Dear BOW Followers,
According to the British Geological Survey (BGS), there had been no earthquakes in Surrey in the last 50 years; but since April 1 2018, a series of seven tremors (including three of magnitude well above 2 ML and one of magnitude 3.1 ML) has surprised and worried residents around Newdigate and the wider area between Dorking and Crawley. This is at a time of increased oil and gas activity in the county, and many people are making a connection between the two.
We think that serious questions should be asked and investigated, especially in connection with the two oil and gas sites nearest to the epicentres: Brockham and Horse Hill.
In a statement issued following the earthquakes, the BGS say that they are unable to categorically say if these earthquakes are related to hydrocarbon operations though they do not rule out that possibility.
The statement also says that, “it is well known that hydrocarbon exploration and production can result in man-made or “induced” earthquakes” and that “such events usually result from either long term hydrocarbon extraction, or the injection of fluids (e.g. hydraulic fracturing) during production.” The announcement mentions that it seems unlikely that any flow testing at the Horse Hill site would result in induced seismicity.
We have written to the BGS to point out that what the statement fails to mention is that there is a re-injection well at Brockham, where produced water had been re-injected for years from operations at the Brockham and Lidsey sites. Both sites were closed for most of 2016 and 2017, but resumed production in March and February 2018 respectively, and water reinjection also restarted at Brockham in March according to the Oil and Gas Authority (OGA) website.
Based on analysis and studies done in US, the strongest relationship to seismicity has been found where wells re-injected waste water underground for permanent disposal. Over time, pressure can start to build up on geologic faults causing them to slip. Earthquake risk can spread miles away from the disposal wells and persist for more than a decade after re-injection stops. This presents a challenge in analysing a possible link, exacerbated by a lack of reliable earthquake data due to the fact that BGS’s closest monitoring station is located more than 50km away from the estimated epicentres.
With respect to the Horse Hill site, UK Oil & Gas (UKOG) announced on 27th June that they commenced “production flow test operations.” However, since then Mr. Sanderson, UKOG’s executive chairman said that “there’s been no sub-surface activity since March 2016” on the site. The OGA have confirmed this, but failed to produce any clear evidence to support it.
Given that according to expert analysis, the Horse Hill-1 well was drilled into a fault zone, and that UKOG’s Environment Agency permit allows for injection of acid and chemicals under pressure high enough to squeeze it into the pores of the rock, we think that the activities at Horse Hill should be investigated and closely monitored in order to be certain that UKOG have not triggered the earthquakes and do not trigger them in the future.
Unfortunately, the type of flow test UKOG are intending to perform will not be caught by the OGA’s requirement to monitor seismicity in real time through a “traffic light protocol”, which is only required for sites where hydraulic fracturing is proposed. Therefore, there is no oversight mechanism from the OGA to monitor induced seismicity at Horse Hill. 
The convergence of the Horse Hill flow test, resumed operations at Brockham and the earthquakes is at the very least puzzling and needs to be explained.
We think that there are too many unknowns and that operations at Brockham and Horse Hill should be immediately suspended. The reasons for the earthquakes should be thoroughly investigated, the likely cause established and any mitigation required put in place before the operations can continue.
There is an urgent need for monitoring equipment positioned locally to produce better data on earthquake epicentres and depths. Detailed injection information is needed from the regulators or industry to allow for analysis.
Well integrity should be tested as well to check if the earthquakes didn’t cause damage that could lead to environmental pollution.
This is critically important at a time when Surrey is facing a proliferation of applications for hydrocarbon exploration and production, including in some of its most precious areas of outstanding natural beauty.
P.S. What can you do about it? Please see here a useful list from A Voice for Leith Hill.
 Oil & Gas Authority: Consolidated Onshore Guidance V.1, November 2017, https://www.ogauthority.co.uk/media/4475/29112017_consolidated-onshore-guidance-compendium_v-10.pdf
Dear BOW followers,
The date for Surrey County Council Planning & Regulatory committee meeting where the current Brockham oilfield application will be decided has been postponed again! It is the third delay (from the original date in May), and decision is now due on the 8th of August.
Three new documents were added on the 13th of June to SCC planning portal for this application, and one of them has been updated just yesterday (the documents concern emissions to air from gas engine and flare, and we will write more on this next), so we suspect that the reason for delays is the lack of sufficient information and tardiness on the part of Angus Energy in supplying it.
This is something of a pattern and it appears that, following the revelations of unauthorized drilling in January 2017 against the council’s advice, the attitude of Angus Energy towards the regulators has not become any more transparent. The Brockham site is also going through a re-permitting process by the Environment Agency; the initial consultation closed in early September 2017, but the permit has not yet been determined because, as we were told by the Agency, they have not yet been provided with sufficient detail.
Meanwhile, we have discovered a loophole in the regulatory system (which we also wrote about previously). This loophole allows for various activities to take place without the operator having to notify the Environment Agency and without monitoring, until the modern-standard permit is put in place. These activities include acid stimulation, hydraulic fracturing and water re-injection. Our concern is that, if the current planning application for well BRX4Z targeting the Kimmeridge Clay Formation is approved, Angus Energy will be able start stimulation without any environmental monitoring and without us knowing! If you would like to read more about what we discovered, please see this recently published Drill Or Drop? article.
On a different note, below is a picture from last Saturday, when BOW welcomed in Brockham cyclists from the Tour de Frack UK. The ride was organised to highlight the threat of the industrialisation of our countryside, and passed also by the Horse Hill, Balcombe and (planned) Leith Hill drilling sites.
Horse Hill and UKOG
Long-term flow tests of the Kimmeridge layers have just started at the Horse Hill site, which is operated by UK Oil & Gas (UKOG). UKOG applied to the High Court for an injunction that would effectively stop any campaigning that affects its economic interests. The company since amended the order, but it still seeks to cover “lawful activities” threatening penalties including prison for anyone who breaches it. The injunction hearing is on Tuesday, 3rd July at 1pm and support is welcome. Here is the event Facebook page and article by one of the brave defendants who decided to fight it. UKOG are currently not involved at Brockham.
Dear BOW Supporter,
PROFESSOR DAVID SMYTHE’S EXPERT OPINION
We are very grateful to David Smythe, Emeritus Professor at the University of Glasgow, who submitted his expert technical commentary in support of our representation to Surrey County Council on the current application. Prof Smythe highlights that inadequate information has been shared with the council for a reliable assessment to be made. His analysis of the available detail concludes that sidetrack BRX4Z was drilled close to a major fault possibly targeting the damage zone of the fault to increase the flow (to emulate the results at Horse Hill-1, nick-named the Gatwick Gusher). This carries an environmental risk, because if any kind of stimulation is applied, the fault zone may become permeable and therefore be a ‘fast track’ to the near surface environment.
Prof Smythe says also that the applicant’s arguments that stimulation of the Kimmeridge Clay Formation (the target of BRX4Z), whether by acidisaton or by fracking, will not be necessary are incredible, because they run counter to the known geomechanical properties of the KCF, and because they conflict with the extensive experience of similar unconventional plays in the USA.
Angus Energy admit that the target Kimmeridge layers are an interbedded shale and limestone hybrid reservoir, yet they describe themselves as a ‘conventional’ oil & gas company at every opportunity, and re-iterate that there will be no hydraulic fracturing because the Kimmeridge is naturally fractured. Professor Smythe points out that the natural fractures (which are visible in the outcrop at the Kimmeridge Bay) are vertical, so it is difficult to see how lateral drainage (from a near vertical well) of the reservoir can be achieved. In any case, even if an unconventional reservoir is naturally fractured, it will still require the drilling of back-to-back wells in order to drain the fractures efficiently, and it will likely require acid stimulation. (1)
Acid stimulation is a type of fracking performed on limestone or sandstone-rich shale that dissolves the rock enlarging or creating new fractures. Unfortunately, acid stimulation, like hydraulic fracturing using fluid volumes below the arbitrary threshold set out in the Infrastructure Act 2015, is exempt from the Government definition of ‘associated hydraulic fracturing’, and from the regulations introduced by the IA2015.
ENVIRONMENT AGENCY AND RE-PERMITTING OF BROCKHAM
Meanwhile, we’ve also been in close communication with the local Environment Agency team, who shared their comments to SCC on the current planning application with us. The EA is currently reviewing the existing environmental permit at Brockham as part of a national review to bring all permits to a modern standard. This process started some time ago for Brockham, and there was already one public consultation in July 2017; but because of gaps in information provided by the applicant, the EA has had to request more detail and so the re-permitting process continues. There will be a second consultation once the additional information is submitted, and the earliest this can happen is July 2018. The permit would not be issued until the results of the consultation are evaluated and the assessment is complete.
There is therefore a mismatch between the timescales for the consideration of the planning application to be decided on 20th June and the re-permitting process currently being undertaken by the EA. The EA do not yet have the information that they need to assess the activities proposed by Angus, to decide whether to grant a permit, and to set the terms and conditions for such a permit.
In particular, the EA lists the following items that are yet to be determined:
- Whether what Angus Energyis proposing constitutes appraisal or production from the Kimmeridge Clay Formation.
- How much gas will be produced from the Kimmeridge formation, and whether the flare falls into the emergency only category or if it may be used for gas disposal.
- Whether any stimulation is proposed (stimulation includes processes such as matrix acidising, acid fracturing or hydraulic fracturing) to appraise the Kimmeridge Clay Formation and what activities are underway in the Portland Formation.
- What is the composition of fluids to be re-injected at Brockham (is it produced water, or flowback from stimulation activities; is it from Brockham only, or from other wellsites, such as Lidsey as well)
Until the new permit is in place, the site operates under the old-style permit, under which none of the above is either clarified or monitored. This means that Angus can carry out stimulation (with acid or hydraulic fracturing) so long as the volumes of fluids injected are below the levels specified as ‘associated hydraulic fracturing’ in the Infrastructure Act 2015, and they will not even need to notify the EA of what they are doing. This is all the more worrying because there is no groundwater monitoring in place at the moment, even though it will be required going forward because of the risk of pollution from re-injection. There is no air quality monitoring in place either, but this will also be required as part of the new permit. Until then, monitoring of site activities can only be carried out via site inspections and verbal interaction with Angus staff. Given the track record of Angus Energy, we are very concerned about this.
With decision on this application postponed again until 11th July, comments are received until 12 noon on 10th July. Please see here on how to object.
Dear BOW Supporter,
There’s been a number of updates since we wrote last on 17th April, day before the official deadline to comment on the current application from Angus Energy covering the drilling and appraisal of unauthorised sidetrack BRX4Z drilled January 2017 (MO/2018/0444). We are sharing some today.
NEW DATE TO COMMITTEE
This application was going to be voted by the Surrey County Council Planning and Regulatory Committee on 23rd May, but this has now been moved to the next P&R Committee meeting on 20th June.
This is good news because we now have longer to make comments, and if you have not commented yet, there is still time. Representations will be received until noon on 19th of June. See our website here for instructions.
MVDC UNANIMOUS OBJECTION
Mole Valley District Council, who is a statutory consultee on this application, discussed it on 2nd of May and voted unanimously to object on the basis that the 3-year period proposed by Angus is unnecessarily long to appraise as well (our note: this needs to be seen in the context of Angus making repeated statements over the past months and as recently as late April about putting BRX4Z “straight into commercial production”). MV councillors also raised concern over the potential use of acidisation, emissions from the flare stack, and lack of a risk assessment, as well as the need for close monitoring given the track record of the applicant.
ANGUS ENERGY’S COMPLAINT TO OFCOM AGAINST BBC DISMISSED
Drill Or Drop reported on May 8th that Angus had complained to Ofcom about BBC’s reporting of the drilling of BRX4Z, and that this complaint has not been upheld. Ofcom said that BBC had not been unfair to Angus and that its report reflected the company’s position adequately and fairly. Angus were represented by Schillings International LLP – international privacy and reputation law firm that has represented many high-profile clients including celebrities, sports starts and other famous people.
We note that this article in The Times says it is still the subject of a legal complaint from Angus Energy plc.
ANGUS BECOMES THE OPERATOR OF BALCOMBE
Angus Energy announced today that they received approval from Oil & Gas Authority to become the operator of Balcombe (taking over from Cuadrilla).
Here is a quote from Jonathan Tidswell, CEO of Angus Energy from a recent investor show: “The idea of taking over is that we are a non-fracking company. The idea will be to somehow convince the locals over the next few months that there will never be any fracking on the site.”
We believe what might be meant by fracking in this quote is ‘associated hydraulic fracturing’ as defined by the Government in the Infrastructure Act 2015. This definition leaves out a lot of fracking activities that do not meet the definition’s very high thresholds of injected fluids. You can read more on this issue in very digestible format here and here.
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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.
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.
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
Comments can still be made on this application until 7 August, 12 noon. Please copy them to firstname.lastname@example.org
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.
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 email@example.com (please copy the case officer: firstname.lastname@example.org) or by post to Caroline Smith, Planning Development Manager, Planning Development Group, Surrey County Council, County Hall, Kingston upon Thames, Surrey KT1 2DY.
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 is scheduled to be decided at Surrey County Council’s Planning and Regulatory Committee meeting on 8th August, 10:30 am, to be held in the Ashcombe Suite, County Hall, Kingston upon Thames, Surrey KT1 2DN.