Europa Oil and Gas is seeking more time to drill and test a well at its exploration site near Leith Hill in Surrey.
The current permission, granted in 2015, runs out next month. The company has not complied with all the conditions and no site construction work, drilling or testing has been carried out in the past three years.
In a statement to investors, Europa said it would submit a new planning application for the site at Bury Hill Wood (known by the industry as Holmwood).
It also said the exploration licence covering the site had been extended again and that it had been granted environmental permits.
Extending planning permission
Europa said it was seeking to extend permission for operations at the site for another three years. It also wants to remove the condition of the current planning permission to identify a holding area for heavy goods vehicles.
This condition was imposed by the inspector at a planning inquiry in 2015. It has been a barrier to satisfying conditions in the current permission, which expires on 6 August 2018. Europa had tried to use a café car park on the A24 and motorway services on the M25 but DrillOrDrop understands that it failed to get the agreement from the operators.
Europa added that it was applying to extend another two planning permissions: for the underground drilling corridor for the Bury Hill Wood well and security fencing around the site.
A spokesperson for Surrey County Council said:
“We’ve received three applications but these have yet to be checked and validated so no decisions on timescale have been made yet. Once they have been they will go on the council’s website in the usual way.
“These are EIA [Environmental Impact Assessment] applications and as such will be subject to a minimum 30 day public consultation.”
This is the latest stage in a long-running planning dispute over the site in the Surrey Hills Area of Outstanding Natural Beauty and the green belt.
Europa first submitted the application to drill nearly 10 years ago in December 2008. It has been through two public inquiries and two court cases. Local people said they have spent a six-figure sum opposing the proposals.
Sixth licence extension
Europa said the Oil and Gas Authority had extended the initial or exploration term of the Petroleum Exploration and Development Licence covering Bury Hill Wood for another two years.
The initial term of PEDL143 had been due to expire on 1 October 2018. The terms of the licence require operators to drill a well or give up the licence. Europa is unlikely to meet that commitment. But it said the OGA had extended the initial term until 30 September 2020.
According to information supplied in response to a Freedom of Information request, this will be at least the sixth extension of the initial term of PEDL143.
Previous extensions were made in 2016 (two years), 2015 (one year), 2013 (two years), 2012 (one year) and 2010 (two years).
Environmental permit granted
Earlier this week (23 July 2018), the Environment Agency issued a mining waste permit to Europa for the Bury Hill Wood site.
During the consultation on the permit, there were nearly 2,000 responses. A petition urging the Environment Agency not to grant consent had more than 100,000 signatures.
Two expert reports, submitted to the EA by opposition groups, argued there were significant errors, inconsistencies and omissions in the permit application documents.
Opponents of the scheme said they were concerned about contamination of the local aquifer and air quality. They said the company should be required to apply for a groundwater activity and water discharge permits.
There were also concerns that Europa may not be able to restore the site if it went bankrupt.
Issues in the mining waste permit
Risk to groundwater
In a 32-page decision document, the Environment Agency said Europa did not need a groundwater activity permit because the risk was regarded as “de minimis” and had been addressed by the company’s hydrogeological assessment.
Depth of weald clay
The EA said it had been concerned about discrepancies over the depth of the weald clay under the site. This was considered crucial because Europa said this rock formation acted as an impermeable layer, protecting the aquifer from any contamination.
The EA said:
“Europa was able to demonstrate that latest information confirms there should be over 400m depth of Weald Clay available to protect the Tunbridge Wells sand formation within the Hastings Beds.”
Opponents of the scheme said there were sandstone and limestone bands in the weald clay that could create a pathway for contaminants.
The EA said these bands were unlikely to be “in hydraulic continuity with groundwater-bearing units”. It also said the grain size of sandstone would be very fine and well cemented so “they will not form a significant migration pathway for fluids and will only contain negligible amounts of groundwater.”
Oil based drilling muds
Europa proposed to use oil based drilling muds in the weald clay, at a depth which was against UK guidance. The EA said it accepted Europa’s argument that using oil based drilling muds would be safer, quicker and less risky than water-based muds.
Angle of the well
Opponents of the scheme were concerned that Europa has made the angle of the well steeper than originally proposed and the planned depth of secondary casing had been shortened.
The EA said the company’s proposal “meets expected requirements”.
Use of acid
Europa had originally said it proposed to clean the well bore using acid wash and acid squeeze operations. The acid squeeze would send dilute hydrochloric acid (HCL) up to 14m into the formation and may stimulate the oil flow, the company had said.
In response to questions from the EA, Europa revised its plans. It said the only intention was to clear any damage in the target formations caused by drilling. Pressures used would not be enough fracture rocks and there would be “no discernible trace of the product” in the groundwater, it said. Europa also reduced the expected distance that acid would travel into the formation, although the EA decision document did not disclose what this was.
The EA said 93m3 of HCL would be pumped into the formation for a maximum of three acid wash and squeeze operations in the Portland sandstone, Kimmeridge Micrites and Corallian Sandstone. The Great Oolite Group may also be targeted, the EA added.
It said the operations met a regulatory exclusion which meant Europa did not need to apply for a groundwater activity permit.
The expert reports commissioned by opponents raised concerns that Europa was including the Kimmeridge micrites as a target reservoir and describing it as a “conventional oil play”.
This would require acidising to release the oil and the volume was at higher levels that would be expected for a “conventional” oil well, opponents argued. They also suggested that the proposed acid squeeze amounted to matrix acidisation.
The EA added “whether operations are considered conventional or unconventional is not a critical part of the decision process.” It added that the permit would not allow Europa to undertake hydraulic fracturing.
The report commissioned by A Voice for Leith Hill criticised Europa for not undertaking seismic reflection studies to define faulting and target structures. It also suggested there was a poor understanding of the structure of the principal aquifer.
The EA responded that it was satisfied that groundwater would be protected, without the need for seismic data.
It added that data from groundwater monitoring boreholes would identify if groundwater flow was in a different direction to that anticipated by the company.
The permit will allow Europa to flare waste gas from the well for a total of 15 days, providing the volume does not exceed 10 tonnes a day.
The site is within 600m of the Leith Hill Site of Special Scientific Interest and the exploration site boundary is 50m away from ancient woodland. Opponents had argued that the flare would contribute to air pollution.
The EA said proposals to monitor the flare were “satisfactory to control air emissions”. It said the critical level of nitrogen oxides (NOx) over a 24-hour period could be exceeded. But it said:
“This is limited to 10-20m of the nearest part of the ancient woodland with the majority of woodland remaining below the critical level for NOx.”
It added that the operations were not likely to damage wildlife or other features in the Leith Hill SSSI, nor affect “any sites of nature conservation, landscape and heritage, and/or protected species or habitats identified”
Conditions of the permit
Europa is required to submit:
- Method for calculating air emissions of nitrogen oxides, carbon monoxide and TVOCs [total volatile organic compounds]
- Construction quality assurance (CQA) plan on site surfacing and containment at the well site
- CQA validation report on site surface and containment
- Baseline groundwater monitoring results and a report proposing compliance limits
- Report on monitoring key indicators of chemical additives including proposed compliance limits.
The Environment Agency (EA) has also issued standard rules permits for radioactive substances and oil storage at Bury Hill Wood.
Julian Everett of community group, A Voice for Leith Hill: said:
“It’s sadly symbolic that just before this year’s Earth Overshoot Day – when humanity will have used more from nature than our planet can renew in the entire year – this permit has been granted by the government agency responsible for protecting our environment. The EA has decided to permit activities that will exacerbate climate change and jeopardise our drinking water supply in an area that is currently experiencing unprecedented levels of seismic activity.
“The EA claims activities will be closely monitored, yet despite several site visits they were unaware of an entire side-track being illegally drilled at Brockham – drilling that was conducted by the same company that now has the farm-out deal at Leith Hill. Instead, once again it is going to fall to the citizens of Surrey to do the job these publicly funded professionals should be doing: of protecting our environment and communal resources, and of upholding the will of local democracy”.