Campaigners opposed to drilling in the Surrey Hills said the chance of finding oil at a site near Leith Hill was small and any oil that was recovered was likely to be nationally insignificant.

The Leith Hill Action Group was giving evidence this morning on the third day of a public inquiry into plans by Europa Oil and Gas for an exploratory oil well at Bury Hill Wood, near Coldharbour.

Patrick Nolan, the group’s chairman, said the company’s own figures showed there was a 70% chance of not finding any oil at all. The probability of the well producing Europa’s estimate of 5.6m barrels over its lifetime – about 0.04% of UK annual oil supply –  was just 10%.

“In national terms any oil extraction from the development would be insignificant”.

Mr Nolan said the need for oil was outweighed by the harm that the drilling site would do the landscape, the area’s tranquillity, local businesses and visitors. The proposed site is in the Green Belt and the Surrey Hills Area of Outstanding Natural Beauty (AONB).

The inquiry in Dorking is the latest stage in a long-running planning battle between Europa and local residents over the proposal, which was first submitted in 2008. Surrey County Council’s planning committee rejected the planning application, against the advice of officers. The company appealed but a public inquiry upheld the decision. Europa then went to the High Court, which overruled the inquiry inspector. Leith Hill Action Group (LHAG) took a case to the Court of Appeal to overturn that judgement but lost. The current inquiry is hearing all the evidence again.

Drill site breaks national planning rules

Mr Nolan said LHAG believed Europa’s proposal broke national planning rules. It was, he said, an inappropriate development in the Green Belt and there were no special circumstances to justify it. The site also failed the test of major developments in an AONB, which required they must be in the public interest or there should be exceptional circumstances.

Europa has said Bury Hill Wood is the only feasible site it could use to explore the Holmewood prospect and it has ruled out sites outside the AONB. But Mr Nolan told the inquiry the company had admitted there was no technical reason why it could not drill from outside the AONB and it had costed this option.

Government policy requires planning authorities to take account of the national need for oil and gas when considering planning applications. But guidance for drilling AONBs allows them to consider opportunities for meeting that need from other supplies. Given the insignificant amount of oil that was likely to be generated, the inquiry should look at these other opportunities, Mr Nolan said.

Questions over lorry journeys

Europa’s proposed access road to the drilling site, Coldharbour Lane, was one of the most heavily used cycle routes in the country outside London, Mr Nolan said. Yet the company had estimated there would be about 1,000 journeys by heavy goods vehicles (HGVs) during the 18 weeks the site was in use.

Mr Nolan said the number of HGV journeys could be even higher. Since the estimate of 1,000 had been made, the Enviornment Agency had required Europa to change the design of the well. This led to a doubling of the well’s volume, Mr Nolan said. LHAG had asked Europa about the implications for HGV traffic but it had not responded.

Critique of Europa’s evidence

Sustainable development Mr Nolan said a Europa consultant had tried to claim that the well site was sustainable development. To do that he should prove it would, among other things, protect and enhance the natural environment. “The environmental role is justified purely on the grounds that this development will have regard to the protection of the environment”, Mr Nolan said. Even if the development were seen in the most positive perspective, it was “hard to see it meets an environmental role”.

“If drilling for oil in the middle of the most protected possible landscape could be judged to be sustainable development then I don’t see how the term has any meaning”.

HGV route In its evidence to the inquiry, Europa has described Coldharbour Lane as an established HGV route. Mr Nolan told the inquiry this was untrue because there was a width restriction of 6ft 6” on the road.

Increase in HGV traffic Europa said the increase in HGV traffic would be very small or negligible on Coldharbour Lane but in other parts of its evidence it admitted there would be up to a 400% increase. Mr Nolan said guidance classed even a 90% increase as “substantial”.

Tranquillity Europa has sought to undermine suggestions by opponents of the scheme that the area around its proposed site was tranquil. The company has used a map, produced by consultants for the Campaign for Rural England, which identified the area as semi-tranquil. Mr Nolan said Europa had misunderstood the map. It was designed to show change over time at a national, not local level. He said the methodology meant that tranquillity was judged against a set of indicators. Two were relevant to Bury Hill Wood. It was within 2.2km from the edge of Dorking and opposite a small car park.

“What you need to do is go there and form a view of whether it is tranquil or not”, Mr Nolan said. “If that tells you this is high tranquillity, this supersedes this crude and low resolution map”.

Noise of forestry operations Mr Nolan said Europa had implied noise from forestry operations was continuous at the site. But Mr Nolan said it was rare.

Impact on amenity Mr Nolan said Europa had ignored the impact of HGVs on the amenity value of the area for residents, walkers and cyclists. He said in one part of the evidence, another Europa’s consultant “effectively states that cyclists should just go elsewhere”.

The public inquiry continues on Tuesday 28th April when it will hear Europa’s case for the drilling site.

Reports from Day 1: Morning and afternoon

Reports from Day 2: Morning and afternoon