14th March 2014
Staff from West Sussex County Council had weeks of negotiations with Cuadrilla’s planning consultant over what information should be included in the company’s application to flow test its well at Balcombe.
The evidence emerged in the response to a Freedom of Information request by InvestigatingBalcomebAndCuadrilla.com which asked for correspondence between the council and the consultant, Ove Arup and Partners. It helps to explain why there was a wait of nearly seven weeks before the application was published.
Much of the correspondence is between Jane Moseley, the council’s Principal Planner, and Nigel Gould, an Arup associate. It covers the period between submission of the application on December 5th and publication on 22nd January.
The application is to test the flow of oil in the exploration well at Lower Stumble. Part of the process involves acid washing or flushing to clean the well bore with diluted hydrochloric acid under pressure.
According to the correspondence, the two sides appeared to disagree on how much information was needed on the visual impact of the rig (described as a workover rig). There were also discussions about the noise of the generator and the possible impact of hydrochloric acid on groundwater.
Jane Moseley asked for at least two cross-sections of the site to show the height of the rig and other equipment. She wrote: “If the exact equipment to be on site has yet to be determined, a ‘worst case scenario’ should be used for the scale of equipment.”
Ms Moseley asked for information on the generator (its type, how long it would be on site, the hours it would be used and the measures that would be in place to mitigate noise). And she requested information on how much hydrochloric acid would be used and what impact it was likely to have on groundwater.
Nigel Gould replied saying that he had not been able to acquire a cross-section, even in draft form, of a suitable rig. He said “I would therefore suggest that the details are submitted with the notification of the start of works i.e. when the exact specification of the rig is known.”
Mr Gould also said the Environment Agency would be responsible for controlling any pollutants on site and the make-up of the ‘acid flush’.
Ms Moseley replied on the same day, saying she would await information that would allow her to validate the application on January 2nd.
Mr Gould sent a revised planning statement that he said “takes on board the comments raised in your email of 13th December”. He asked for confirmation that the application had been validated and registered.
Ms Moseley wrote “I do not agree that sections [the cross-sections] are not required.” She said the exploration site was in an Area of Outstanding Natural Beauty and the visual impact of the equipment would be considered by the planning committee. She said site cross-sections had been provided for other exploration applications. “I do not consider it unreasonable to require that these accompany the application.”
On the generator, she said further details were needed to clarify how it would be used. “Noise is a key issue on this site and affects our consideration of the proposal.” She said the application indicated that the generator would be used day and night for the whole six-month period of the planning application. “We therefore need reassurance that Cuadrilla has considered the potential impacts of this, and reassurance that the operations would be different to those over the summer.”
On both the cross-sections and the generator she wrote: “Please note – I cannot validate the application until this information has been provided.” [Miss Moseley’s emphasis].
Ms Moseley also said there was still no clarification on the impact, if any, of the hydrochloric acid on groundwater and asked for information on this point.
Mr Gould wrote to say he had attached an amended statement responding to the issues Ms Moseley had raised.
At 10.29am, Ms Moseley wrote “I am struggling to justify validating the application without elevations/sections of the site – showing the workover rig on site.” She said the height of the rig at 22m was “entirely relevant” to the determination of the application. She asked for clarification on how long the rig would be on site, whether it would remain when it was not being used and whether it would be fully extended at all times.
Mr Gould replied at 3.00pm referring to a drawing attached to his previous email. This, he said, indicated the maximum height and length of the workover rig. He said the rig would remain on site throughout the operation and provided details of when it would be fully extended. He said the workover rig was 10m lower than the drilling rig that had previously received planning permission. “The visual impact of the drilling rig was considered acceptable”, he said. “With the reduced rig size and temporary period of use detailed I consider the visual impact to be of minor impact and of a greatly reduced impact compared to the drilling rig.”
Mr Gould proposed two options:
- Submitting the planning statement with the drawing, with a condition that the exact specifications would be provided before work began, or
- Providing a scale drawing, with a caveat that the exact details would be confirmed before work began.
He said the operation would be short term, temporary and reversible. “The impact on the AONB is minimal…There are no sensitive receptors nearby and …my preference would be the first of my suggestions.”
The correspondence does not include Ms Moseley’s reply and it appears the issue was discussed by phone.
Mr Gould sent the final amended planning statement.
West Sussex County Council registered the planning application. The final document included:
- Drawing showing “typical dimensions of the workover rig”
- Four photos with a rectangular shape superimposed to represent the rig
- Confirmation that 20 cubic metres of diluted (10%) hydrochloric acid would be circulated through the well
- Statement that the Environment Agency and Health and Safety Executive had concluded that methods proposed were safe for surface and groundwater
- Statement that the exact specification of the generator could not be confirmed
- Specifications of a typical silenced canopy generator
The Freedom of Information response is available at https://www.whatdotheyknow.com/request/correspondence_relating_to_plann_2#incoming-492355