Dear BOW Followers,

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

“Back to back” wells are Horse Hill?

Catholic Church, 4 Vicarage Ln

Horley RH6 8AR

Tuesday 23 October, 7:45pm

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

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

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

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

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

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

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

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

The NSIP consultation document gives a clue on page 9:

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

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

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

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

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

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

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

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

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

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

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

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

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

 and that

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Link to webcast from meeting.

Dear BOW Followers,

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

PRESENTATION SLIDES 

You can view the presentation here

VIDEO 

PART 1 – Earthquakes 

PART 2 – Earthquakes Continued

PART 3 – Brockham Planning Application MO/2018/0444

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

Dear BOW Followers,

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

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

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

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

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

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

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

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

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

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

P.S.

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

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

Best,

BOW

https://brockhamoilwatch.org/

Twitter: @BrockhamWatch

Facebook

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.

Brockham

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.

Horse Hill

With respect to the Horse Hill site, UK Oil & Gas (UKOG) announced on 27^th 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. [1]

Conclusion

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.

Best,

BOW

https://brockhamoilwatch.org/

Twitter: @BrockhamWatch

Facebook 

[1] 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 8^th of August.

 Three new documents were added on the 13^th 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, 3^rd 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.

​

Best,

BOW

https://brockhamoilwatch.org/

Twitter: @BrockhamWatch

Facebook

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.

PROFESSOR SMYTHE’S SUBMISSION

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.

PLEASE SEE HERE MORE DETAIL ON THE KIMMERIDGE AND ACID STIMULATION

ENVIRONMENT AGENCY AND RE-PERMITTING OF BROCKHAM

Read here Drill Or Drop Article on this loophole in the system

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.

(1) Kimmeridge Limestone Oil: The UK Opportunity, April 2016, EY (Commissioned by UK Oil & Gas Investments PLC (UKOG)

Best,

BOW

https://brockhamoilwatch.org/

Twitter: @BrockhamWatch

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