Update on our open letter to the Government calling for a ban on all forms of fracking

We would like to thank all signatories to our open letter that asked the Government to replace the current moratorium on high volume hydraulic fracturing with a ban on all well stimulation for oil and gas exploration and production.

We are sharing with you the response we received on behalf of the Government from the energy minister, Kwasi Kwarteng.

Mr Kwarteng’s letter doesn’t respond to the issues carefully detailed in our letter to him. The documents cited within his response have been referenced in our in-depth legal brief that was attached in our letter. This brief is based on months of research into the regulatory framework, co-authored and signed off by leading environmental firm, Harrison Grant.

The response is a polite but firm refusal and a dismissal of our concerns. Specifically on acidisation, it is true that the Environment Agency regulates this area, but the EA has failed to clarify the boundaries between well maintenance techniques and acid stimulation – a fracking-like technique. As it stands, permits and exclusions are granted based on the oil and gas firms’ stated intent, which results in insufficient restrictions, reporting and monitoring to guard against acid stimulation taking place under the guise of well maintenance. The EA’s regulatory position remains opaque, with no clarity whatsoever over where the boundary between unacceptably dangerous acid stimulation and routine well maintenance lies.

Confusion also remains with respect to which operations require hydraulic fracture plans, while the ministerial statement on the moratorium on fracking referred to by Mr Kwarteng refers to hydraulic fracture plans as well as to hydraulic fracture consents – two different regulatory consents that apply to operations of different scope. This highlights the many inconsistencies in the legal and regulatory framework for hydraulic fracturing and the need for an expanded ban for all well stimulation treatments.

We also believe that investment in the post-covid recovery should be in line with climate change targets and therefore on green energy, not domestic oil and gas, involving acid stimulation or otherwise. Given the drop in demand, it would be an easy win for the Government to look proactive on climate change by switching their focus to renewables.




New Ministers Face Renewed Calls For Extension of the Fracking Moratorium

BROCKHAM, SURREY, 24 Feb 2020 – An open letter to the Government signed by more than 600 academics, politicians and campaigners was delivered today to key ministers overseeing fracking, including Alok Sharma and George Eustice, the newly appointed secretaries for BEIS and DEFRA. The letter was also sent to Prime Minister Boris Johnson and copied to chief executives of national onshore oil & gas regulators.

The letter – which was launched by Brockham Oil Watch on 2 November 2019, the day the fracking moratorium was announced – calls for replacing the current moratorium with an outright ban and an extension of this ban to all forms of hydraulic fracturing and other well stimulation techniques to enhance the productivity of onshore oil and gas wells. Together with the letter, addressees received a copy of the legal brief, Acid Stimulation: Fracking by Stealth, detailing the issues raised.

Signatories include professors Denis Hall, Stuart Haszeldine, Robert Howarth, Anthony Ingraffea and David Smythe; politicians Caroline Lucas MP, Jonathan Bartlett, co-leader of the Green Party, Baronesses Jenny Jones and Natalie Bennett; Doug Parr on behalf of Greenpeace UK, Bill McKibben, Co-founder of 350.org, George Monbiot, Vivienne Westwood, Joe Corré, Jeremy Leggett, Alistair Beaton – playwright and the author of Fracked!, actors Susan Jameson and James Bolam, Josh Fox – Director of Oscar Nominated Film Gaslands, Dr Gail Bradbrook of Extinction Rebellion and many more.

Nearly 100 anti-fracking and related groups in the UK and internationally also signed the letter.

David K. Smythe, Emeritus Professor of Geophysics at the University of Glasgow who provided scientific advice to the project, said “Current legal drafting and accompanying technical definitions are in places self-contradictory and shambolic. We can cut the Gordian knot around controls on fracking (and its ugly sister acidisation) by basing the legislation on the concept of ‘stimulation’, this being defined as the permanent alteration of the bulk physical properties of the rock volume to be exploited for oil or gas.”

Alice Goodenough, consultant solicitor at Harrison Grant, who co-authored the legal brief said: “Where well stimulation activities fall outside the narrow legal definition of “hydraulic fracturing”, there is no clarity over what legal and regulatory controls apply.  Many of the restrictions in place for fracking do not apply to other forms of well stimulation.”

Ada Zaffina from Brockham Oil Watch said: “This issue unites anti-fracking campaigns across the country. People don’t want fracking, whether it’s high volume, fracking with acid, or using some other extreme extraction technique. The associated environmental and public health risks are unacceptable, and so is continuing to extract oil and gas from unyielding rocks instead of tackling the climate emergency.”

[1] Open letter to the Government: Stimulation of oil and gas wells – reforms required is available here and the legal briefing: Acid Stimulation: Fracking by Stealth  is available on request.

The brief was co-authored by Brockham Oil Watch and Harrison Grant Solicitors, with scientific Advice from David K. Smythe, Emeritus Professor of Geophysics, University of Glasgow.

[2] Fracking moratorium announcement 2 Nov 2019: https://bit.ly/39m2YHF. Government clarification on the limited scope of the moratorium https://drillordrop.com/2020/01/29/government-statement-confirms-fracking-is-still-allowed-under-moratorium-campaigners/

Editor’s Notes

About Brockham Oil Watch:    Brockham Oil Watch (BOW) is a non-political group of local residents concerned about the threat of unconventional hydrocarbon extraction from the Kimmeridge Clay Formation (or other unconventional reservoirs) at Brockham, and gaps in the current legislative/regulatory framework. For more information visit www.brockhamoilwatch.org

About Harrison Grant Solicitors:    Harrison Grant provides experience and expertise in environmental, wildlife, human rights, planning and public law, and advice on governance for charities and campaign groups.  For more information visit https://www.hglaw.co.uk/

About Professor Smythe: David K. Smythe is Emeritus Professor of Geophysics at the University of Glasgow. He took early retirement from the Chair of Geophysics in 1998 when the Department of Geology & Applied Geology was closed. He lives in France. His main current research interests are fracking, nuclear waste disposal, and nuclear accidents. For more information visit: https://www.davidsmythe.org 

2 Nov 2019 moratorium – What’s the fracking problem?


A temporary pause

The moratorium has been widely criticised in the press as an “election stunt” to hold on to voters as public support for fracking has dropped to an all-time low. The main criticism has been around the fact this moratorium is only a temporary pause and so easy to reverse when “compelling new evidence is provided”.

Published a few days later, the government response to consultation on whether to introduce permitted development rights for shale gas exploratory drilling, said that although not being taken forward now, “there could be considerable merit in taking forward these proposals in the future” and that “the government remains committed to making planning decisions faster and fairer for all those affected by new shale developments.”


Limited scope

But the temporary nature is not the only problem with this moratorium. It is also partial in scope, only covering some fracking operations. And there is confusion about which ones.

The moratorium announcement says that the government will take a presumption against issuing Hydraulic Fracturing Consents (HFC). The requirement for an HFC, along with other controls on shale gas exploration, was introduced by the Infrastructure Act 2015 (IA2015). An HFC is given by the Secretary of State (SoS) for Business, Energy and Industrial Strategy (BEIS). It is required for operations that meet the “associated hydraulic fracturing” definition in the IA2015, which is hydraulic fracturing that “involves, or is expected to involve, the injection of—

  1. more than 1,000 cubic metres of fluid at each stage, or expected stage, of the hydraulic fracturing, or
  2. more than 10,000 cubic metres of fluid in total.”

However, since the 29 November 2017 BEIS ministerial direction to the Oil and Gas Authority (OGA), all operations that meet the definition of “relevant hydraulic fracturing” (introduced in 2016 regulations for protected areas) should also be referred to the SoS for consent. The difference between “relevant” vs “associated” hydraulic fracturing is that the volume is, or is expected to be 1,000m3 at any stage vs each stage (this does make a very big difference!).

So we interpret this as that the moratorium covers only to operations that meet either the “associated” or “relevant” hydraulic fracturing definition.


4 Nov 2019 – Andrea Leadsom’s Written Statement Confusion

The above interpretation is contradicted by Mrs Leadsom’s statement to Parliament on 4 November 2019, where she refers to HFCs but also says that “the OGA are therefore unlikely to approve future Hydraulic Fracture Plans unless new evidence is presented.”

Hydraulic Fracture Plans and Hydraulic Fracturing Consents are two different things.

A Hydraulic Fracture Plan (HFP) is required by the OGA. Its main purpose is to mitigate the risk of induced seismicity through a traffic light system contained within the HFP. The OGA guidance states that an HFP will always be required for hydraulic fracturing operations (any operation where injections are above fracture gradient), but in evidence given to Housing, Communities and Local Government (HCLGC) in 2018, the OGA seems to contradict this by saying that they would not always require an HFP for operations that are below the IA2015 volume thresholds.

It is therefore unclear when exactly an HFP is required, but it is clearly required for a wider spectrum of fracking operations than either “associated” or “relevant” hydraulic fracturing. Therefore, Mrs Leadsom’s statement suggests that the moratorium covers a wider spectrum of operations than “associated” or “relevant” hydraulic fracturing.

Since the reason for imposing the moratorium is because “it is not possible with current technology to accurately predict the probability of tremors associated with fracking” and since seismicity is regulated through an HFP, this conclusion seems correct.


Fracking of PNR1 and PNR2 – neither “associated” nor “relevant” hydraulic fracturing

Neither of the Preston New Road (PNR) fracking operations in 2018 (PNR-1) and 2019 (PNR-2) met the definition of “associated” or “relevant” hydraulic fracturing. The maximum volume in any stage in both cases was only 400m3+, while the total volumes were well below 10,000m3 (see the numbers highlighted in pale salmon below).

In both cases Cuadrilla sought Hydraulic Fracturing Consent from the SoS for BEIS because the expected volumes were much higher than those achieved in the actual operations. It appears that, had Cuadrilla made more realistic expectations, they would not have had to obtain HFCs for neither of the PNR wells.

However, even if the expected volumes matched the reduced volumes actually achieved, Cuadrilla would have likely had to submit and agree Hydraulic Fracture Plans with the OGA for both.

Screen Shot 2019-11-29 at 15.53.18.png

Comparison of all three high volume hydraulic fracturing operations carried out in England to date


Testing the Moratorium  

It looks like the fracking problem isn’t gone at all. The first test case for the moratorium (if it is not reversed before then) might be the Wressle, North Lincolnshire planning enquiry decision, where a Hydraulic Fracture Plan is required for the planned operations (and according to Drill Or Drop, the Environment Permit for the site makes 27 references to hydraulic fracturing), but where the volumes are not expected to meet the “associated” or “relevant” definitions of hydraulic fracturing, and therefore won’t need a Hydraulic Fracturing Consent.

Other cases to watch are the Harthill site in S Yorks where Ineos is pursuing a shale gas development but the company said that the moratorium has no effect since they are not fracking, and Woodsetts (also in S Yorks), where Ineos installed new protest injunction notices.

What about acid stimulation? 

In any case, the moratorium definitely does not cover matrix acid stimulation – a form fracking carried out through injections below fracture gradient (where the rock is dissolved by acid rather than fractured under hydraulic pressure). It is suspected that this form of well stimulation might already be taking place at sites in Surrey and Sussex under the guise of acid wash, therefore escaping vital protections and regulations, including the traffic light system for induced seismicity. Given that, according to data from the British Geological Survey (BGS), Surrey is now one of the UK’s earthquake hot spots, this is a truly shocking state of affairs.


P.S. We are inviting signatures for our open letter to the Government to close this loophole and ban all forms of fracking. The letter is based on an in-depth legal briefing that goes into the above issues in more detail. See here for more.



Acknowledgements: the above analysis would not have been possible without the comprehensive and in-depth reporting by Drill Or Drop?



Sources for comparison chart of high volume hydraulic fracturing:

Preese Hall, 2011

PNR-1, 2018

PNR-2, 2019

Crowdfunder for a judicial review of Horse Hill decision


A local campaigner has launched a Crowdfunder appeal to raise funds for a judicial review of Surrey County Council’s decision to allow massive expansion of oil drilling at Horse Hill in Surrey.

Sarah Finch is looking to raise £25,000 to cover legal costs.

She says, “Like many other people, I wrote objections to the plans for four more oil wells and 20 years of production at Horse Hill. So I was dismayed when the planning committee ignored our well-researched objections.

“The decision to allow 20 years of oil production was wrong.

“It was wrong because of the climate emergency. 20 years takes us way past the time when we need to have stopped using fossil fuels like oil.

“It was wrong because of the earthquake risks in this vulnerable area – and Surrey County Council refused to look at the evidence on this, saying it wasn’t their responsibility.

“And it was wrong because Green Belt countryside is no place for industrial development.

“That’s why I am seeking a Judicial Review of the decision now.”

Ms Finch, working with others from the Weald Action Group, has secured a team of leading environmental and planning lawyers, including barristers Marc Willers QC from Garden Court Chambers, Estelle Dehon from Cornerstone Chambers, and solicitors from Leith Day.

She said, “Our lawyers are working for a fraction of their usual fees but even so, fighting through the courts costs money. I hope that local residents and people concerned about climate change will donate what they can. Together we can get this very bad decision overturned, and make sure Surrey and other planning authorities look at all the implications of oil and gas drilling in future.”


Visit the Crowdfunder appeal:

Open letter to the Government asks for a ban on all forms of fracking

BROCKHAM, SURREY, 2 November 2019 – The Government’s announcement today to end its support for fracking is welcome news, but the moratorium covers only high volume hydraulic fracturing as defined by the Infrastructure Act 2015. It does not cover other forms of stimulation of oil and gas wells, including acid stimulation.

This is despite studies conducted abroad suggesting that many of the risks and concerns surrounding hydraulic fracturing are the same as for acid stimulation, namely induced seismicity, air and noise pollution and groundwater contamination. This has not been well studied or publicised in the UK, despite a number of communities across the country potentially affected.

So today we are launching a legal briefing that sets out the loopholes and ambiguities that exist in the legal and regulatory position surrounding the use of acid stimulation in England. The briefing is titled Acid Stimulation: Fracking by Stealth (available on request) and co-authored by Brockham Oil Watch and Harrison Grant Solicitors, with scientific Advice from David K. Smythe, Emeritus Professor of Geophysics, University of Glasgow.

We are also launching an open letter to the Government based on the recommendations of the legal briefing. We are asking for 1) an amendment of the definition of fracking in the Infrastructure Act 2015 to include all well stimulation treatments which may enhance the productivity of oil and gas wells by increasing the permeability of the target rock, and 2) a permanent ban on all well stimulation for oil and gas exploration and production. We are inviting signatures from campaign groups, environmental groups, elected representatives in the affected communities, academics, NGOs and other supportive individuals and groups.

One specific recommendation of our briefing is that the traffic light monitoring system to monitor and manage induced seismicity should apply to all well stimulation treatments, not only high volume hydraulic fracturing. This is further supported by the fact that the Preston New Road (PNR) tremors, which have brought about today’s moratorium, were caused by injections of fluid well below the volumes defined in the Infrastructure Act 2015 definition [1,2].

The largest tremor at PNR was 2.9ML whilst the largest tremor registered in Newdigate, Surrey was 3.1ML. Suspicions that the Newdigate tremors are caused by operations at the nearby Horse Hill site could be better understood with the implementation of a well-designed traffic light system and adequate reporting requirements.

[1] https://drillordrop.com/2019/04/01/confidential-records-reveal-limitations-of-cuadrillas-lancashire-fracking-operation/

[2] https://drillordrop.com/2019/09/12/cuadrilla-fracked-seven-times-before-record-breaking-tremor-official-logs/

Editor’s Notes

Open letter to the Government: Stimulation of oil and gas wells – reforms required is available at https://bit.ly/3w3j2tI and legal briefing: Acid Stimulation: Fracking by Stealth is available on request.

About Brockham Oil Watch:    Brockham Oil Watch (BOW) is a non-political group of local residents concerned about the threat of unconventional hydrocarbon extraction from the Kimmeridge Clay Formation (or other unconventional reservoirs) at Brockham, and gaps in the current legislative/regulatory framework. For more information visit www.brockhamoilwatch.org

About Harrison Grant Solicitors:    Harrison Grant provides experience and expertise in public law, planning and environmental law (including international law), human rights and advice on governance for charities and campaign groups. Noted for its role in high profile cases, it is recognised as a leading law firm of leading lawyers. For more information visit https://www.hglaw.co.uk/

About Professor Smythe: David K. Smythe is Emeritus Professor of Geophysics at the University of Glasgow. He took early retirement from the Chair of Geophysics in 1998 when the Department of Geology & Applied Geology was closed. He lives in France. His main current research interests are fracking, nuclear waste disposal, and nuclear accidents. For more information visit: https://www.davidsmythe.org 

The Newdigate Earthquake Swarm:   As of 2nd November 2019, 57 earthquakes have been registered in Newdigate. The strongest tremor measuring 3.1 ML was recorded on 27th February 2019. http://www.quakes.bgs.ac.uk/research/SurreyEarthquakes.html

Contact:  contact@brockhamoilwatch.org


Brockham Update – Oct 2019

  • After announcing in June 2019 that the company was in preliminary discussions with a third party regarding a sale of its 65% interest in the Brockham license, Angus Energy is no longer actively selling, although a market buyer could still offer to purchase the site and licence. Angus said it received a temporary extension of its production license PL235 from the Oil and Gas Authority (it was due to expire in Oct 2019) but they have not told us the new expiry date.
  • Angus said there was oil in the Kimmeridge shale at Brockham, but “not in sufficient quantity or under sufficient pressure to want to release itself and come up the pipe.” They said there are variations in the Kimmeridge and that it is really an unknown. Multiple wells in multiple locations would have to be drilled to understand how the rock behaves in different areas.
  • Angus confirmed they have ruled out high volume fracking. The Kimmeridge layers are shallower than 1,000m below ground, and high volume fracking is not allowed. They also told Drill Or Drop? that it is too expensive and too difficult to get community support. Angus did not comment on other fracking-like methods such as acid stimulation.
    • Our comment: if there is not enough oil in the Kimmeridge, it makes little sense to try to extract it.
  • Angus says it plans to re-start production from the conventional Portland reservoir via well BRX2. The Portland has already been exploited at Brockham and is towards the end of its life.
  • Angus will need to apply pressure management techniques (namely reinjection of waste water), to produce the Portland. They previously said: “if we can’t reinject we can’t support the pressure in the reservoir and we can’t get rid of any water that has been produced.” Angus said they were in discussions with the Environment Agency to find a way around this technical issue, but no application has been made.
    • Our comment: In November 2018, Angus was granted a new environmental permit by the EA. This permit prohibited the reinjection of waste water (from Brockham and another drill site – Lidsey) at Brockham because of the risk of pollution of groundwater. There is no groundwater monitoring at Brockham, and Angus was not able to demonstrate to the EA that they had the required procedures in place to monitor well integrity when injecting waste water underground.
    • 31 Oct update: the EA confirmed that they have not received an application from Angus Energy for reinjection, and that they have not had formal discussions with them on this matter. If Angus were to make an application, the EA would need further information from them to formally make an assessment including of any required conditions. 
    • 30 April 2020: the EA confirmed that they have not received an application from Angus Energy for reinjection.
  • Angus also believe there might an opportunity to access the Portland via the infamous sidetrack BRx4Z drilled without planning permission. Although they also obtained a cost estimate to plug and abandon it.
  • If Portland extraction is not viable, the entire site will be probably abandoned and restored to agriculture.
  • Angus also told the Parish Council that they might target other layers, but no other detail is available.
  • Angus tentatively agreed to form a local liaison committee with the Parish Council and members of Brocham Oil Watch. Meetings of this group would begin in November 2019.
  • On 25 Oct 2019 Angus announced that it raised a £1.5m loan facility to pay for the costs of decommissioning oil and gas wells, and that £1m of the loan has been drawn down immediately to be set aside to fund the future restoration of oil sites at Brockham in Surrey and Lidsey in West Sussex. In this announcement Angus also says that Brockham is a valuable asset it still expects to exploit, and that a decision on whether to impair or fully write down its carrying value will be made at the time the full year accounts to 30 September 2019 are prepared and reviewed by its auditors.

Link to PC/Angus meeting notes will be posted if permission given

Link to Drill or Drop Interview

BBC’s “The Corrections” Needs Correcting

Weald Action Group & Frack Free Balcombe Residents Association complaint, October 2019

Re BBC ‘The Corrections’ programme on fracking in Balcombe, first broadcast on Friday September 27th, 2019.

1)    The programme was unbalanced. The subject was ‘the incorrect way fracking in Balcombe was reported in 2013’. But no one from the anti-fracking side of the argument was consulted or interviewed. No member of the Balcombe community was contacted, and no Balcombe resident was heard in the programme. The programme focussed on the industry’s view.

2)    The programme was very poorly researched, in so many ways, detailed below, with evidence/links in footnotes.

3)    Pre-broadcast warnings of error and bias went unheeded. Balcombe residents learnt of its intended broadcast and could see the view it would take from the on-line trail. They supplied factual, balancing information and evidence to the editor and to BBC Complaints, asking that the programme should be dropped or postponed pending investigation, to ensure truth and balance. We received the same answer from the Complaints department and from the editor. They said we should wait to hear the programme before complaining. By then, by now, the damage has been done. Many listeners will believe there is no cause for concern in Balcombe. That is not true.

4)    The programme’s dismissal of the fracking argument was especially damaging at that particular time, exactly one week before the release of Angus Energy’s new planning application was due – for three years of ‘testing’ at Balcombe.

5)    The tone of the presenter was sarcastic and mocking. She spoke of protest and environmental concerns with inexplicable jokiness and scorn. She presented protesters and campaigners as ill informed and violent (neither was true) and as coming largely from outside the village. We have been researching the subject now for eight years, and we are most certainly better informed than the producers of this programme. A great many people from the village protested at the site.

6)   The programme was based on an incorrect assumption that fracking was never planned for Balcombe. That is not true. Oil company Cuadrilla had clearly announced at public meetings and in letters that their intention was to frack.

7)   The ‘we are not fracking at Balcombe’ message came out only in January 2014. In 2014 and 2015, the government, supportive of the oil industry, changed the legal definition of fracking and the definition of ‘conventional’ oil and gas source rocks in planning guidance. Subsequently, many activities that would have been called fracking would not now be called fracking. This ‘Corrections’ programme was about alleged manipulation of vocabulary. They failed to mention those two important cases of manipulation of definitions.

8)    The makers of the programme failed to understand the nature of the planning and permitting process. Planning permission comes in slices. First a company applies to drill, then to test, and then to produce. In Cuadrilla’s case, they applied in the first instance to drill and test. Villagers were clearly told at meetings with Cuadrilla that the test would involve injecting fluids at a pressure just below fracturing point ie ‘not quite fracking’. The fracking would come later, within a new planning phase. Protesters and campaigners knew that. They/we knew that fracking would not take place in 2013. Fracking was for later. We are not stupid. The oil industry increasingly exploits this ‘permission creep’ phenomenon in its eagerness not to admit, yet, that their end game is to frack.

9)   The makers of the programme failed to understand that to stop fracking at the Balcombe site at a later date we knew we needed to protest at drilling stage. Once a company has spent £3.5m on drilling a well, it is hard for council minerals planners to say, ‘No, you can’t test it and you can’t produce from it!’ The protesters/campaigners knew the current planning permission was due to run out at the end of September 2013. The aim of the protests was to delay the drilling so that they would run out of time, and to raise awareness of the hazards of fracking.

10) The programme presents the idea of fracking for oil in the South East as a construct of silly-season journalists and dim-wit protesters. On the contrary, fracking in South East England is a deeply concerning future prospect that has been belittled by this programme.

11) The programme said oil production in the South East would be ‘conventional’ ie in geological terms from permeable rocks. This is a matter of spin and vocabulary manipulation. See below and please ask for further detailed explanation and evidence if required.

12) The programme makes no mention of acidising, an interim stage before fracking the shale – see below and see the attached leaflet 


Screen Shot 2019-07-10 at 16.57.10

Fracking was in truth always the plan – the detail

Oil and gas prospectors Cuadrilla and their then operator Bolney Resources wrote to the Department for Energy and Climate Change in June 2011 that their plan had ‘always been to drill (a) well(s) (vertical and/or horizontal) targeting the Kimmeridge Shale and to hydraulically fracture stimulate… Without the ability to undertake hydraulic fracture operations, Bolney will not be able to attempt commercial production.’(1) Fracking was at that time subject to a government moratorium following induced earthquakes near Blackpool. The following January 2012, in front of a packed hall in Balcombe, Cuadrilla explained how fracking worked and expressed their intention to frack. See below (2) an article in the Telegraph about this meeting. Thus, when in 2013 protesters from the village and beyond gathered at Balcombe to oppose Cuadrilla’s plans, there was no doubt whatsoever that at some point in the future Cuadrilla intended to frack.

Cuadrilla in fact could do no more than drill during the summer of 2013 because they ran out of time, thanks to the protests. Their planning permission expired at the end of September and they had to leave the site.

Balcombe’s current site operator for Cuadrilla, Angus Energy, own a site on the same geological formation only 14 miles away in Brockham, Surrey. They announced recently that ‘It is extremely unlikely that commercial hydrocarbon flow can be established from the Kimmeridge layer at Brockham’ without fracking (3). (‘Kimmeridge layer’ means the thick layer of shale interspersed with thin layers of muddy limestone.)

The Kimmeridge layer of interbedded shales and limestones under the Weald is the kind of geology that needs to be fracked, cracked open, to release its oil. Once the fractured portion of rock runs dry, another well needs to be drilled, and then another. Looking into the future, the industry would need hundreds of wells across the region to exploit to the full the areas they have licensed. The CEO of one company exploring the Weald has spoken of ‘this kind of geology’ requiring wells ‘back to back’(4).

A new oil field across this beautiful countryside, especially at a time of climate crisis, is no joke.


For the oil and gas industry it’s a ‘seismic event’ when the earth shakes. For affected communities it’s an ‘earthquake’. Dictionaries define both in the same way. The programme followed the industry line and scoffed at campaigners using the (perfectly correct) term ‘earthquakes’. Their interviewees said that fracking-induced earthquakes are tiny, comparable to a bus passing your house. But earthquakes near Cuadrilla’s Lancashire fracking site peaked at 2.9 on the Richer scale and have damaged houses. The earthquake at Cuadrilla’s earlier Lancashire fracking site in 2011 damaged the well so badly that it had to be shut down. Earthquakes are stronger underground. Damaged wells can release methane and other pollutants into the environment.

Don’t use the F word! Manipulating language – the other side of the argument

By the end of 2013, the public had correctly begun to realise that fracking was a threat to the environment and public health. The word ‘fracking’ had become a PR menace to the oil and gas industry. In the ensuing months and years, ways were found to avoid the F word.

In January 2014, three months after the end of the roadside protests, Cuadrilla declared they had drilled horizontally into a thin muddy limestone layer amidst the thick layer of shale (muddy limestone is much easier to drill through than the jagged shale) and they had found that it ‘didn’t need fracking’. Instead they would dissolve channels through the limestone using acids and other chemicals. This is known in the trade as acidising, and, at a certain pressure, acid fracking (5).

‘Hydraulic fracturing’, in the industry, had always been used to mean fracturing the rock. But in 2015, the government, eager to support the fracking industry, introduced into the Infrastructure Act a new, narrower definition of hydraulic fracturing/fracking based on the amount of water used(6). Under this definition, 89% of the oil wells that have been fracked in the USA would not be considered in the UK to have been fracked(7). The government also inserted an incorrect definition of ‘conventional’ oil-bearing geology into minerals planning guidance(8). Now all limestone was to be considered ‘conventional’ – so the industry could declare all their activities in the thin limestone-rich layers to be ‘conventional’.

Yes, language matters. Communities across the Weald have had eight years to study fracking and acidising with all the politics, antics and semantics that come with them.

Some other errors that also need correcting

a)    The industry writes frac’ing with an apostrophe. They do say frac’ing, and that apostrophe stands for a k.

b)    ‘Shale deposits are mostly in the North. Yes, but there are significant shale deposits in the Weald Basin in the South East. The north has mostly gas, the South East has mostly oil.

c)    Barton Moss in Lancashire had little media coverage, the programme said. How shocking that the BBC, so close to Barton Moss from their new home in Salford, for the most part failed to cover this ‘story’. Yes, there is a southern media bias and yes, Balcombe had the advantage of being on the London to Brighton line and being inhabited by, amongst others, lawyers and professors within easy commute of London. Successful publicity does not equate with spurious story.

d)    The programme said ‘shale gas produces less carbon dioxide than coal or oil. Yes, when it’s burnt. But during production, treatment and transmission enough methane is lost to outweigh that ‘advantage’. In any case, all three must be phased out.

e)    The American flaming tap (or ‘faucet’ as the producer described it, adopting the vocabulary of her American industry-influenced source) had nothing to do with nearby fracked wells, the industry and this programme insists. See http://1trickpony.cachefly.net/gas/pdf/Affirming_Gasland_Sept_2010.pdf for the balancing view of this industry-driven denial.

It is a pity that ‘The Corrections’ failed to do their research, failed to speak to the people of Balcombe, and took no notice of detailed information sent to them by Balcombe residents in plenty of time for this error-ridden programme to be pulled.


  1. Letter reveals Cuadrilla “had to frack Balcombe area of the Sussex Weald to be commercially productive”
  2. Shale gas: the battle for Balcombe’s riches
  3. Angus looks to sell Brockham after sidetrack found “uncommercial” without fracking
  4. CEO Interview: Game changer for UKOG, the Weald Basin, and the UK oil and gas industry
  5. Weald Action Group — Frack Free Sussex
  6. Infrastructure Act 2015
  7. Haszeldene S and Smythe D, Nature August 2017 https://www.nature.com/articles/548393a?foxtrotcallback=true
  8. Minerals



Kathryn McWhirter, Balcombe

Professor Lawrence Dunne, Balcombe


More Drilling For The Kimmeridge Oil That Angus Energy Said Could Not Be Produced Without Fracking

On 4th July IGas announced that it is planning to drill two wells at a new site in PEDL (Petroleum Exploration and Development License) 235, just west of Dunsfold, where another driller – UK Oil & Gas (UKOG) is in the process of securing a planning permission to also drill an exploratory well. In addition to the conventional Portland sandstone, the new wells are to target the Kimmeridge rocks – the same strata UKOG and Angus Energy (the third Weald player) are after at various locations around the South East including Brockham, Horse Hill, Balcombe, Broadford Bridge, Arreton on the Isle of Wight and an, as yet unnamed, location targeting the Holmwood prospect in PEDL 143 (which was going to be drilled from Leith Hill until the Environment Minister, Michael Gove, pulled the plug on these plans after nearly 10 years of planning battles).

The IGas announcement comes hot on the heels of news from Angus Energy the week before that their infamous Brockham sidetrack was extremely unlikely to flow commercially without stimulation such as hydraulic fracturing.

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In light of the recent persistent assurances of UKOG, Angus and now IGas that the unconventional Kimmeridge reservoir can be produced via conventional methods (or conventional wells), this is an astonishing admission, which vindicates what we have been saying all along – that the Kimmeridge will need fracking (whether with water or with acid) to flow commercially. Our warnings have been based on the available geological and extraction data from similar reservoirs elsewhere in the world, and on the expert opinion of David Smythe, Emeritus Professor of Geophysics at the University of Glasgow.

Angus Energy’s statement agrees with what Cuadrilla (who since handed over the operatorship to Angus) said about producing the Kimmeridge in Balcombe in 2011; their letter to the Department of Energy and Climate Change (the predecessor to today’s Oil and Gas Authority) reads that the company would “need to rely, to a significant degree, on being able to undertake hydraulic fracture stimulation(s) of this unconventional reservoir.” Some years later, the Balcombe Kimmeridge is yet to be successfully tested…

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At Broadford Bridge, where UKOG tested the Kimmeridge in late 2017/early 2018, it concluded that the rock “appears to be unproductive due to low reservoir permeability” and that new completion and “other reservoir stimulation techniques” would be considered on future wells (see here and here).

Horse Hill, also operated by UKOG, is the only site where, according to the company, the Kimmeridge has been flowing oil (although its development has been put on hold until after the start of full-scale Portland production..). Detailed analysis shows that the Horse Hill exploratory well was drilled into a fault, presumably to help the flow. And UKOG has been less than clear about the methods it is using on this well. In 2015 Stephen Sanderson, the firm’s chief executive and executive chairman, was openly talking about stimulation; while a 2016 paper published by EY – the global consultancy – and commissioned by UKOG, said that the Kimmeridge will likely require stimulation with acid to flow to surface at commercial rates (despite the apparently naturally occurring fractures). But since then UKOG has revised its position, claiming that only a weak acid wash should be used (while inadvertently confirming they did more than that at Broadford Bridge, but that it didn’t work).

In addition to this confusion we are also dealing with muddled definitions in the UK legal and regulatory framework about what fracking actually is, and whether it includes acid stimulation (we will explore this in another piece). Whatever the definition, the Kimmeridge rock is tight and any production expected to decline rapidly, and the proliferation of wells we are seeing looks like the beginning of what Mr Sanderson described in early 2016 in his famous statement: “this type of oil deposit very much depends on being able to drill your wells almost back-to-back so it becomes very much like an industrialised process”. You can watch see the exact excerpt here:

Who knows, maybe none of the above matters anyway? If, as Angus seem to also surmise (somewhat contradicting the above conclusion), the Kimmeridge at Brockham is not mature and doesn’t have enough recoverable oil, then no amount of fracking, acidising or other extreme methods will make the Kimmeridge wells commercial.

Breaking Brockham News, Earthquakes & Horse Hill Update

Brockham News!

We have some very important news to share: last Friday Angus Energy announced that “it is extremely unlikely that commercial hydrocarbon flow can be established from the Kimmeridge layer at Brockham” and that they have entered into discussions to sell their 65% interest in the Brockham license to an unnamed third party. The news slashed Angus’s share price by 60% in a single day. It came as a huge surprise not only to us, but also the investor community, who were expecting Angus to continue with the well tests commencing in the week of 17 June, as per the published regulatory news release two weeks prior.

Angus also clarified that the Kimmeridge would not flow “on any conventional approach” and that they ruled out the use of stimulation techniques including hydraulic fracturing (because Angus Energy is a non-fracking company, i.e. they don’t have the expertise or the financial resources to frack successfully), in effect confirming what Professor David Smythe, BOW and others have been saying all along – that it will not be possible to commercially produce from the Kimmeridge without hydraulic fracturing or acid stimulation.

This means that there’s still a danger that Angus will sell the Brockham operatorship and their 65% interest in the license to a company who will want to frack. We will be watching developments closely.

In the meantime, we’d like to thank all those who have been keeping a watchful eye on the actions of Angus Energy at Brockham, and helping to maintain pressure on the regulators to make sure the site is monitored closely. We can say with certainly that the scrutiny by regular people made a difference.

Earthquakes Meeting

Over 150 people, including a number of local councillors, attended a public meeting on earthquakes and unconventional drilling in the Weald Basin we held last month at Beare Green Village Hall.

David K Smythe, Emeritus Professor of Geophysics in the University of Glasgow, delivered the main talk, covering the history of oil & gas exploration in the Weald between 1960-90 versus the current phase led by penny-share companies of questionable competence and integrity, the reasons why he supports the Edinburgh University thesis that the Newdigate earthquakes are induced by activity at the Horse Hill site, and recommendations for local residents as well as their elected representatives.

To watch the recording/ see slides, go here.

On a related note, we created a page dedicated to the Newdigate earthquakes and a page tracking related news, where you can catch up on what happened so far.

More on Horse Hill

The meeting to decide on the significant expansion proposals at Horse Hill has been postponed yet again, and it is currently planned for 11th September 2019. This application received over 1,000 objections. Although the official consultation has now ended, you can still comment to the council (here are some helpful links).

And more..

We also want to share this recent story about a breach of blowout preventer safety laws at Horse Hill. Blowouts pose risk to life for well workers, and can have profound consequences for the environment and wildlife. Please share this story with anyone concerned.