call these new wells ‘conventional’ (like the free-flowing Weald wells of old). They feel free to do so, because all limestone and sandstone oil and gas source rocks were incorrectly redefined as ‘conventional’ in the National Minerals Planning Guidance of 2014.

Calling the Kimmeridge limestones of the Weald ‘conventional’ is a ploy to soothe public and media opinion and make this a non-issue for our planners. Although if Teresa May keeps the keys to Downing Street on June 8th, neither we nor the planners shall have any say.

Kathryn McWhirter

Balcombe, Sussex