Yesterday ( Wednesday) the members of the Surrey County Council Planning and Regulatory Committee met to consider the application for the retention and extension of wells at Horse Hill, near Gatwick in West Sussex – to drill for oil and gas from 6 wells for 25 years.
I have never received so many emails on one concern, and these with the agenda papers made for a lot of reading.
During the meeting, there was much to listen to as there were 5 opposition public speakers and 3 speaking for the application. The concerns cover the “swarm” of earthquakes and damage to the environment in this time of Surrey County Council’s declared Climate Emergency.
The applicants emphasised that it is crucial to have a secure national source of energy and the community would benefit from jobs and a share of the wealth, and those who oppose are “scaremongering”.
This is the essence of my comments.
- If it is accepted that these earthquakes are “naturally occurring” and are not caused by drilling, then clearly the company is drilling in an earthquake zone. The committee should impose the condition of a large bond so that any damage now and in the future will be compensated.
This was not supported.
- We are considering an application that is for 25 years of operation. Should there be a break for re-evaluation after 5 years? Officers noted that there is a regulatory requirement to do this after 15 years, and this could not be amended.
There was a discussion about asking the company voluntarily to monitor seismic events in the long term…….
The vote was 7 to 2 in favour of the application. One of the public speakers noted,
“This decision could look uncomfortable in years to come”.
A lot of weight was given to the study of the “Surrey swarm” quakes by Imperial College, London, the University of Bristol, and the British Geological Survey (BGS), which is reported not to show a direct link between oil extraction and earthquakes in the region. Refer to the ICL press release – ‘Surrey swarm’ earthquakes not caused by nearby oil extraction, says study by Caroline Brogan – 27 August 2019 https://www.imperial.ac.uk/…/surrey-swarm-earthquakes-caus…/
However, the author of this paper, Dr.Stephen Hicks, noted this caveat in his paper:
Our knowledge of activities at Brockham and Horse Hill-1 relies on reported operational data provided by the operators. This source of data remains a controversial issue when determining induced versus natural causes of earthquakes. This particularly applies to industrial activities that lack any precedence for causing earthquakes, and for areas with a low rate of background seismicity. As operations continue in the long term, we recommend seismic monitoring close to hydrocarbon development and production sites, and high-resolution reporting of operational activities (e.g., well shut-in periods, production volumes, and rates) that is visible to the public. Over time, long-term monitoring could help reduce uncertainties in correlations and causal factors. Moreover, operators and regulators could consider operating small seismic monitoring networks near conventional oilfield operations to better understand any nearby emergent seismic sequences earlier and to reduce uncertainties.
It is interesting to note that the BGS identifies 27 earthquake events in the last 50 days, from 27th July to 6th September, 27 events have been recorded, 7 in NEWDIGATE, SURREY, 2 in MILLOM, CUMBRIA and the rest were just individual events
http://www.earthquakes.bgs.ac.uk/eart…/recent_uk_events.html
The point on seismic activity is well made and in the context of Dunsfold this will be a concern as according to the planning application the “Sweet Spot” being targeted by the sidetrack well is directly underneath the threshold of disused Runway 30 on the airfield. So does the Garden Village design spec need to be upgraded to shake proof windows and wider mantles and shelves with fiddles to keep the ornaments in place?
As a minimum it should be noted in the planning decision that there has been absolutely no record of any seismic activity at all at Dunsfold / Loxley in living memory if ever. If drilling permission is granted and at any time seismic activity is detected, then the burden of proof will be on UKOG to prove convincingly that it was as a result of “natural causes” that have coincidentally only just cropped up after drilling started.
In the absence of this convincing proof then all activity should cease until such proof is available to the satisfaction of all stakeholders.
It was also interesting to note that the argument of Cllr Mallock was very clear that the granting of exploration permission carries with it the strong implication that production permission would be granted if commercially produced reserves were found – there was no strictures on local seismic activity at the time.
He went on to say there were no new grounds for objection to production that were not dealt with when the exploration permission was granted and the flaky state of UKOG finances were just as flaky then so there is no justification for asking for a bond – Cllr Mallock has carefully not read the Dunsfold / Loxley application which pleads for permission to drill a sidetrack into the Portland using experimental chemicals and techniques because all their Weald wells at both Broadford Bridge and Horsehill have proved be “sub commercial”. It seems “learnings” from these Loxley experiments are required for any hope of profit and of course this profit is a requirement if UKOG is going to be able to fund the millions of pounds of restoration costs they are already committed to – at least as committed as any company with “limited liability” is to anything.
This has significance for Dunsfold as the argument accepted by the Surrey Officers to waiver a full Environmentakl impact assessment was that the proposed exploration well at Dunsfold was “small and temporary”. The exporession was used over 23 times in the SCC justification so many that it was irritating. The justification went on to say issues arising from any proposed production could be addressed at the time when Production permission was applied for.
We now know that is not the case as Cllr Mallock or hie equivalent may well be on the committee arguing the same case as he argued yesterday.
With this new insight into how the Surrey decision making works there is a strong case that the Dunsfold/Loxley application must be sent back round the block and a complete environmental Impact analysis and consideration of the future implications of any proposed production completed before consideration is given to the exploration application.
This should now be the new policy for any onshore applications for exploration as clearly UKOG has the skills of a giant slalom skier when it comes to evading the very few opportunities that communities have to defend their environment from this flagrant attempt to sustain six figure salaries for a handful of directors for a few more years before they are finally found out.
The WW believes Dunsfold Park’s owners would be horrified to learn that its new Government backed garden village could be adversely affected – before it has even taken off?!
As for the argument accepted by Surrey Planning Officers that a full Environmental Impact Assessment is not requred because the proposed exploration in Dunsfold is both ‘small and temporary’ is utter nonsense.
Waverley Council has accepted that it has a is a legal duty to carry out a full EIA on developments in the borough in future – even though it has played fast and loose with the legislation over here in Farnham for more than a decade in relation to the Special Protection Area in Farnham! No doubt SCC’s planning officers are of the same view.
Yesterday’s decision does not auger well for the Dunsfold area does it?
Everyone in the borough must demand a full EIA – including the owners of Dunsfold Park – to defend the environment in the eastern villages. Let us hope the plumply salaried directors of UKOG can be stopped before they cause any further blight and damage to this vulnrable part of the borough.
How can we at the Waverley Web help?
If folk truly want to help they should listen to Cllr Ernest Mallett on the webcast around 1 hour 23 minutes and to the subsequent clarifications from lawyers on what this committee is empowered to do – which is very little.
Cllr Mallett is very clear that NOW is the time to examine the whole project and Surrey planning officers have been disingenuous in suggesting that we need not worry as the implications for production can be considered when there is a subsequent application.
people can still raise objections here
https://planning.surreycc.gov.uk/planappdisp.aspx?AppNo=SCC%20Ref%202019/0072
Here is the Webcast
https://surreycc.public-i.tv/core/portal/webcast_interactive/440931
He states
“the fact is that the exploration and appraisal stages which we have approved predicate production if in fact that production is possible, if it is not possible it does not happen … to a large extent in my opinion the production phase doesn’t necessarily — is not looking to planning as being a natural area for refusal.
He goes on to assume there is no carbon cost of exploration while transport costs automatically are assumed to cost more emissions.
Mallett opines that we must stick by rules and conventions even if unpopular.
95% of the reasons for refusal on production are the same as for exploration and so have already been dealt with then – not small and temporary then? exploration predicates production permission at the discretion of the explorer
In this case we should be expecting Cllr Mallett to move that the officers were wrong to waiver a full Environmental Impact assessment before the “small and temporary” decision on Dunsfold. The application MUST be deferred so that the genuine planning matters that will be involved in the production of hydrocarbons from the site can be investigated in full including all options on pipelines for both gas and oil, local powerstations and so on.
As he so eloquently says giving permission to explore “predicates” that permission to produce will be granted if commercial production is found to be possible.
Surrey Planning Lawyers state that the only real power that they have is to determine if the development is an acceptable use of the land and they must assume that all the other regulatory agencies will do their job.
So far from it being a trivial decision on a “small and temporary” application this is the first and only opportunity for Surrey MPA to review whether this site is an appropriate use of land for the next 25 years. There will not be another opportunity to examine this and
Mallett goes on to say that our duty is to produce local hydrocarbons because of the carbon emissions arising from importing by sea. In this he ignores the fact that you need about 10 exploration wells to get one producing well – each exploration well causes significant emissions and pollution so every exploration well as a minimum shoukd be required to buy carbon credits to the value of 10 times the carbon emitted during drilling one exploration well which can be traded back when production starts at the rate per barrel of the carbon emissions associated with transporting that barrel by sea.
In fact a more certain and much easier way to reduce the emissions in the round might not be to explore for oil locally but to invest in reducing the emissions of supertankers that are bringing oil from already developed production resources – we already know where all the oil is that we can possibly burn before we must meet our Net Zero obligations.
We will make a seperate post of the information you have supplied – very many thanks WW
you are welcome – one thought – the tanker we arrested at Gibraltar at the behest of the USA carried 2,100,000 barrels of oil – UKOG hope that a well they drill will produce 1000 barrels a day for the first 6 months then 500 a day for another 6 then maybe 250 a day for 19 years.
So 1 supertanker can deliver the entire 20 years of production from one of these wells in one delivery and they can do several deliveries per year.
it is not good enough to produce wild assertions without doing the math and Cllr Mullet should be ashamed of himself.
The supertanker example certainly focusses the mind – especially when Loxley oil would not be piped to a refinery – every barrel would be trucked to Southampton. Hardly the green way of getting a Supertanker’s worth to consumers.
Just imagine all those lorries, joining all the other lorries on our roads. A lorra,lorra lorries coming our way?