Regulation

Angus announces go-ahead for oil production at disputed Brockham side-track

Brockham night working Brockham Protection Camp

Drilling the Brockham sidetrack in January 2017. Photo: Brockham Oil Watch

Angus Energy announced in the past hour that it had received approval from the Oil & Gas Authority allowing it to produce oil from a side-track well drilled earlier this year.

The consent is for a well that has been the centre of a planning dispute with Surrey County Council.

Angus drilled the sidetrack in January 2017 and has maintained consistently that it has planning permission for the work.

The county council has argued that the well was not covered by existing planning permissions on the site and had asked the company to make a retrospective application.

The OGA approval of the company’s Field Development Plan addendum had been predicted on Twitter last week.

risky

“Final approval”

Angus said the OGA approval was the final regulatory consent it needed to begin production from the Kimmeridge formation in the well, known as BR-X4Z.

This morning Angus said the well would initially produce from a 200m naturally-fractured section of a 385m thick Kimmeridge layer of interbedded shale and limestone.

It confirmed an earlier plan, announced last month, to also generate electricity at the site (DrillOrDrop report).

“Prior to initiating production Angus Energy will install a connection to the National Grid for the distribution of excess power generated onsite”.

Angus shares opened up 4% this morning.

Link to Angus Energy statement

“Betraying trust”

At a Surrey County Council planning committee last month, Angus was accused of betraying trust and misleading councillors over the sidetrack (DrillOrDrop report).

The chair, Cllr Tim Hall, said:

“They [Angus] know full well what we think.

“We have legal counsel’s opinion which says there needs to be an application. We have communicated that to Angus Energy. They know our position full well.”

The then development control manager, Alan Stones, said:

“Discussions are ongoing at present in respect of other applications in terms of this site. Early stages but I am hopeful that things would move forward and are sensibly resolved.”

In a recent letter to the Oil and Gas Authority (OGA), Surrey County Council said:

“For the avoidance of doubt, the CPA [county planning authority] considers that no planning permission exists for the sidetrack BRX4z as an exploratory well or for producing from it.”

Surrey County Council has made no public statement since then that its position has changed. DrillOrDrop will invite the council to comment and update this piece with any response.

39 replies »

  1. The OGA obviously disagree with some in SCC, hence the authorisation. Angus legal advice obtained many months ago disagrees with some in SCC. Angus state their consistent public stance is still the same.
    I know it seems unthinkable to some, but could some in SCC actually have been taken up the garden path? It certainly would not be the first time for this particular authority.

    • You’d think you guys would be ploughing in to offshore wind like all the sensible traders, Just shows you how little in the know some of you are!

  2. Great news! Scc need to be ready for a court battle if they are certain. Governmental authority believes permission is in place. A side track is part of an existing well, ‘‘tis not a new welling permission was in place for the original well

    • You’d think you guys would be ploughing in to offshore wind like all the sensible traders, Just shows you how little in the know some of you are!

  3. “If work commences”?? This is an active, operating site already Rachel. This whole process has been about increasing output from an existing site. As all authorisations are in place, a stop notice is pretty unlikely. I’m not sure many Surrey tax payers would be happy about such a gamble, especially as it took SCC so long to get any legal opinion supporting them.

    • Nothing has been happening on site since end of January, when Angus completed their unauthorised sidetrack. So the question is indeed whether the council will enforce when Angus arrive back on site. And let me assure you that many Brockham and Surrey residents are adamant about this and will demand that the council stands strng. They don’t want the values of their properties to collapse!

        • Furthermore, that’s 30 years of harmonious relations and production at Brockham, which also included previous sidetracks having been drilled without issue. The main difference now is that some locals are being brainwashed by propaganda and misinformation fed to them by a small group of antagonists, and lazy journalists who are acting as dumb relays, who do NOT represent the majority. You only have to look at how often the word fracking is used in the same context to see just how misguided these people are. Angus Energy is NOT engaging in fracking at any of its sites.

        • There has been a site there for 30 years, yes, but the target was the Portland, a conventional reservoir. The difference now is that the target is the Kimmeridge Clay – composed mainly of shale. The oil within it is tight and does’t flow. There’s been a number of wells drilled through the Kimmeridge and they never flowed from this strata so why would they now? It is new technology – acidising and fracking. The Kimmeridge is unconventional, even Angus admitted this in their IPO document. But they say that it can be extracted via conventional means – this is an argument for very naive people.

          On a side note, Injureer, you have had a very detailed response from David Smythe, and a very long discussion on another post with Kathryn McWhirter. You are clearly not prepared to listen to the other side so why do you pretend to engage in a discussion? It frankly seems a waste of time.

          • Acidising has been in use for 100yrs+ for both water and oil wells. You say it is new. The facts suggest otherwise.

            Fracking is of no relevance here. Angus Energy are NOT fracking and will NOT be fracking.

            Horse Hill flowed oil to surface from the Kimmeridge with NO FRACKING.

            • You have your facts wrong. I suggest you go and read about the distinction between acid wash and acid stimulation. Then you can read about the issues with current definition of fracking. Then we can continue this discussion.

            • Liuseniuk,

              I actually do know the difference between an acid wash, a matrix acid job and an acid frac.

              Neither Angus nor UKOG will use acid frac’ing, or matrix acidisation, and UKOG did not do so on HH.

              The anti-frac lobby often claim that HM Govt is in the pockets of the Oil & Gas Industry, because volumes in the adopted definition of a Frac in a shale gas Well are apparently so large.

              They also often claim that Presse Hall would not be classified under this definition, because only 8,400cum were pumped.

              However, this completely ignores the fact that six stages were pumped, for an average of 1,400cum per stage (they varied from 39cum to over 2,000cum) and so would have come under this legislation because of the “1,000 cum per stage” clause.

              The volumes used for a Frac definition in UK legislation actually come from a recommendation by the EU commission on the 22nd of January 2014 and was based on actual data from Shale Wells in Denmark, the Netherlands and Poland.

              http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014H0070&from=EN

              Incidentally, the EU commission also refers to requiring ‘Golden Rules’ for the safe development of unconventional gas.

          • Hi liuseniuk,

            If you look at my other posts, I have already explained why the Kimmeridge was never really a target during the 1980’s and 1990’s, and why advances in drilling, drilling fluids and E-Logging technology since then have changed that – primarily better identification of fractures with E-Logs and use of horizontal drilling techniques which were not feasible then.

            That is what has changed. Acidising and Frac’ing are not new technology – frac’ing has been around since 1947 and acidising for much longer than that.

            By drilling horizontal wells, you essentially intersect more fractures. Acid washes are needed to clean out the perforation debris, LCM and cement from cementing the liner to allow the Well to flow.

            It does not need either matrix acidisation or acid fracs to do so.

            Despite the assertions of many, neither Angus or UKOG will frac these Wells – they don’t need to and as I explained in my responses to Kathryn, they couldn’t if they wanted to – you cannot frac a formation that already has natural fractures.

            I am prepared to listen to all views, but I kinda sorta object to being told I’m wrong by someone who has read a bit about the drilling process and thinks they know all about it, while I’ve actually got many years experience as a Drilling Manager / Superintendent / Engineer – including drilling some Wells in the Wessex and Weald basins.

            I would be interested to see Kathryn’s response to my last post in that thread.

            As for the Professor, I was deeply underwhelmed by his response to my post, while also wondering why he chose to put it up on his blog rather than Drill or Drop, until I found he’d also had it posted on several other websites – presumably so his website gets any extra hits rather than Dill or Drop.

            I’m not surprised that UKOG have never bothered to respond to him (although it would help if he actually wrote to them) as I certainly cannot be bothered to chase him cross the Internet. He is acting like a kid caught with his hand in the biscuit tin, because someone dared to call his bluff. He knows it and no amount of bluster, bigging up of his credentials or denigration of mine can hide it.

            He has been proved wrong on both HH and BB-1z and is now grasping at straws.

            What I have not seen him admit is that if his definition of ‘unconventional’ was used, then there are numerous fields throughout the World that would now be classified as unconventional – including some of the largest and most prolific fields in the Middle East, SE Asia and the Americas which are Carbonate Fields that produce through natural fractures.

            Closer to home, all Danish production and much of Norway’s production would also be classified as unconventional by his definition. This includes the giant Ekofisk Field which has been in production since 1971 and it forecast not to finish until around 2050 – I have never heard anyone classify this as ‘unconventional’.

            Neither do Angus classify the Kimmeridge Limestone play as being unconventional.

            http://www.angusenergy.co.uk/wp-content/uploads/2016/11/Angus-Energy-IPO-Investor-Presentation.pdf

            While the matrix permeability is very low, what is crucial is the effective permeability that is seen by the wellbore. This is where the natural fractures come into play – by exposing a large surface area of the formation and therefore hugely increasing the effective flow area.

            I suppose I could follow up on the Professors suggestion and take another Introduction to Geophysics course – it’s been a while since my last one… On the other hand, he certainly needs to take introductory courses on Drilling Engineering, Completions Engineering, Reservoir Engineering and Economics.

            In the meantime, I am not surprised that Glasgow University have disassociated themselves from him and his views.

            • I have seen your other posts and prof Smythe’s detailed reply. No need to repeat the arguments here. I will always put the opinion of a qualified geologist before yours. And definitely no point quoting Angus – they are by definition biased.

            • The Professor is a Geophysicist who has, by his own admission, been retired for over 20 years. He is NOT a qualified Geologist. Neither is he a qualified as a Drilling, Completions or Reservoir Engineer. Or an Economist.

              Why is an oil company by definition biased?

              So people who continue to believe – despite all evidence to the contrary – that these Wells have not and will not be frac’ed, are not biased?

            • The evidence is in science: The Kimmeridge is an unconventional reservoir containing shale oil. Permeability of between 0.02mD and 0.04mD – as in very very low. The OGA compared it to the Bakken formation in the US and we all know what happened there – it was all fracked and many many wells drilled. So yes, all evidence points that the Kimmeridge will have to be fracked (even if under the current UK definition it is not called frack!)

            • Hi Liuseniuk,

              You may have missed one of my other posts, where I explained that what is important is the EFFECTIVE permeability seen by the well bore, not the matrix permeability of the formation.

              By intersecting natural fractures, the effective permeability is orders of magnitude higher, because so much more formation is exposed.

              Think of fractures as vertical sheets of paper. Drill a vertical well, you might hit one. Drill a deviated or horizontal well in the correct direction (i.e. perpendicular to the fracture orientation), you will hit many.

              This is where 70% of the production in the Middle East comes from, or, closer to home, production from the Ekofisk Field in the Norwegian sector, and I’ve never heard anyone claim that these are ‘unconventional’ fields.

              I’ve seen the claim that the OGA compared the Kimmeridge to the Bakken before and it is misleading.

              The claim comes from this study;

              https://www.ogauthority.co.uk/media/2773/bgs_decc_jurassicwealdshale_study_2014_main_report.pdf

              The study was trying to quantify the amount of oil that might be present in the Kimmeridge and used data from the Bakken (and other US shale provinces) to try and quantify this.

              It did not make any assumptions about how this would or could be produced.

              In any case, note the date of the report – it was before the HH Well results were known.

              So any statements that were made PRIOR to the HH Well about requiring frac’ing to produce oil from the Kimmeridge were correct with the information that was known AT THE TIME.

              The HH Well was a game changer, in that it proved that there were more extensive natural fracture systems in the Kimmeridge Limestone sequences than previously thought and that they could be produced at what are exceptionally high rates for a UK Onshore Well.

              The testing of the BB-1z and Angus wells in the next few days will confirm whether or not these natural fracture systems are widespread across the Weald Basin.

              The good thing about science is that facts remain facts, whether or not people choose to believe them.

            • Ok, Injuneer. So now, you are challenging the OGA and their analysis as well? If the effective permeability is so great, how about you give me the numbers for it? There is also a very wise saying: if something looks too good to be true, then it is. There are no magic bullets. The Kimmeridge is an unconventional, impermeable reservoir and all the talk about natural fractures doesn’t change this. There’s been over 50 wells drilled through the Kimmeridge before HH and none freely flowed oil from this strata. What is your explanation for this? That they were vertical wells? They still should have indicated flow. Also, how do you explain Mr Sanderson talking about back to back wells, horizontal drilling and stimulation? This is the Horse Hill man.

  4. I’d love to see this happen more often, councilors are pretty weak minded these days and only serve a small % of local voters. They are easily swayed by a vocal minority opposed to onshore O&G, probably out of fear.
    An overhaul of the planning system to remove them out of the equation is long overdue but won’t be forthcoming whilst we have a weak leader like May at the helm.
    Love the screenshot of the twitter account btw!

    • You’d think you guys would be ploughing in to offshore wind like all the sensible traders, Just shows you how little in the know some of you are!

  5. I would suggest it is worth clarifying the timings of SCC’s comments. The letter to the OGA is from August (so not at all “recent” as this article suggests) and thus precedes the meeting in September during which Alan Stones indicated amicable resolution of any pending concerns. Clearly OGA have completed their due diligence and concurred with Angus Energy’s view that all necessary planning permissions were in place. If that were not the case they would not have given their approval to the Field Development Plan.

    It is reassuring to see common sense and the true underlying facts prevail. Thanks to the professionalism of those involved, including Alan Stones for maintaining an objective view in the face of various campaings of smearing, misreporting and propaganda. I’m sure that Surrey taxpayers will be grateful that no more funds will be squandered on this baseless witch hunt initiated by poorly informed protestors and a rogue councillor.

  6. Obviously something is still going on behind the scenes. Extract from FOI reply from OGA reads “We are writing to advise you that, unfortunately, the time limit for responding to your request for information again needs to be extended.
    The FOIA obliges us to respond to requests promptly and in any case no later than 20 working days after receiving your request. However, when a “qualified” exemption is engaged by the information and an accompanying public interest test is necessary, the Act allows the time for response to be longer, in which case a full response must be provided within such time as is reasonable in all circumstances.
    In the case of your request, we have not yet reached a decision on where the balance of the public interest lies. The specific exemptions which are considered to be engaged by parts of your request are sections 22, 40(2) and 43(2) FOIA (information intended for future publication, Personal informaiton and commercial interests) and Regulations 12(5)(e) and 13(1) of the EIR (the confidentiality of
    commercial or industrial information and personal information). Other exemptions may also apply.
    Some of the information which you have requested may also constitute environmental information for the purposes of the EIRs. The EIRs also allow us 20 working days to respond to your request from the date of its receipt. However, it is
    occasionally necessary to extend the 20 working day limit for issuing a response. In this case, we must extend the time limit for responding because of the complexity and volume of the request (in accordance with regulation 7 (1) of the EIRs).
    We hope to let you have a response by 7 November 2017 but will aim to provide you with a final reply as soon as possible.”

    • Sounds like an overly complex/sizeable request which requires more time. Doesn’t suggest there’s anything else going on behind the scenes.

      Might as well post the full request and the full reply with personal/contact info redacted.

  7. liuseniuk-for someone posting information that is factually incorrect, it seems a bit strange for you to criticise someone who does know the facts for being unwilling to “listen to the other side”. When the “other side” starts posting some correct information I am sure you will observe a huge positive response.

  8. Try Giggling Horse Hill, liuseniuk. Even the BBC got a little bit right.

    As this is very much the focus of why the Weald is being looked at currently, it is quite important! We do know some poor science when we see it, so please don’t expect us to listen to that. I recognise that some will, but that is a different matter altogether.
    Not directed at you particularly, but the factual errors that are now appearing from the antis in increasing frequency, are noted. It is a slippery slope and you really should expect someone to challenge.

    • What about Horse Hill Martin Collyer? That it supposedly flowed oil without stimulation? Have you read Prof Smythe’s analysis proposing this well was drilled into a fault zone, which is much more permeable than otherwise? Have you seen reports from the neighbouring horse riding centre about clients and horses getting nose bleeds and about the horrible smells? Maybe you need to do some more digging into this instead of blindly believing what the oil companies tell you. They will be the ones having the last laugh, living the high life off the investors’ money, and folding when things go pear shape.

      • Hi liuseniuk,

        Yes, HH flowed without use of matrix acidisation or acid fracs.

        Only acid washes were used to clear the well bore of perforation debris, LCM and cement from the cementing of the liner.

        The well is seeing more effective permeability (see my post above on why natural fractures increase the effective permeability) because it intersected several natural fractures in the KL 1 – 4 sections. While faulting can help cause natural fracturing, in the many faults I have drilled through, I have never seen anything close to the effect that the Professor is trying to claim is why the HH produces so well. In fact, the great majority of the faults I have drilled though had no such effect. As for the few that did have a rubble zone associated with them, it was only a few meters in length – nothing like what the Professor is trying to claim.

        I have seen the hearsay reports and, quite frankly, they are not credible. I’ve never seen (or heard of) anyone on an acid wash on a well pad get a nose bleed, never mind anyone off site.

        • Injuneer, how do you know only acid washes were used? Is it according to the company statements (I have a difficult time trusting them) or can you verify otherwise?

          • Sure. They didn’t take 28% HCL to site (used on a matrix acid job) and they didn’t take any Frac equipment to site – so no acid frac’s.

            That leaves acid washes – which is what I’ve done in similar circumstances in various places I’ve worked in.

            While you may have difficulty in trusting statements by Angus, bear in mind that when an RNS is issued, what is said HAS to be factually correct. It may be very carefully worded to try and obfuscate it’s true meaning and put the best ‘spin’ possible on the statement, but they cannot tell porkies.

            Also, remember that the HSE / OGA have to approve the work program before hand and have to be notified of any deviation (planned or otherwise) from it.

            At the very least, the HSE / OGA will get sent a weekly summary of the Daily Drilling Report (DDR) (they will get sent a whole raft of other reports too) so they can monitor what is going on even without spot inspections. Actually, these days they probably get the DDR sent directly to them anyway.

            Given the microscope under which the O&G Industry is working these days, you can guarantee that the HSE / OGA will be paying very close attention to what Angus (and UKOG etc) are doing.

            • Even you admit the RNSs are a spin. Glad you agree. Acid can be mixed on site, correct? It doesn’t have to be brought diluted as 28% or 15%. Anyway, how do you know they didn’t take 28% acid or frac equipment to site? Were you there on site? Surely you were not part of the protest/watch camp?

            • Yes, like any Company on the FTSE 100 / 250 / AIM etc, they will try to present any statement in the best possible light. But like I said, it HAS to be factual. They cannot say they did X if they actually did Y.

              Let me clean up a misconception about the acid.

              15% HCL is how it’s actually supplied to the well location – not what the final formulation used is.

              When it’s used in the acid wash, it’s further diluted. It will be added to in a quantity to achieve the final required concentration (usually 5 – 10% HCL), plus there will be small quantities of some additional chemicals in the recipe (e.g. surfactant, demulsifier, inhibitor, iron sequestration).

              That’s why you sometimes see people claiming the Operator can’t do maths because the recipe adds up to more than 100% – those people are under the impression that 15% HCL is the final formulation when it’s not.

              So no, acid is not ‘mixed on site’ as such, except to dilute it further.

              Their approved chemical list (previously submitted to HSE/OGA & SCC) had 15% HCL listed, not 28%. They can’t take anything to site that is not an approved chemical.

              As for the Frac equipment, it’s an old adage “you’ll know it when you see it”.

              The video below is a bit cheesy, but it shows the type of Frac trucks that would be used here, rather than the bigger tractor / trailer units you normally see in these videos.

              In addition to these, there would be several trucks with assorted other equipment (pipework, monitoring, mobile lab, command & control center etc).

              Now, lets go into conspiracy theory territory and presume that a Frac of 999 cubic mts was done, so that it didn’t have to have prior permission. Note that if they did this, it would still show up on the DDR’s, which as I said previously, go to the HSE / OGA.

              So just in acid, this would need around 40 tote tanks (2 – 3 per truck) – which would have been seen being taken to and from the site.

              It would need around 20 x 60k lt water storage tanks – which would have been seen being taken to and from the site.

              It would need around 50 x 200k lt trucks of water – which would have been seen being taken onto site.

              The % flow back from an Acid Frac is usually very high, so let’s say 45 x 200k lt trucks to take away the flowback fluid – which would have been seen being taken from the site.

              Not only would there have been a step change in equipment, there would have been a step change in the number of Service Company personnel required – which presumably would have been seen going to and from the site every day (they wouldn’t stay on location).

              So, no, UKOG just did Acid Washes and not Matrix Acid or Acid Frac jobs.

              No, I wasn’t on location and I certainly wasn’t at the protest / watch camp. I have far better things to do than to protest against something that isn’t going to happen anyway.

            • Thanks very much for this detailed response and the video (love the music!) That is really useful. I gather from this that HCl comes in 15% or 28% concentration and the right one needs to be approved. I also see your argument about the truck traffic and personnel requirement. However, you use 999 cu meters as an example, where matrix acidising can be done at a much lower level per stage than that, correct ? I understand that the average volume of fluid used in US fracking operations is 2,500 cu meters per well, so this also has got to be much less than 999 cu meters per stage.

            • You are welcome!

              HCL as used in the oilfield normally comes in 15% or 28% concentration.

              In the UK, any chemical which is used Onshore first has to get approval from the EA (there may be other authorities too, I forget. Hewes62 may have more details). This is general approval and not specific to a particular well.

              As for the Well itself, the Operator has to submit a list of chemicals it plans to use. This is normally divided in two – those it will definitely use and those ‘contingency’ chemicals which may be used in certain circumstances. This list will be in the submissions to the HSE / OGA & the County Council and will be included in the approval process.

              So for a chemical to be used on the Well, there is actually a two stage approval process, and no, you cannot take a chemical that hasn’t been approved onto the location.

              It’s not really correct to say the Matrix Acid jobs are done in stages, but that’s me straying too far into Engineer semantics territory.

              Yes, Matrix Acid jobs use a lot less fluid than a Frac.

              Incidentally, virtually all the Wells producing in the Weald & Wessex basins have had matrix acid jobs done on them (I know of at least one that has been Frac’ed as well…), because they are producing from the Oolites, which have much higher matrix permeability than the Kimmeridge.

              However, matrix acid jobs wouldn’t work on the Kimmeridge, because the matrix permeability (as opposed to effective permeability) is too low. You simply wouldn’t get enough of a production increase to justify it.

              I used 999 cums as it comes under the current 1,000 cums per stage in UK legislation.

              Oh, in case you missed it;

              The volumes for a Frac definition actually come from a recommendation by the EU commission on the 22nd of January 2014, based on actual data from Shale Wells in Denmark, the Netherlands and Poland. Incidentally, the EU commission also refers to requiring ‘Golden Rules’ for the safe development of unconventional gas.

              http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014H0070&from=EN

              Those against Frac’ing often claim that Presse Hall would not be classified under this definition, because only 8,400cum were pumped. However, this ignores the fact that six stages were pumped, for an average of 1,400cum per stage (they actually varied from 39cum to over 2,000cum) and so would come under this legislation because of the “1,000 cum per stage” clause.

              Anyway, I’ve seen it quoted on here that 88% of US Frac jobs wouldn’t be covered by the current UK definition of a Frac and that the average Frac volume per Well in the US is 2,500cums.

              I don’t know where either of those statistics comes from – I haven’t been able to find any papers actually showing these figures.

              In any case, it’s wrong to use an average per Well, as this varies tremendously between the different Shale formations in the US. It’s a bit like saying the average passenger vehicle on UK roads is a Ford Fiesta, when it varies from a motorcycle to a double decker bus.

              Each shale is different and it comes down to a cost vs. economic benefit in terms of if the wells are drilled vertically, directionally or horizontally, how many stages are pumped per Well and what volume of fluid is used in each stage.

              What works in the Permian does not work in the Marcellus or Barnett for example.

              We don’t yet know what would work in the Bowland Shale, there simply hasn’t been enough testing done yet.

              In that respect, anyone who says that Shale gas definitely will / will not be economic in the UK is being premature – we just don’t currently have enough information.

              It might be economically worthwhile – like in some areas of the US. Or it might be like Poland, where various Companies spent a lot of money and it simply didn’t work, as they couldn’t get enough production from the Wells.

            • You say that “However, matrix acid jobs wouldn’t work on the Kimmeridge, because the matrix permeability (as opposed to effective permeability) is too low. You simply wouldn’t get enough of a production increase to justify it.” If matrix acid job doesn’t work, are you implying it will need to be a more intensive operation (such as acid frack or hydraulic fracking)? Whilst arguing agains one point, you inadvertently agree with another I made earlier.

              Same with the average volume per well – I agree with you that it makes absolutely no sense to speak of averages as every formation is different. Then why does the UK government give a very specific figure of 10,000 cu meters per well or 1,000 cu meters per stage? They should also take into account the variety of formations and various levels of fluid required.

              In addition, regarding yoru statement “We don’t yet know what would work in the Bowland Shale, there simply hasn’t been enough testing done yet.” The same can be said of the Kimmeridge. How can then the companies claim that it will be all conventional?

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