Environment Agency objects again to UKOG’s South Downs oil drilling plans

EA objection on Markwells Wood

Plans to produce oil at a site in the South Downs could pose an unacceptable risk to a nearby source of drinking water, the Environment Agency has said.

In a response published this evening, the organisation said it was maintaining its objection to proposals by UK Oil & Gas Investments plc for its wellsite at Markwells Wood, near Rowlands Castle. The company wants to drill four new wells at the site and produce oil for 20 years

The Environment Agency (EA) recommended refusal of UKOG’s planning application in November 2016, saying the company’s groundwater risk assessment was not detailed enough.

UKOG produced a revised risk assessment last month (March 2017). The author, Envireau Water, concluded that the risk of operations at the site to groundwater was low or very low and no greater than drilling a conventional water well.

But the EA said:

“We maintain our objection to the planning application, as amended, as we consider that the application has not provided sufficient information to demonstrate that the risks to groundwater and the public water supply are acceptable”

“The development could pose an unacceptable risk to groundwater resources from which supplies of potable [drinking] water are obtained. Further evidence based assessment of the hydrogeology at the Markwell’s Wood site is needed to show the potential risks are fully identified and understood.”

The EA added:

“In the absence of adequate information, we adopt the ‘precautionary principle’ to manage and protect groundwater and the public water supply. We recommend that planning permission should be refused.”

Water for Portsmouth


The Markwells Wood site is in the catchment area of the Bedhampton and Havant Springs, 8km away, which supplies drinking water to about 200,000 people in the Portsmouth area.

The EA said there was a “significant possibility” that a network of underground fissures in the chalk could allow groundwater to flow rapidly from the site to the springs. It said:

“There is a risk that should groundwater become polluted from either surface or deep activities associated with the development there would be little opportunity to intercept the pollutants before they reach the public supply”.

The EA said the revised risk assessment failed to provide site-specific evidence to support the conclusions and a number of uncertainties remained.

“We consider these uncertainties to be significant in the decision-making process and as such we are adopting the precautionary principle in our response”.

The company’s risk assessment has also been strongly criticised in an appraisal commissioned by Markwells Wood Watch, a community group which opposes UKOG’s plans.

The appraisal, by Dr Aidan Foley, concluded the revised risk assessment contained “significant shortcomings”, “factual errors”, “misinterpretations of basic sources of information” and omissions”.

Dr Foley said:

“Several serious misinterpretations and omissions undermine the credibility of the conceptualisation and thus the basis of the risk assessment”.

Key issues

The EA said UKOG’s risk assessment had not adequately addressed research on the area by the British Geological Survey. This concluded that there were likely to be connected underground networks of enlarged fissures and conduits in the Markwells Wood area, through which groundwater flowed to the Bedhampton and Havant springs.

The risk assessment had argued that these features, known as karstic, were less frequent at Markwells Wood than other parts of the area. But the EA said there was possible evidence of these features near the site. It said research suggested groundwater in the area could travel rapidly, sometimes up to 6km in less than 48 hours.

Dr Foley and the EA said the risk assessment should have discussed the loss of drill fluids during construction of the existing well at Markwells Wood in 2010. Dr Foley said there were significant drilling fluid losses in the Upper Chalk section of the well at 131m and 231m below ground level. The site operator had to introduce aggregates into the borehole to stop the loss at 131m, so the cavity must be sufficiently large to transport drilling fluids away from the well, Dr Foley said.

Dr Foley also argued that the risk assessment was based on generalisations about how water moves through chalk.

“There is a consistent downplaying of the groundwater vulnerability”, he said.  Some information was misinterpreted and the potential significance of dry valleys around the site had been dismissed. Dr Foley added:

“It is unreasonable to conclude [as the risk assessment did] that the UKOG site locality is hydrologically isolated and very different from elsewhere in the catchment”.

“Inconsistent with planning policy”

The EA concluded:

“We maintain the application, as submitted, continues to be inconsistent with national and local planning policy.”

It cited:

Paragraph 109 of the National Planning Policy Framework: planning decisions should ensure that new developments do not result in unacceptable levels of water pollution

Policy 16 of the West Sussex Minerals Local Plan 2003: appropriate measures will be required for safeguarding the water environment during working

Policy M16 Draft West Sussex Joint Minerals Local Plan 2016: mineral development will be permitted provided that they would not cause unacceptable risk to the quality and quantity of water resources or causes changes to groundwater

Policy SD15 of the South Downs Local Plan: Development proposals that comply  with other relevant policies will be permitted provided that they safeguard groundwater aquifers from contamination.

Other comments and decision date

The South Downs National Park Authority’s planning committee is expected to consider the Markwells Wood application at a meeting on 11 May. The authority has said it will take comments up to the date of the meeting.

As well as the recommendation to refuse from the EA, the authority has received objections in the past few days from its own landscape officer, Markwells Wood Watch, Stoughton and Rogate Parish Councils and Sussex Wildlife Trust.


Link to planning application  (click on documents for responses)

DrillOrDrop’s Markwells Wood key facts and timeline

DrillOrDrop report: Study identifies risks to drinking water from UKOG’s South Downs oil drilling plan (1 April 2017)

6 replies »

  1. “As well as the recommendation to refuse from the EA, the authority has received objections in the past few days from its own landscape officer, Markwells Wood Watch, Stoughton and Rogate Parish Councils and Sussex Wildlife Trust.”

    “its own landscape officer, Markwells Wood Watch, Stoughton and Rogate Parish Councils and Sussex Wildlife Trust.” – none of these are sufficient to stop planning permission being granted by the Planning Committee / PINS at appeal.

    However the EA objection on it’s own is sufficient and planning permission will be refused (as it should be in this case).

    • Yep. I can create 2 groups, Markswell Wood 1 and Markswell Wood 2. MW1 can then write in supporting it and MW2 can then write in opposing it. Its meaningless. The EA is capable of judging something for itself and even if I create 50 groups opposing something and then 10 groups supporting the same my 5/1 favouring one position doesn’t mean much.

      I am pleased to see the EA doing its job. If any company wants to do anything anywhere it needs to show it can do it safely. Me going around and telling people whatever I want on the doorstep, ‘arrr, they’re gonna kill ya all’, is gonna get me some signitures and me forming ‘World Super Dupa Mega Big World Protection Super I Care About Everything Wonder Group’ and writing in to oppose everything everywhere ever doesn’t mean I have any power, even if I get off my bum and knock on 100 doors per night and…. ‘arrr, they’re gonna kill ya all’. Yay! Another 20 signitures.

    • The EA have to consider source, pathway, and receptor.

      They have identified the presence of polluting material and it’s source.

      They recognise the threat to the the public water supply.

      In this application they acknowledge the existence of pathways through fissures and conduits.

      Fracking creates fissures and conduits. That is how it works.

      Thousands of induced fractures would create an environment which could join the natural fractures, noted by the BGS, in the Bowland Basin. The Preese Hall well confirms this can easily happen.

      Any application which would create pathways for pollution to identifiable sensitive receptors should be objected to by the EA.

    • Yep, and the EA know the defintions too. The companies plan has to demonstrate they fully understand it as well and that their plans can mitigate it, otherwise, no chance.

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