Angus Energy announced this morning it had begun its testing programme on a controversial oil well at Brockham in Surrey. But local people have been asking questions about whether the company has met all the conditions of its environmental permit.
The Environment Agency (EA) issued an updated permit for the site last month, in advance of tests to assess oil flow from the well. This was drilled – in Surrey County Council’s view – without planning consent.
The permit included pre-conditions that had to be met before work could begin. The conditions including: requirements for a gas management plan, site improvements and monitoring arrangements; restrictions on the use of acid; and prevention of water reinjection.
The EA dropped its usual public consultation on the proposed permit because testing was imminent. But it promised to tell a residents’ group when the pre-conditions had been met.
So far, the group, Brockham Oil Watch, has said it has heard nothing. The EA is treating the group’s questions, sent earlier this month, as a Freedom of Information request. This means there is no obligation on the EA to respond sooner than 20 working days.
DrillOrDrop asked the EA whether the pre-conditions had been met and invited it to respond to the group’s concerns about the handing of its questions.
The EA said this afternoon it would be issuing a briefing tomorrow (Thursday 20 December 2018). Asked about the form and distribution of the briefing and, again, whether the pre-conditions had been met, an EA spokesperson said:
“That is all I have”.
Angus Energy said in a statement to investors this morning it had “commenced its previously announced commercial flow test programme at the Brockham Oil Field.”
The flow test will assess the Kimmeridge layers of the BR-X4Z well at Brockham. The company said the test programme would break for a fortnight over Christmas, starting on 23 December 2018. An analytical update would be issued in due course, Angus said.
Brockham Oil Watch said today:
“We have a confirmation that the flow test started, but no confirmation that the pre-operational condition was satisfied and no details of an approved gas management plan.
“Why are the conditions of the new EA permit not being enforced?
“Angus have an appalling track record at Brockham and other sites. They have committed numerous breaches, misled the public and the regulators, playing them off against each other time and again. This should not be tolerated.”
Angus chairman, Paul Vonk, talked about the Brockham flow test during an interview in October:
“We are finalising the contracts with service providers and the details are being set out. We’re looking to switch that on literally in the next couple of weeks – definitely before Christmas and then we’ll be in production.”
Shares in Angus fell sharply on today’s news and closed on the day down more than 14% at 11.02p.
This morning, some online comments by investors drew attention to the wording of the statement. They distinguished between the start of the “programme”, used in the statement, and actually “testing”.
DrillOrDrop invited Angus Energy to comment on the statement. This article will be updated with any response.
Equipment began arriving at the Brockham site earlier this month, beginning with the flare stack on 6 December.
This prompted Brockham Oil Watch to contact the EA with questions about the permit pre-conditions.
When the group received no answers, it turned to local councillors, appealing to them to press the EA for more information and for an unannounced visit to the Brockham site.
Brockham Oil Watch told DrillOrDrop earlier this week:
“We are surprised with the work progressing so quickly after the announcement of the modern EA permit 26 Nov. This permit has a number of conditions including the requirement for a gas management plan that must be agreed prior to production from the Kimmeridge layers via the new well (BRX4Z). As far as we’re aware, the conditions have not yet been satisfied.
“The last update we had from the EA was on 7 Dec. The enclosed CAR dated 29 Nov shows that the EA are raising a number of issues with regards to the gas management plan. It also shows that Angus have not yet removed the link between the injection pump and the reinjection well on the site plan, even though reinjection is banned under the new permit.
“Angus Energy are pressing ahead with the appraisal work, possibly in breach of the new environmental permit. They may well also be pressuring the EA to work to their schedule and rushing through approvals. We have asked multiple questions of the EA since 7 Dec due to the activity on site, but were told that, due to a small number of staff, these would be answered as FOI requests, so taking 20 working days or more. (By then, the workover might be completed and any damage would have been done.)
“The EA prides itself on transparency and maintaining strong and meaningful links with the local community in order to benefit from local support and local knowledge. It is therefore unacceptable for the EA to be introducing delays in information disclosure by treating them as FOI requests. Such delays run the potential risk of failure to prevent permit breaches. We expect the EA to provide information in a timely and transparent way.”
Brockham Oil Watch said Angus Energy was required to establish a community liaison group as part of permission for a seven-day well test at another oil site at Balcombe, in West Sussex.
“The community liaison group includes regulators, police, councillors and representatives of local community.
“At Brockham, where Angus have permission for 3 years of extraction, including multiple workovers, there is no liaison group and little transparency, leaving the community in the dark. A representative of Angus Energy met with three parish councillors in late October and offered the next meeting in 6 months’ time.”
Updated: Investor comment
An investor in Brockham, the exploration company Doriemus, said in a statement (20/12/2018):
“We are pleased that the long-term flow testing of the Kimmeridge layers has now
finally commenced at Brockham. This work has been a long time coming.
“There is now obviously a great deal of local and UK attention on the visible activities
associated with work on site at Brockham, and Doriemus sees it as totally prudent
that the Operator publicly flag its intention to temporarily stop flow testing over the
Christmas and New Year break. An unannounced lack of activity at Brockham over
this holiday period may indeed cause unnecessary concerns as to the programme
Updated 20/12/2018 with Doriemus comment