Live updates: Egdon’s Wressle planning inquiry Day 2

Wressle drilling 2014 Egdon

Drilling at Wressle in 2014

Live updates from the second day of the public inquiry into plans by Egdon Resources to produce oil from its site at Wressle in Lincolnshire. Updates from Day 1 here

Today’s session is expected to  hear from public opponents of Egdon’s proposals and a second witness for North Lincolnshire Council.

The company is appealing against refusals of planning permission by North Lincolnshire Council in January and July 2017. The company is seeking permission for 15 years of production at Lodge Farm, Clapp Gate, Appleby. The proposals include the use of two production techniques, proppant squeeze and acidisation.

The hearing, at Grange Farm Hobbies Centre, in Scunthorpe, is expected to last until 15 November 2017.

5pm inquiry adjourns

The hearing resumes tomorrow (9 November 2017) at 9.30am

4.55pm Public speaker: Dr Kate Simpson

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Dr Kate Simpson, 8 November 2017. Photo: DrillOrDrop

Dr Simpson, from Scunthorpe, says UK has a legally binding target to reduce emissions under the Climate Change Act and the Paris Agreement.

This week’s Bonn climate talks have called for more urgent action is needed to tackle emissions, Dr Simpson says.

Demand for oil and gas could reduce in the future, she says. The cost of extraction is likely to make oil and gas too expensive, compared with other forms of energy.

The proposal does not comply with the sustainable activity policy in the local plan, Dr Simpson says.

It does  not align with local, national or international policies and plans, she says.

4.50pm Egdon Resources case

Re-examination of Mark Abbott

Mr Abbott, managing director of Egdon Resources, confirms that North Lincolnshire Council never asked for a ground investigation report. Asked about drillers’ logs, he says they provide useful information and are a good reflection of the subsurface.

Mr Abbott confirms there is geotextile membrane between the stone layer and the impermeable membrane on the site. The level of stone in the loading areas of 300mm is fine. The two membranes increase the ability of the membrane to cope with large loads.

4.45pm Egdon Resources case

Questions by the inspector for Mark Abbott

The inspector, Keri Williams, asks why the second application left out radial drilling. Mr Abbott says the company would like the option to do radial drilling but it was the least likely of the options it had described in the proposals.This was to differentiate between the two applications.

3.30pm Egdon Resources case

Cross-examination of Mark Abbott

Site construction reports

Alan Evans, for North Lincolnshire Council, asks Mark Abbott, managing director of Egdon Resources, about oil and gas industry good practice guidance. One guidane document makes a ground investigation report compulsory.  Mr Evans says there is no report for Wressle. Mr Abbott says there was an investigation but no report. He says

“We took the knowledge and experience of our ground works engineer. That is the good practice we have taken.”

Mr Evans says the reason for a report is that there is then evidence that people can assess.

Mr Abbott agrees that it is a way of reviewing what was done.

Mr Evans puts it to Mr Abbott that good experience is not an adequate substitute because no one can go behind that or evaluate.  Mr Abbott agrees there are no benefits of a report.

Mr Abbott says there is document about the construction of the site and the experience of operating on the site without any issues or problems.

Mr Evans asks whether there is a readily accessible document of a ground report, or quality construction assurance. Mr Abbott says there is no ground report but there is documentation of the stones used and the installation of the liner.

Mr Evans  asks why these documents have not formed part of the rebuttal.

You are asking us to place our trust in an experienced civil engineer.

That and that the site has been operated and used for a period of time without issue, Mr Abbott says.  Mr Evans puts it to him:

That doesn’t tell us whether the site can be operated for a considerably longer period of time.

Not necessarily, says Mr Abbott.

Confidence in protections

Mr Evans asks how people are able to assess the quality of the site protections without documentation. Mr Abbott says people can draw comfort from the granting of the environmental permit and the results of monitoring of water in the Ella Beck.

Mr Evans says the site is closed and is not carrying out pollution-causing operations. Mr Abbott says there is no permission to do work on the site. Operations have been care and maintenance for nearly two years, since testing in 2015.

Mr Evans said Egdon had produced drillers’ logs about the Wressle site. These are not geologists’ logs. Mr Abbott agrees but says they can be interpreted by geologists. You could have less confidence in a drillers’ log than geologists’ log, Mr Evans suggest. You would have different information, Mr Abbott says.

Stone layer different from pollution plan

Egdon has told the inquiry it put a layer of 300mm of stone on top of the liner at the Wressle.

Mr Evans refers to the pollution accident management plan for the site. He says this document refers to 500mm of limestone and 150mm of top dressing.

“Why is it something different is set out in this document?”

That’s an error, Mr Abbott says.

Mr Evans asks:

“Was this error picked up by the Environment Agency?”

Mr Abbott says he doesn’t know. Mr Evans says:

“It’s an unfortunate error that states there is a layer almost double what is actually on the site. Was this document prepared in accordance with good practice?”

I can’t comment, Mr Abbott says. He says other sites have 650mm depth of cover, depending on the ground conditions.

Liner guidance recommends 600mm of cover

Mr Evans reviews the instructions for installing the site liner. This suggests a minimum 600mm of cover on top of the liner if there is frequent traffic.

Mr Evans there will be 1-3 vehicles a day at the Wressle site during production. The liner is designed for landfill, rather than oil and gas sites. We make the case that it is even more important for oil and gas sites that there should be 600mm of cover, he says. Mr Abbott confirms that there would be daily traffic on parts of the site.

Size of stones in liner covering

Mr Abbott told the hearing that 65% of the stone was 20mm. Mr Evans asks whether the remaining stone needs to meet any standard. Mr Abbott says there is no specific standard. It could be significantly bigger than 25mm, Mr Evans asks. It could be Mr Abbott agrees.

Mr Evans says the liner manufacturer recommends stones are 5-25mm diameter. Mr Abbott says if more than 50% is greater than 20mm diameter then a test may be needed.

Leakage testing

Mr Evans suggests that documentary evidence was not put before the planning committee in January 2017 that the liner had been tested for leaks.

Mr Abbott says he will check which documents were submitted to the committee for the first application.

Mr Evans says the integrity of the liner containment was untested at the date of a report written for Egdon in May 2016. Mr Abbott says this is true for physical tests but the site has been operated. Liners have to be exposed to be tested, Mr Abbott says.

Containment capacity

Mr Evans asks about the volume of spilt oil that could be contained on the site. He suggests there is a discrepancy between two documents submitted by Egdon. Mr Abbott says he will look into the issue.


Yesterday, geologist Susan Wagstaff, for the council, said the interceptor at Wressle should be capable of catching hydrocarbons that may come out of the well to prevent contamination of the Ella Beck.

Mr Evans asks whether the design of the interceptor has to be submitted to the Environment Agency under the permit conditions. Mr Abbott says he will look into this issue.

First committee

Mr Evans says British Steel did not withdraw its objection when the first application was discussed in January. The Environment Agency had not granted a permit at that point, or reached a draft decision. Mr Abbott agrees.

At that meeting, two members of the committee expressed lack of confidence in the Environment Agency, Mr Evans says. You can’t infer from that comment that any other members shared that view, Mr Evans asks. Mr Abbott accepts that this would be speculation. He says this is material issue, Mr Abbott adds.

3.20pm Break

The inquiry resumes at 3.30pm

3.08pm Egdon Resources case

Questions for Mark Abbott from the public

Kathryn McWhirter said Egdon was seeking to inject acid up to 6m. She asked whether it was cleaning the perforations or the pore spaces. Both, Mr Abbott replied. You have called it stimulation, Ms McWhirter said. Putting that acid into the wellbore and recovering that acid to clean up the pore spaces, Mr Abbott says.

Ms McWhirter asks Mr Abbott for details of the permeability of the Ashover Grit. She also asks about the components of the formation water. Mr Abbott says this is unknown because no water has been produced.

Ms McWhirter put it to Mr Abbott that the company had over-emphasised the benefit of the site. Mr Abbott says Egdon has never suggested Wressle would be a major employer. Upgrading the site would use local contractors. They are spending money when they are working. The longer-term benefits are business rates, taxation and balance of payments, Mr Abbott says.

These are relatively modest oil accumulations.

Ms McWhirter asks where wastewater would go. Mr Abbott says the company doesn’t know until the water has been sampled.

Ms McWhirter asked whether proppant squeeze had been used onshore in the UK. Mr Abbott says it hasn’t but similar techniques have and it is an appropriate process.

1.55pm Egdon Resources case

Evidence by Mark Abbott, managing director, Egdon Resources

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Mark Abbott, managing director of Egdon Resources, 8 November 2017. Photo: DrillOrDrop

Mr Abbott says the Wressle site was granted planning permission in March 2013. The well was drilled in 2014 to a total depth of 2,240m. It was tested in 2015. There were no complaints from the community, he says.

Site construction

He says the site was constructed by Richard Elliott, who had built 13 other sites with a bentomat liner. He has a huge amount of experience on constructing well sites, Mr Abbott says.

Mr Abbott says there was an assessment of the soil conditions, before site construction, taking into account issues such as site loading and likely traffic. There was no  need to change the design of the site, he says.

Mr Abbott tells the inquiry the liner was covered with a 300mm layer of surface stone 65% of which was 20mm diameter.

On the risk of pollution to Ella Beck from surface spills, he says was no impact on water quality from previous operations. There would be no discharge of fluids during oil production, he says. An Environment Agency-approved interceptor would ensure this would happen, he says.

Mr Abbott says the liner was tested in 2016 and it would be tested again in future. Concrete bonds would be installed in key areas, such as the tanker loading bay, to contain any spills of oil or chemicals.

Environmental management

I am responsible for any environmental or health and safety issues throughout the business, Mr Abbott says.

He says there are procedures, risk assessments, training documents, and a working environmental assessment document. The company also has pollution management and emergency plans. Environmental monitoring also has a plan, he says.

Every eventuality has a procedure in place to deal with matters quickly and responsibly, Mr Abbott says.

On a day-day basis, sites are operated by one-two people. There are high-level cut outs on storage tanks – electronically shut-down procedures that would shut down the site.

People pick up spills on site, he says, and deal with them.

Contamination risks

Any contaminants sit on the surface, Mr Abbott says. We would deal with it. The main risks is spillages on the surface. This would be at most risk in the well head area, which would be surrounded by a bund.

The surrounding drainage ditches would be improved if permission were granted, he says.

Environment Agency scrutiny

Mr Abbott says the site had 13 site visits during drilling and testing. The permit was an “issue and forget” process, he says. There is monitoring of air and surface water quality as part of the permit, he says.

If the EA had concerns about the groundwater monitoring scheme at Wressle, it would not have accepted it, Mr Abbott says.

Relative risk

Richard Glover, for Egdon, asks Mr Abbott about the relative risk of the exploration and production stages. Mr Abbott says the relative risks are very similar.

During production, it is of longer duration but there is a steady site, you understand the operation, you are managing operations, looking for spills, you have high level cut offs. In the case of Wressle, there will be permanent buds and tanker loading, enhancement of drainage ditches and water management. The risks are comparable.

During the exploration phase you are in a more unknown situation, where the risks are more related to sub-surface.

Well operations

Mr Abbott says the first application proposed two possible side wells drilled radially from the main bore but this was not included in the second application.

He says the environmental permit allows proppant squeeze. There are similarities to hydraulic fracturing but it is a smaller scale operation, Mr Abbott says.

Acidisation is included in the applications. This is routinely used in water wells, Mr Abbott says.

He says acidisation would be undertaken first. If that is not successful there would be one proppant squeeze. If neither worked, the company would drill a side-track.

Mr Abbott says the natural flow from the ashover grit had been impaired by the drilling operation. This is referred to as skin or formation damage. To mediate this and optimise flow from the well, the company will improve the permeabliity by acidisation.

“It is a conventional reservoir. It did flow, until the skin damage overcame it.”

The operations we are looking to undertake are purely to deal with that and ensure it will not occur in the future, Mr Abbott says. They would not be repeated.

“We have a single approval to undertake the proppant squeeze.

The acidisation is a one-off.”

Hydrofluoric acid

Mr Abbott says the total combined fluid would be 50cu metres. Hdrochloric acid deals with the carbonate particles. The hydrofluoric acid is required to deal with the quatz in the sandstone. The Environment Agency has reviewed the treatments and chemicals.


The Ashover Grit will produced oil with some associated gas. Over time, it may produce increasing quantities of produced water. Oil will be taken to the Immingham refinery. The gas volumes were uncertain. The company was looking to generate electricity from the gas for export to the grid.

At the end of production, the site would be restored to agricultural use.

Reason for refusal

Mr Abbott says he believes the committee at the first application did not trust the Environment Agency. Members did not accept the advice of the planning officers or the Environment Agency.

No questions were raised by committee members at the second refusal meeting of three senior members of the EA, he says.

No substantive planning reasons for refusal were put before the committee at either meeting, Mr Abbott says. The committee did not follow its own good practice.

Benefit of oil production

Mr Abbott says Wressle oil would reduce UK imports, not add to the nation’s use. Domestically-produced hydrocarbons were needed as the country transitioned to a low carbon economy. Locally, it could raise spending in the economy. Nationally, it would generate tax receipts.


Mr Abbott says the Wressle did not intersect a fault. The operations were a mile underground and that is where the faults needed to be considered. The fault was to the north and east of the well in the Ashover Grit.

1.50pm Public speaker: Melanie Dale

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Melanie Dale, 8 November 2017. Photo: DrillOrDrop

Ms Dale says she was brought up on Broughton, near Egdon’s Wressle site. She says she attended a meeting organised by Egdon. She feels strongly misled by the presentation. The company said there would be no risk to the environment and there was no prominent information about acid, she says.

Egdon has not offered a bond or given details of how it would compensate the community, Ms Gayle says.

If hydrofluoric acid is used frequently, I can’t understand why the Environment Agency has no information on its use, she says.

1.45pm Public statement by Linda Bett

Mrs Bett, of Broughton, says in a statement she has misgivings about Egdon’s plans. She is concerned about contamination of the aquifer and the impact of a geological fault. She says there are many unanswered questions about the development. She asks whether there has been an environmental impact assessment. She says she doesn’t believe hydrofluoric acid has been used in similar circumstances.

12.45pm Break

The inquiry resumes at 1.45pm

12.25pm North Lincolnshire Council case

Re-examination of Katie Atkinson

Letter from Egdon Resources to N Lincs Council

Alan Evan for North Lincolnshire Council, refers to a letter from Egdon sent after the second refusal in July 2017. This suggests the council did not follow its own good practice at the second committee meeting.

Mrs Atkinson says little weight should be given to this suggestion. The appeal had overtaken the committee procedure. There is still a shortage of information on some issues, she says.

The letter appears to complain that there was no verbal report from the planning officer at the committee meeting. Mrs Atkinson says a written report would replace any verbal presentation. The written report included updated issues, including the withdrawal of objection by British Steel.

The letter also suggests there was enough discussion about the implications of not accepting the planning officer’s recommendation to approve. Mrs Atkinson says the planning committee would be aware of the implications.

Lack of trust in the Environment Agency

Mr Evans asks if there is any evidence that the committee was influenced to refuse the application by a feeling by two members of a lack of trust in the Environment Agency. Mrs Atkinson says there is no evidence and the inquiry should not speculate on this issue.

Mr Evans asks about Egdon’s offer to meet councillors to discuss the application. He puts it to Mrs Atkinson that it is hard for councillors to meet an applicant before a decision is made. She says there is justification for not meeting.

He asks what weight should be attributed to concerns expressed now that had not been raised earlier. Mrs Atkinson says greater weight should be given to issues raised at the appeal, rather than earlier at the committee.

Planning policy

Mr Evans asks about North Lincolnshire’s local plan policy M23, which deals with production boreholes. Mrs Atkinson says a proposal would breach this policy if mitigation failed to prevent unacceptable impacts.

Mrs Atkinson says local policy DS13 deals with groundwater protection, rather than just land drainage, as Egdon suggested. Groundwater protection is an important part of the policy and it deals with pollution, she says.

Socio-economic benefits

Mrs Atkinson confirms she has not seen any quantification of economic benefits from Egdon. She confirms she has considered local and national benefits in her planning balance.

12.15pm North Lincolnshire Council case

Questions from the inspector to Katie Atkinson

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Role of other regulators

The inspector, Keri Williams, asks about the guidance on the roles of different regulators. Mrs Atkinson says issues dealt with by the Environment Agency should still be considered by the mineral planning authority.

Planning practice guidance says some issues by other regulators would have interest to mineral planning authorities, for example water pollution issues, Mrs Atkinson says. Mineral planning authorities should be satisfied that issues should be adequately addressed by the other regulator, she says.

Mr Williams asks

“Are we in a position where the authority is not satisfied about the role of the Environment Agency?”

“I would say so”, Mrs Atkinson replies.

She confirms that the council’s case on harm resulting from the application was related to evidence from Susan Wagstaff, the geology witness who gave evidence yesterday. DrillOrDrop report

Precautionary princple

Mr Williams asks about the precautionary principle. Mrs Atkinson says the planning authority must ensure there is no unacceptable impact. Where the council can’t be sure the application should be refused. This is compatible with the precautionary principle.

11.20am North Lincolnshire Council case

Cross-examination of Katie Atkinson, planning consultant

Planning committee procedure

Richard Glover, for Egdon Resources, asks Mrs Atkinson about the process of refusing planning permission. He puts it to Mrs Atkinson that the councillors on the planning committee did not follow good practice guidance in refusing permission.

Mrs Atkinson says the planning officer presented his views to the planning committee and this met the good practice guidance. She says she was not at the committee meeting. The minutes report there was a discussion of the report.

Mr Glover  questions whether the implications of overruling the planning officer recommendation were discussed at the committee meeting. Mrs Atkinson says a reason for refusal were given.

Trust in the Environment Agency

Mr Glover puts it to Mrs Atkinson that the first application was refused because the committee did not trust the Environment Agency.

Mrs Atkinson said this view was expressed by some members but it was not known whether the whole committee was influenced by this to refuse. It was not a valid reason for refusal, she says. Mrs Atkinson says a planning officer said this was not a reason for refusal and another reason was given. Mr Glover says it was an unlawful decision. Mrs Atkinson says she is not agreeing that this happened.

Information gaps and offer of meeting

Mr Glover says Egdon offered to meet councillors, as it had with the British Steel and Lincolnshire Wildlife Trust. Those meetings resulted in a withdrawal of objections. Councillors did not take up a similar offer.

He puts it to Mrs Atkinson says there was no outstanding information requested by the councillor or officers at the time the decisions were made.  There were no gaps, he says. Mrs Atkinson says members raised concerns about specific issues, which is why the application was refused. They are entitled to do so, Mrs Atkinson says.

Mr Glover says you can’t make a decision saying there has been a breach in policy if there were no gaps in information. Mrs Atkinson says frequently applications are turned down for lack of information.

Mr Glover says it is not reasonable to refuse permission on those grounds. Mrs Atkinson says the council did what it did. Mr Glover says a reasonable planning authority would defer decision. That is one option, Mrs Atkinson says.

Mr Glover says the applications complied with all other policies. He says there is no link between a lack of information and unacceptable harm to local people, communities or economy. Mrs Atkinson says if there is a lack of information there can be no certainty that there will not be unacceptable harm. She says the council believes there could be substantial harm through the lack of information.

Mr Glover puts it to her that there is no evidence of unacceptable harm. Mrs Atkinson says at the time of the decision there was evidence that there could be harm. That’s not what was in the wording for refusal, Mr Glover says.

With the evidence of the appeal, there is no certainty it would have an unacceptable impact on local people, communities and the economy, Mr Glover says. Mrs Atkinson says Ms Wagstaff was taking the precautionary principle, as did the council committee. That is not supported anywhere in guidance, Mr Glover says. Mrs Atkinson says it is an approach open to the council and more information can be submitted through the appeal process.

Reasons for refusal

Mr Glover says the council incorrectly stated that planning policies were breached by the proposal. He says policy M23 on production boreholes does not use the words “unacceptable impact”. Mrs Atkinson says this is implied in the policy.

He says policy DS13, which is referred to in the refusal, deals with land drainage. We don’t have an issue with controlling the levels of water in land drainage. Mrs Atkinson says members had a concern with the site membrane. That is not relevant to a breach of DS13, he says. It also deals with groundwater protection, Mrs Atkinson says.

Another policy, DS15, deals with water resources, Mr Glover says.  The policy seeks to reduce impacts to an acceptable level. This is a job for the Environment Agency, he says. Mrs Atkinson says councillors were entitled to come to a different conclusion than the Environment Agency.

The final policy mentioned in the refusal, CS18, which deals with sustainable resource use and climate change. Mr Glover puts it to Mrs Atkinson that there is no breach of any of the elements in that policy. Mrs Atkinson says element 10 was of most concern to the council because of lack of information.

Planning balance

Mr Glover says a planning balance takes account of benefits and impacts of a development and the comments from statutory agencies. He puts it to Mrs Atkinson that great weight should be given to the benefit of extracting minerals. These should include contribution to local business rates,capital investment in the local economy. Mrs Atkinson says she is not aware that Egdon submitted any evidence to the council on social-economic benefits.

Mr Glover says there is a national benefit of revenue and security of supply of hydrocarbons should also be considered.

None of these benefits were weighed up by councillors, Mr Glover says. Mrs Atkinson says this was included in the planning officer’s report. She says the reason for refusal talks about the impact on residents and the local economy.

There is no evidence that the councillors identified the impact on the local economy, Mr Glover says. Mrs Atkinson says British Steel objected to the first application because of concerns about its borehole. Members said they had no information to resolve their concerns about the second application, Mrs Atkinson says.

Mr Glover asks where Mrs Atkinson has assessed the economic benefit. Mrs Atkinson says she has given great weight to mineral extraction.

11am Break

The inquiry resumes at 11.20am

10.47am North Lincolnshire Council case

Second witness: Katie Atkinson, planning consultant

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Katie Atkinson, 8 November 2017. Photo: DrillOrDrop

Policy and guidance

Mrs Atkinson says the reasons for refusing Egdon’s applications were justified by local planning policies and these should be given substantial weight in the planning balance.

She says if there is not enough evidence to satisfy the policies then it is enough to conclude that they have been breached.

Mrs Atkinson says mineral planning authorities should assume that the regulatory regime will operate correctly but they do not have to agree with other regulators.

The planning authority should look at these issues, she says. In my view the MPA is entitled to come to a different decision from the Environment Agency. They need to take advice but they need to be satisfied with the advice.

The council said Egdon’s proposals were in contravention of the North Lincolnshire Plan, Mrs Atkinson says. There are no policies in the NPPF or local plan which suggest these appeals should be allowed.

“The potential adverse risk to groundwater from pollution cannot be satisfactorily assessed by the limited information submitted with the application and so it is contrary to the development plan.

There is no valid planning reason for all three appeals to be allowed. They should all be dismissed.”

10.38am Cross-examination of Kathryn McWhirter

Richard Glover, for Egdon Resources, put it to Ms McWhirter that the rock at Wressle was highly permeable. Ms Mcwhirter asks Egdon to give details of the permeablity. The operation proposes to stimulate 5-7m. Why use hydrofluoric acid, she asks.

Mr Glover puts it to Ms McWhirter that it is incorrect to say that hydrofluoric acid would be used for the first time at Wressle. Ms McWhirter says the Environment Agency said in a response to a Freedom of Information request that had hydrofluoric acid had not been used in the oil and gas industry. She also says the water industry would never use hydrofluoric acid.

Mr Glover puts it to Ms McWhirter that the EA has issued a permit. Ms McWhirter responds that the EA may not have considered all the evidence available.

Mr Glover says there has been full disclosure of all chemicals. Ms McWhirter says there are several propriertory mixes do not give a chemical name.

10.10am Public speaker: Kathryn McWhirter

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Kathryn McWhirter, 8 November 2017. Photo: DrillOrDrop

Ms McWhirter says she is from southern England where communities are facing oil extraction from tight limestone rocks. She says planning decisions are being made based on a wrong definition of conventional oil and gas operations.

If you are drilling a conventional well, it will be into permeable rocks, draining oil or gas from a large area, she says. Unconventional oil and gas wells are drilled into impermeable rocks which require stimulation to flow.

Since 2014, planning guidance describes conventional as anything drilled into limestone or sandstone. But this is not accurate, she says. Micrite limestone is very low permeability. Oil companies describe them as conventional when they are wearing their PR hats, Ms McWhirter says.

She says she spoke to the person who wrote the guidance, who said this section was inserted by the Department of Energy and Climate Change. No one will take responsibility for this issues, she says. The British Geological Survey admits the definition is incorrect. The Environment Agency has no definition, she says.

An oil CEO in Surrey says “back-back” wells will be needed in the south because the geology is tight, or low permeabliity, Ms McWhirter adds. The Ashover Grit at Egdon’s site is also low permeability.

“What is the permeability of this formation, please, Egdon Resources, expressed in microDarcies?

“This well is extreme”.

“Hydrofluoric acid is perhaps the most dangerous chemical on earth”

Ms McWhirter says:

Egdon seek to minimise the risk of acidising with hydrofluoric acid – perhaps the most dangerous chemical on earth. And Egdon’s risk assessment falls short in so many other ways. The application fails to address toxic emissions from the flare, and plays down the probable toxicity of the waste water. It ignores the potential for contamination via the well bore. It makes spurious comparisons with the use of acids in water drilling. There have been almost no studies on the use of hydrofluoric acid in the oil industry. So how can it be said with such certainty that the risk is low?

Ms McWhirter criticises the Environment Agency for failing in its duty for describing the proposed operation as “de minimis” or not worth a thought.

She says hydrofluoric acid – to be used to stimulate the well – is the most corrosive chemicals on earth. She quotes from the US steelworkers union:

“If released into the atmosphere, hydrofluoric acid rapidly forms dense vapor clouds that hover near land and can travel great distances. Hydrofluoric can cause deep, severe burns and damage the eyes, skin, nose, throat and respiratory system”

She asks how prepared are the emergency services. Firefighters would need special breathing apparatus and full protective clothing and equipment.

Proprietary mix contents not fully disclosed

Ms McWhirter says the contents of the proprietary mix that will react down the well is called Protekt 22 are not fully disclosed. Protekt 22 was not mentioned n the first wellbore fluids list.

Ms McWhirter says:

Egdon’s reassurances that their liquid waste will be innocuous are complacent to say the least. In addition to any remaining acid, returning fluid will contain other injected chemicals and reaction chemicals, as well as substances released from the formation: salts of heavy metals, potentially Naturally Occurring Radioactive Materials.

Ms McWhirter says Egdon may use more than one acid treatment more than once, including what she calls an acid frack.

She also raises risks from deteriorating cement or steel casing:

This council should consider demanding a bond from Egdon Resources and their associates, so that the council and surrounding population will not be liable for clean-up long after Egdon is dead and gone.

Acidising – regulation “shockingly weak”

She adds:

Acidising uses far higher concentrations of chemicals than fracking, yet it is barely regulated and the Environment Agency has until now paid it scant regard.

The Environment Agency has no chemical data, done no testing or monitoring of flowback, holds no information on water abstraction or reinjection. It admits that acidising an oil well with hydrofluoric acid is a new process.

“I would contend that while the UK regulatory system for fracking is far from strong and stable, regulation of acidising is shockingly weak and wobbly.

“I contend that this council could not, and you the planning inspector, cannot and should not rely on the competence in this matter of the Environment Agency.”

MsWhirter says it is untrue to say acidising is akin to rehabilitation of public water supply and commercial water wells. Water engineers say they use acidising in water wells extremely rarely and only to clean the well bore. They use only hydrochloric acid and never at pressure.

She concludes:

I believe North Lincolnshire County Council made a very wise decision when they refused this planning application. On the grounds of water safety, as well as possible pollution to the air that Lincolnshire inhabitants breathe, there are compelling reasons why this application should not be allowed to go ahead.

10am Break

The inspector, Kit Williams, calls a break to allow the Egdon Resources team to read documents submitted by the public.

9.52am Cross-examination of Martin Foster

Richard Glover, for Egdon Resources, says British Steel has withdrawn its objection to the application. Mr Foster replies that British Steel has no objection to him speaking at the inquiry. The company has its own reason for withdrawing its objection.

Mr Glover says there’s been no movement below the well site for 350 million years. Mr Foster says the last recorded earthquake before a recent one at Market Raisin was in 1882.

Mr Glover put it to Mr Foster that the Environment Agency was satisfied that there would be no problem with seismicity. Mr Foster said he wasn’t aware that the Environment Agency was an expert on this issue. “Let’s hope they’re not wrong”, he says.

9.34am Public speaker: Martin Foster

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Martin Foster, Unite Convener at British Steel at Scunthorpe, 8 November 2017. Photo: DrillOrDrop

Mr Foster, Unite convener at British Steel at Scunthorpe, says he is also speaking on behalf of the GMB and Community unions.

He says British Steel takes water from a borehole near the proposed production site. The water is used in the plant’s enclosed cooling system and boilers. The purity of the water is crucial. Any contamination would cause a lost of production, costing thousands or millions of pounds.

Mr Foster says he could not accept that there would be no risk of contamination. He said monitoring would not prevent contamination.

He says he was also concerned about seismic activity. Lincolnshire is a high-earthquake area he says. There is also plenty of evidence that pumping of fluids underground led to earthquakes.

Egdon has already drilled through a major fault at the Wressle site, Mr Foster says. The fault also runs through a number of iron stone mines, which supply water to British Steel. A seismic event could cause a collapse in the mine. Collapses have happened in the past. British Steel could lose water from the borehole and the mines at the same time if there were a seismic event, which would be catastrophic, Mr Foster says.

Egdon says it will monitor of seismic activity. But Mr Foster says this is after the event. Operations would stop after seismic activity is detected. But this would not stop an earthquake happening, he says.

Scunthorpe steelworks employs 3,500 people and and other 1,500 contractors. It is the town’s second largest employer. The steel is industry is still vulnerable. The Scunthorpe plant would not recover from a  major problem caused by seismic activity.

Mr Foster says he strongly objects to Egdon’s plans because it poses a significant risk to the steel works and the town.

9.30am Inquiry Day 2 opens

This report has been made possible by donations from individual DrillOrDrop readers

68 replies »

  1. The last Earthquake was in Market Raisin 1882, Suddenly Unite are Seismologists? Unite were defending the rights of workers stealing bog rolls off the last construction site I worked on. How will British Steel function when the lorries and trains that carry that steel run out of Diesel? Or the fact that fuel prices are so high, transporters of that steel have to put up costs, throwing the onus on cheaper steel from over seas?
    I wonder if he drives a Jag or Mercedes like the Unite workers on our site?

  2. KatT-no, it is not democracy. These people had the opportunity at the previous meetings to give their input. This is an Inquiry into whether those meetings made a correct decision. It is quite easy to see from some of the comments that some are simply wanting to have another go that they missed originally, or feel they can do better this time.
    Whilst I can see the temptation, I suspect the person in charge of the Inquiry will largely discount such input. My concern is not about the democratic issue here, it is about the purpose of the Inquiry, which surely is to decide whether correct decisions were made? Unless that is the focus, it becomes a drawn out and needlessly costly business, which is not in the interests of either party.

  3. Can anybody figure out what Mr. Abbot means when he says there are “electronically shut-down procedures that would shut down the site.” [edited by moderator]

  4. Kathryn must be trying to get her old job back at the Indy with all this effort. All a waste of time unfortunately. Hope she enjoys her trip back down south using fossil fuels 🙂

  5. FUMF

    Probably similar to those used for marine wind turbines, and other sites, where automatic shut down is built in. Sensors, relays, valves come to mind, but maybe more sophisticated than that.
    I have several more basic systems, in my toilet cisterns.

    • What about manual shut down – is it as simple as pressing a button? Could Fracking sites be shut down remotely[edited by moderator]?

      • FUMF
        He refers to operations being shut down, which they can do.
        If drilling, you can stop drilling.
        If producing, you just shut in the well if it flows naturally, or if pumping it out, stop the pump.
        It can be as simple as pushing a button.
        The concerns raised are immaterial as to whether a Well has been fracked or not.
        The frac card is being played here to scare people.
        Proppamt squeeze and acidisation are common offshore and onshore elsewhere in the world.
        Hoton has a proppant catcher, and it has been in production for many a year ( as an example ), and scale is not squeezed out by distilled water, but some interesting chemicals.

        I do wonder if people think imported oil is extracted from some sort of trouble free well, where, once drilled it flows( gushes ) out without any form of Well stimulation activity. No locals are affected, Well pads are perfect, everyone is keen on renewable energy, corruption is absent and the Health Service is free.

        Or maybe out of sight is out of mind, and no worries, other than the price.

  6. Hmm Mr Evans is now really having to clutch at straws, the majority of this information doesn’t actually have anything to do with this appeal, the whole thing is to understand if the councillors were wrong in granting refusal and they were. The council is acting as if this is a first time planning meeting. If the councillors had acted correctly they could have asked any of these questions during a 2nd hearing but because they refused the application outright this opportunity wasn’t available. Take for example the TMP @ Holmwood, Europa have been given time to answer the questions. It is simply bad practice by the council and they know it, they are simply pretending they have more arguments than they do. All at the tax payers expense.

  7. Most of the protestors seem to be guided by emotion philosophy or ignorance. I am afraid none of those sentiments or deficiencies will sway an inquiry . You have to submit fact to an inquiry, not ‘I have read’, or I have been told that etc . As for democracy, well half a dozen people holding placards is not a representation of national democracy in a nation of 65,000,000. It represents a view point of those holding the placards. If they wish to claim it is democratic then they would have to hold a national vote on the subject

    • Vern, as you can see by the vast majority of local residents accepting money from Cuadrilla on their fracking site there is no where near any majority for banning any form of onshore O&G. If the government came out with a statement saying household bills would fall by £100 I bets over 90% would sign up to promote onshore O&G. Yes renewables will be a big part of the future but they need a lot of tweaking and will never provide all the answers. Oil will always be required.
      These ultra lefties are a tiny minority but they have a huge voice courtesy of social media and their new best friend Google for reference.
      No wonder A&E is full of hypochondriacs.

  8. GBK-having made a rare visit to the NHS last week I arrived to be told my appointment with my consultant had been cancelled, together with 5 others, but the letters had not been sent! Today, I see the head of the NHS calling for more money.

    It is indeed a funny old world.

    A few weeks ago my hard drive gave up the ghost so I had to reload everything on my new hard drive, including my security system. All as simple as can be, yet the NHS find it impossible?

    Am I old fashioned in believing if you are head of ANY business you look silly asking for more finances when you are not managing those you already have, and supporting your own employees?

    However, we are all happy, it seems! Perhaps, after Brexit some will realise it is a tough world out there and sometimes you just need to get things done. But, don’t hold your breath. We can always go round and round.

  9. Well, what a sad litany of non compliance with Egdon’s contract and the regulations that define good good practice.

    This had better be done in easy chunks, there is too much to say all in one post, so:

    It is worth repeating what i said yesterday at the day one inquiry, just to clarify the situation today.

    Mr. Mark Abbott’s apparent failure to provide any sort of compulsory site investigation report other than a vague promise that there was one but there is no report only serves to illustrate the same weak and contemptuous attitude of all the other conditions that they failed to produce, or apparently even consider necessary. Mr Abbott did say there was a civil engineer who looked at it, but there is no record of that or who looked at the borehole logs and how any of the conclusions and apparent recommendations to contravene the regulation compulsory orders was not provided. What are we to make of that?

    Have you done your homework Mark? Yes. Can i see it? No. Why not? I didn’t write it down. Then how do i know that you did it then? You will just have to take my word for it, i showed it to someone and they said it was OK. Who was that? There is no record of it.

    Do we believe that? No, of course not.

    So we have no site investigation report, and no evidence that any such thing was ever done or where it was or what it revealed or what was derived in engineering terms from it. That is a failure to carry out a compulsory engineering requirement without which permission cannot be granted.

    Like i said yesterday, i don’t recall any any hydrocarbon exploration or production site that did not have at least one site investigation report.

    Paper trails are essential, otherwise court hearings will wipe the floor with the defendant, as should happen here.

    • Then we have the stone layer over the membrane:

      “I can’t comment, Mr Abbott says. He says other sites have 650mm depth of cover, depending on the ground conditions.

      Liner guidance recommends 600mm of cover
      Mr Evans reviews the instructions for installing the site liner. This suggests a minimum 600mm of cover on top of the liner if there is frequent traffic.

      Mr Evans there will be 1-3 vehicles a day at the Wressle site during production. The liner is designed for landfill, rather than oil and gas sites. We make the case that it is even more important for oil and gas sites that there should be 600mm of cover, he says. Mr Abbott confirms that there would be daily traffic on parts of the site.”

      “Size of stones in liner covering
      Mr Abbott told the hearing that 65% of the stone was 20mm. Mr Evans asks whether the remaining stone needs to meet any standard. Mr Abbott says there is no specific standard. It could be significantly bigger than 25mm, Mr Evans asks. It could be Mr Abbott agrees.

      Mr Evans says the liner manufacturer recommends stones are 5-25mm diameter. Mr Abbott says if more than 50% is greater than 20mm diameter then a test may be needed.”

      I would say there is no may about it, the actual 300mm thickness of the wrong type of stone is a contravention and is grounds for refusal of permission.

      The lack of the correct 600mm thick rounded DTP3 stone layer that was also required as an engineering regulation for a site which will have turning and tearing movements of HGV and LHV traffic is also a matter of non compliance. 300mm will not withstand that sort of ripping and tearing motion and the bow wave effect will displace and rut the surface and damage the membrane, the flints will rip the membrane to shreds.

      The minimum allowed was 500mm and a 150mm sand layer, that being the membrane protection layer, IE 650mm in all. it is essential that the stone is rounded and the correct diameter is average 22mm as i said yesterday, flint is sharp and will split and cut the membrane and vehicle tyres, the stones on site were 60mm or more, that is too large, large stones cannot be compacted and will project into the membrane and also up onto the surface, causing ruts. if 650mm of stone was used elsewhwere, then why not here?

      This thickness and material requirement would all have been revealed by the site investigation, but of course that is not available, or is it and they dont want to produce it? Again, non compliance and refusal of permission is the only result that can be made.

      [Figure corrected at poster’s request]

      • Next water and leakage.

        Neither the membrane integration nor the site itself had been tested for leaks.

        “Mr Evans suggests that documentary evidence was not put before the planning committee in January 2017 that the liner had been tested for leaks.
        Mr Abbott says he will check which documents were submitted to the committee for the first application.
        Mr Evans says the integrity of the liner containment was untested at the date of a report written for Egdon in May 2016. Mr Abbott says this is true for physical tests but the site has been operated. Liners have to be exposed to be tested, Mr Abbott says.”

        For the membrane to be tested now will mean removing all the stone material, removing the stone material will compromise the membrane, the sharp flints will have compromised the membrane anyway. The membrane will have to be replaced and all the stone, hopefully the correct grade of stone and the correct thickness.

        How can Egdon hold their heads up over this? It is an utter disaster, it proves that the entire operation is nothing but gross incompetence.

        • next Containment capacity

          “Mr Evans asks about the volume of spilt oil that could be contained on the site. He suggests there is a discrepancy between two documents submitted by Egdon. Mr Abbott says he will look into the issue.”

          “Yesterday, geologist Susan Wagstaff, for the council, said the interceptor at Wressle should be capable of catching hydrocarbons that may come out of the well to prevent contamination of the Ella Beck.”

          In fact a full retention interceptor is required, the normal interceptors are bypass designs to allow surface water to outflow whilst retaining the first flush, they need to be designed specifically for the job, just any old interceptor will not do the job.

          “Mr Evans asks whether the design of the interceptor has to be submitted to the Environment Agency under the permit conditions. Mr Abbott says he will look into this issue.”

          You cannot place any old oil interceptor without calculations and a specification, how can that not be a design requirement submitted to the EA?

          Contamination risks

          “Any contaminants sit on the surface, Mr Abbott says. We would deal with it. The main risks is spillages on the surface. This would be at most risk in the well head area, which would be surrounded by a bund.

          The surrounding drainage ditches would be improved if permission were granted, he says.”

          Not true, the surface is not impermeable, any contamination will soak down to the membrane, that is why the membrane is there, the surface material will soak it up and leak over a period of time, that depends upon the severity of the contamination, with severe leaks the entire top of the surface material may have to be removed and treated as contaminated waste.

          The surrounding interception ditches are similarly a problem, since they have to be impermeable too and any large rainfall must be similarly contained and the water treated as contaminated waste water. How can you post improve the drainage ditches? The membrane is all ready compromised with sharp flints, it will leak like a sieve. It does not make sense.

      • Phil, I can’t remember the planning committee mentioning any inadequacy with the lining, membrane, shingle surface or interceptor. I seem to remember complaints about the EA or too much information being supplied to cope with. They can’t change the reasons for refusal during the appeal, it just makes them look a laughing stock.

        • Its in the text terri,

          “Leakage testing
          Mr Evans suggests that documentary evidence was not put before the planning committee in January 2017 that the liner had been tested for leaks.

          Mr Abbott says he will check which documents were submitted to the committee for the first application.

          Mr Evans says the integrity of the liner containment was untested at the date of a report written for Egdon in May 2016. Mr Abbott says this is true for physical tests but the site has been operated. Liners have to be exposed to be tested, Mr Abbott says.”

          So the membrane is untested, or that details are not available for the EA or provided to the council.

          Also, the use of flint as a stone material which shatters into knife like edges and the stone being too large (above 50mm) as mentioned by Susan Wagstaff yesterday compromises the membrane as HGV and LHV vehicular movements require a minimum 600mm thickness of stone and the provided 300mm of too large a stone and containing flint also exacerbates the danger of membrane perforation.

          The membrane also needs to be lapped and sealed with proprietary methods, without that the membrane is untested and hence unreliable, it has to be exposed to be tested as Mr Abbott said, and that would mean stripping off the existing 300mm of stone and presumably the sand layer too, if there is one of course. also if the membrane has not been viewed or confirmed by anyone from any regulatory body, how do we know it is complete to the ditch locations? A can of worms i am afraid.

          • Thanks for your reply Phil, but I obviously didn’t make my statement clear.
            I know what was meant to have been said today. I am referring to the planning meetings in January and July. The planning officer and the planning committee made no mention of any inadequacy with the lining, membrane, shingle surface or interceptor. I seem to remember complaints about the EA or too much information being supplied to cope with. They can’t change the reasons for refusal during the appeal, as I said, it just makes them look a laughing stock.

            • Hi Terri, i suspect that the council is treating the appeal as a clarification of details that were required as part of the original application, but not forthcoming from Egdon originally? Perhaps that lack of required information triggered the original refusal? I am just surmising about that however, I don’t know that.
              Perhaps you have more knowledge of that?
              There is presumably a list of required information for the original and subsequent applications, and what was, and what was not submitted?

            • I can’t reply to your 10.10pm post Phil, without putting it in the wrong place, so I hope you notice my opinion of the situation:
              Thanks again for your reply. From what I am aware, the planning committee had very little debate or consultation about the actual planning application. The focus of attention was very much with regard to the vast number of complaints from members of the public, FoE, anti-fracking groups etc.
              Even though the planning officer recommended approval of the planning application, as you know, the decision to refuse meant an appeal would be handed back to the planning officer to defend. So the planning officer and legal team have had to come up with a plan. It appears they have chosen to discredit the Environment Agency’s findings, and attempt to prove an unacceptable risk of pollution to ground and surface waters. But this will put the planning inspector in a very difficult position, where if he accepts this defence has grounds, he will have to put a report together criticizing the Environment Agency. The possible consequences are far reaching. Any application refused by the EA can be challenged because they have been found to be incompetent.
              Where does this lead to?

            • Yes, it’s a weird situation Terri, perhaps it is a result of the financially and organisationally crippled state of the EA?
              They are so hard put to deal with complex proposals by the ohandgee industry, they do not have the staff, or the finance or the freedom to act in the way they were supposed to be able to do.
              This government obviously did not want an organisation with the resources and the legal teeth to be able to deal with the flood of applications.
              That enabled almost anything to get rubber stamped through in spite of the serious failings and failures to comply with regulations.
              The result is that, as you said, they complained that they could not deal with all the information that poured into their in tray.
              It’s a political coup in effect, and the tax payer and the local residents are the ones who are and will suffer as a result of that crippling.
              E can have the most powerful regulations on the planet (we have not) but if you cripple the regulators, it all goes to he’ll.
              What we have is inadequate regulations that the operators run rings around, and a crippled regulator who cannot possibly deal with the complexities of the applications.
              Result? Carte Blanche for the ohandgee corporations, which was the intention of crippling the system in the first place.

              • There have been some references to a councillor saying they had too information to cope with. DrillOrDrop reported what the councillor said as follows:

                Cllr Grant says the application is much better this time. But he says there’s not enough information to be confident that this is the right thing to do.
                He says there’s a vast amount of information but this doesn’t help him.
                “It clouds my mind. I will be proposing to refuse”

                (from the “second refusal” meeting

                The councillor appears to be complaining that there is not enough relevant information to convince him , and the “vast amount of information” is not helpful.

            • That may be how it appears to you Paul. It certainly isn’t how it appears to me!
              To be honest, I wasn’t referring to the way it was quoted on drillordrop, but from someone who heard him say it in person.

            • Hi terri you said “I seem to remember complaints about the EA or too much information being supplied to cope with.” Personally I don’t recall that from the original Drill or Drop report, but Paul has reminded us of it, Thanks Paul

              I was relying on your comments terri to explain what you meant, you say it was someone you spoke to, i am not party to that, so that explains why i did not appreciate the point..

              i said “Perhaps you have more knowledge of that?” maybe that is why i didn’t understand you, you were referring to a personal conversation, so i could not know that could i?

              If that is different to what you meant, then i misunderstood you, however Paul has made it more clear fro Drill or Drop records, i suspect Paul did not have that personal testimony you mentioned either?

              I begin to understand what you mean however, as i am sure Paul does. You ought to know that i don’t agree with either the union or the oil&gas industry trying to run roughshod over anyone, or indeed anyone else? Perhaps however there are many such attempts to do just that, no matter from which direction or denomination?

              Today and tomorrow may clarify that.

  10. Phil, [edited by moderator] If you think this was a good day for the council or that we feel any anxiety about some insignificant comments made by Mr Evans then I’m afraid we’re going to have to spoil the party.
    It has been proven that the councilors are not capable of carrying out their elected positions and should quite simply resign immediately. But these types of people never admit guilt and nothing will happen other than Egdon win its appeal. If they don’t the council will be annihilated in a court.

    • Who is we? Or does that refer to all those multiple ID’s that talk to each other and make the same comments as if they were different people, but we know they are just one person don’t we?

      Have you actually read any of the testimony? Apparently not? Unless there is some fantasy version of events us mere mortals are not privy to?

      Lets have a look at what you say shall we? Always fun to delve into the stygian darkness for a short while, but i will carry a torch and a 45 magnum, the dark chocolate one

      Do i think it was a good day for the council? I think it was a bad day for Egdon, Mr. Mark Abbott could not produce any evidence and didnt even know if any evidence existed?

      What then about Mr. Evans, Oh, by the way, congratulations on calling him Mr. Evans, a vast improvement. How was anything he asked inconsequential? As far as i can see he asked all the right questions, it was Mr Abbott who could not answer anything and just gave “i don’t know” replies?

      To what does this “spoil the party” refer to? Is that a tory party perhaps? Spoilt i will agree, but not much a party though, more a sort of rolling internecine uncivil war?

      “It has been proven that the councillors are not capable of carrying out their elected positions” really? Proven where? Do you have any written evidence of that? Or is that another total lack of evidence such as the site investigation that never happened? Do tell?

      The rest of your post is simply the same unfulfilled fantasy wish upon a star delusional opinion we were speaking of on the previous days hearing comments and has no engineering relevance.

      “If they don’t the council will be annihilated in a court.” My dear peeny, it is easily established that Egdon have nor fulfilled any of their contractually required compulsory precautions to protect the site from heavy traffic, polluting hydrocarbons and contaminated water, they also intend, i hadnt gotten there yet, to use hydroflouric acid the most caustic acid on the planet in the wells, and the underlying aquifer is, as a result of the compromised membrane and the inadequate thickness of the out of spec stone, going to be contaminated and Egdon dont seem to care?

      OK, that it? That was all you had was it? Lets do a list shall we?

      1. Mr Evans vs Mr Abbott. I would say Mr Evans 9/10, Mr Abbott around 3/10, and that is being generous, mostly just for turning up and not tripping over the furniture, or martins uncomfortable chairs for that matter.
      2. “Spoil the party” Little or no party to be spoilt, unless you count the tory party of course, and they are all ready spoilt.
      3. Councillors (has two “ll”‘s by the way) no evidence given of any such claim of not being capable, just a wild unsubstantiated claim, its probably buried under 300mm of inadequate and out of spec stone and flint with the evidence of the site investigation non report.
      4. Pure opinion wishful thinking i am afraid? No evidence whatsoever.

      I am sorry (well not very much really) to destroy your illusions peeny, but It is Egdon that have not got a rig to drill on, North Lincolnshire Council were and are quite correct to refuse permission, and Egdon will lose in any court.

      • Whilst I’m sure Ruth is doing a wonderful job of reporting the meeting, and many thanks to her for doing so, she does seem to be a bit selective of what she puts in and what she leaves out of her reports. Have a look at the LSE share chat room today under Union Jack Oil, where the poster knows someone else in the meeting and is getting a different take on proceedings. Especially as regards the membrane and the rest of the surface protection regime. As you might expect, replacing all of those materials, if necessary, should be a quick and simple task on such a small site. Apparently one of the council witnesses admitted as much yesterday – but Ruth didn’t mention that.

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