Retrospective Application For Disputed Sidetrack at Brockham – Points for Objection

Comments can still be made on this application until 19 June, 12 noon.  Please copy them to

Angus Energy are back at their wellsite at Feltons Farm, Old School Lane and have restarted pumping oil from one of their two  existing wells, BRX2Y.

Angus have ALSO submitted a planning application to Surrey County Council, which is in 3 parts for:

  • the retention of their other existing well BRX4;
  • the retrospective regularisation of the side track (BRX4Z) they drilled from this well without permission in January 2017; and
  • appraisal of the production potential from this side track, BRX4Z, for a temporary period of three years.

The middle part is application for retrospective permission for the drilling that Angus did in Brockham last January, which DID NOT HAVE PLANNING PERMISSION

The oil field has been here for years, why are we concerned about Angus Energy now?   This is the oil company that:

  • was told in 2014 by consultants commissioned by Angus itself that there was no planning permission to drill at Brockham.
  • ignored two letters from the planning authority that said it needed planning permission to drill. They drilled anyway and then threatened to sue the council if they said they didn’t have permission.
  • didn’t know which well was which, and set up its rig on the wrong wellhead.
  • requested permission for 24 hour working for safety reasons, but but it appears this was to disguise the drilling of a new well all through the night, and over the following 6 days and nights, in contravention of conditions of the permission they were thought to be working under.
  • when local people asked what the noise, lights and activity in the middle of the night were, told the Council it was “Security Lights”. But it wasn’t, they were drilling a new well!

What have they done, or say that they are going to do, for the Brockham village? Absolutely nothing. They have also declined to present their proposals to villagers in a meeting.  So why should they be granted planning permission?

We believe Angus are not responsible operators and this application should be refused. (For more on the history of Angus at Brockham, click here).

Among other issues that you may wish comment to the planning authority on are:

  • Traffic on local roads and access to the wellsite. Angus Energy propose up to 24 HGV movements (12 loads) on any day. This is compared to 2 tanker movements per week in recent years. Traffic will be routed from the A24 in South Holmwood along Old School Lane, Root Hill, Red Lane, Blackbrook Road and Mill Road.)
  • The duration of the permission being sought – 3 years. This is considerably longer than is normally required for an appraisal application, typically 4 to 6 months. This application is for appraisal of the newly targeted rocks, but Angus have been telling their investors that they’re going straight into commercial production.
  • The possible future use of acidisation and/or fracking to “stimulate” the flow of oil from unyielding rocks (different than those targeted so far). Angus sought permission to use of acid and other dangerous chemicals for well cleaning in their permit application to the Environment Agency, but have NOT mentioned this in their Planning Statement. Although at this stage Angus say that they will not frack, the planning authority would not be able to stop them in the future if they grant this application now.
  • Emissions to air and the treatment of natural gas from the well – Angus Energy propose a 12-metre high emergency flare stack, together with a large (375 kVA) gas powered portable generator to burn off the gas and generate electricity.
  • Flood risk. Angus say in their Planning Statement that the site is “at negligible risk from surface water flooding”, but they have not carried out a formal flood risk assessment.
  • The risk of a major incident. There is no mention of major accident or major incident risk in Angus Energy’s Planning Statement.
  • The UK’s commitments to reducing greenhouse gas emissions in the Climate Change Act, 2008.

Representation by Brockham Oil Watch to SCC – Final


To find out more and respond to this planning application you can:

  • Visit the online register of planning applications at Surrey County Council here.
  • Representations can be made by via the SCC portal, via email to (please copy the case officer: or by post to Caroline Smith, Planning Development Manager, Planning Development Group, Surrey County Council, County Hall, Kingston upon Thames, Surrey KT1 2DY.
  • You can see the representations made here (does not include representations by consultees). 

Please remember to provide your name and address, the application number/reference MO/2018/0444 / SCC Ref 2017/0215 and to state the reason why you are writing (e.g. as a local resident) in any representation. Please state clearly that you are OBJECTING to this application (assuming of course you are).

This application will be decided at Surrey County Council’s Planning and Regulatory Committee meeting on 20 June, 10:30 am, to be held in the Ashcombe Suite, County Hall, Kingston upon Thames, Surrey KT1 2DN. 



Crowdfunder to defend against UKOG injunction goes live

Weald Action Group, and the six local campaigners who are challenging the UK Oil and Gas (UKOG) injunction, have launched their crowdfunder today to pay for their legal costs.

Ann, Sue, Natasha, Constance, Vicki and Jacqui have courageously stepped forward to fight this High Court injunction.  This injunction could stop the right to peaceful protest and prevent local people raising awareness of the new risky methods of unconventional oil and gas drilling and the industrialisation of our beautiful countryside.

Can you please pledge to support them? It doesn’t matter as to the amount. EVERY BIT HELPS.


These type of injunctions are draconian in its chilling effect, and counter to the right to assembly and the right to freedom of expression.  There is already criminal law to deal with any unlawful activities, and this injunction should have no part in defining what is legal and what is not. It is a blatant attack on our human rights.

If this injunction is granted it could also serve as a precedent for other oil and companies here and around the country. It should be fiercely resisted and we need to raise funds for our legal costs to fight this.

Please do share on your social media and/or forward this email to your friends. It helps SO much.

Here is the shareable Facebook post.  Also click on this search for #injunctioninjustice on Twitter to retweet or create your own using the hashtag #injunctioninjustice and the crowdfunder link

We are all in this together and we can’t do any of this without your support. So please donate now and help to stop this injunction.

Thank you!



DrillorDrop articles:

6th March report – UKOG seeks injunction to ban protests that aim to damage its business

15th March report – Campaigners to challenge oil company at High Court over protest injunction

17th March Report – Human rights campaigner urges oil company to drop High Court bid for injunction

19th March report – “Shires of England rise up” as oil company UKOG seeks High Court injunction against protests

19th March Report – Court adjourns decision on “wide-ranging” injunction against protests at UKOG oil drilling sites

5th April Report – Oil company withdraws key clauses in protest injunction

Retrospective Application For Disputed Sidetrack at Brockham – CONSULTATION OPEN

Dear BOW Supporter / Follower,

Angus Energy have submitted their long-awaited planning application for the next stage of work at the Brockham Oilfield at Felton’s Farm, Old School Lane. The application is in three parts, and relates to well BRX4 where an unauthorised sidetrack was drilled last January.

Part 1 is for the retention of the BRX4 well. The well was drilled in 2007 under a planning permission that expired in 2008. According to the conditions relating to this permission, the well should have been sealed up and the land returned to its former condition, but this has not happened, and Angus are now applying for permission to retain the well for a further 3 years.

Part 2 is a retrospective application for permission to drill the sidetrack to well BRX4, BRX4Z (the unauthorised drilling that took place last year).

Part 3 is an application for appraisal of the production potential of the sidetrack BRX4Z using the production plant and equipment within the existing site plus some additional plant and equipment. Angus is applying for permission to undertake this work over the next three years, and they say that they plan to produce oil from the well for up to 18 months, during which time they will monitor the pressures and the flow. This information is to be used for a report to the Oil & Gas Authority and to inform a further planning application for production, should the appraisal show that there is oil in commercially recoverable quantities.

What will happen if the planning application (or parts of it) are refused

We do not know what will happen, but it is likely that Angus would appeal. If the appeal is successful then a Planning Inspector will grant planning permission. If it is unsuccessful, then enforcement action could be taken by Surrey to have the well shut down and sealed. However, the other two wells (BRX1 and BRX2Y) have a planning permission to produce oil until 2036, so it is unlikely that the whole wellsite would be restored for some considerable time.

What will happen if the planning permission is granted

The planning permission applied for will have a life of three years, during which time Angus would have permission to undertake the appraisal work on well BRX4Z outlined in Part 3 above. If it is successful, we should expect Angus to submit a planning application for further production in 2021, probably for the period up to 2036.

How you can comment on this planning application

The planning authority that will determine this application is Surrey County Council. You can find details of the application on Surrey County Council’s website here, or on Mole Valley District Council’s website here. Surrey County Council’s consultation period opened on 20 March and closes on 18 April. Representations can be made on the Council’s website, or by email to, but remember to include the application no/reference MO/2018/0444 / SCC Ref 2017/0215, your name and address and to state that you are a local resident.

If you wish to make a representation to Mole Valley Council, this should be sent to them by 6 April, but be advised that they will not be determining the application. They simply provide their own response to Surrey.

Key issues that you may wish to consider

Environmental Impact Assessment: Surrey has provided an EIA Screening Opinion that EIA will not be required. We do not agree with this, on the basis that there could be significant environment effects, and that the precautionary principle should apply.

 Target strata and extraction methods: Angus’ proposed targets are the conventional reservoir of the Portland Sandstone, and also the Kimmerdge Clay Formation, an unconventional shale reservoir beneath it. All of the oil extracted from Brockham since the 1980s has been from the Portland. However, the main interest of oil companies in Surrey and Sussex more recently has been the Kimmeridge. We believe that, in order to extract oil in commercial quantities from the Kimmeridge, permission to use unconventional methods such as the use of acid stimulation and/or fracking may be sought. However, at this stage, Angus say that they have no plans to use such methods at Brockham and that they will only need to use acid wash (done with smaller volumes and at a lower pressure than stimulation). The planning authority confirmed to us that should Angus decide they wish to frack or acid stimulate after this application has been approved, there will be no requirement for a fresh planning application..

To watch a video recording of recent talk by David Smythe, Emeritus Professor of Geophysics at the University of Glasgow. This talk is mainly about Leith Hill, but Prof Smythe explains why the Kimmeridge is unconventional and why it’s likely to require extraction methods such as acidising or fracking:

Length of the appraisal phase: As mentioned above, this application is for a period of three years, and Angus say that they plan to produce oil from the well for up to 18 months. In our view, the length of time proposed is excessive and completely out of line with the appraisal programmes of other operators in the Weald Basin, who have typically applied for a period of 4 to 6 months for appraisal works.  For example, the recently approved well-testing application at Horse Hill was for 150 days (i.e. 5 months). Furthermore, we would draw your attention to the fact that Angus Energy has been telling investors for months that they plan to go straight into production on well BRX4Z. This is also corroborated by the fact their initial submission described the works as “production evaluation” and had to be revised before it was validated.

 New plant and equipment: Angus propose to bring new plant and equipment onto site to deal with any gas from the well. They propose a portable generator and an emergency flare stack. The indicative plant proposed in the application is a 375kVA generator, approximately 6m long, 2.4m wide and 2.6m high, and a flare stack and shroud, 12 m high and 2m diameter. This is to convert and burn off excess gas, which is expected to be present in higher quantities in the Kimmeridge.

 Road traffic: Angus say that the operations for which consent is sought will result in no more than 12 loads (24 HGV movements) on any single day, and that it is likely that daily movements will be significantly below this figure. These figures should be compared with the figure of 2 tanker movements per week for traffic using the wellsite in recent years. The designated route to the A24 is via Root Hill, Red Lane, Blackbrook Road and Mill Road.

Environmental permitting: Oilfield operations require an environmental permit from the Environment Agency which is a separate regulatory system from planning. Angus has an existing permit, but will require it to be updated before the appraisal operations can commence. The application for an updated permit was submitted in July 2017; a new permit has not yet been issued. We will keep people informed of its progress.

Brockham Oil Watch 


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.



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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.



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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


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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.



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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.