Council seeks new comments on Horse Hill oil production plans

181220 Horse Hill site plan HHDL

Site plan for the proposed extension to the Horse Hill oil site in Surrey. Source: Horse Hill Developments Ltd

The decision on plans to expand the UK Oil and Gas exploration site at Horse Hill in Surrey has been put back again, until at least July.

The application for five new wells and long-term oil production at the site near Gatwick had been expected to be decided next month (June 2019) after two previous postponements earlier this year.

But today the county council began another round of consultation on new documents from the company.

People who commented on the original application have been invited to respond to the additional material by 24 June 2019.

After this deadline, the next scheduled meeting of the council’s planning committee is Wednesday 10 July.

A Surrey County Council spokesperson said today:

“Providing all the necessary information has been submitted and consulted on, then 10th July will be the new date.”

190522 SCC consultation letter

Extract of letter from Surrey County Council inviting comments on new material on plans to extend the Horse Hill oil site near Horley

The new material, in five documents, covers issues including earthquakes, risks of major accidents, water re-injection, pollution protection, waste and surface water management, landscape restoration and traffic.

The documents, listed on the application website, are mainly responses to issues raised by the Environment Agency and consultants or departments working for the county council.

The site operator, the UKOG subsidiary Horse Hill Developments Limited, is seeking permission for four new oil wells and a water reinjection borehole. It also wants to build processing and oil storage areas and a tanker loading facility. The application includes well maintenance workovers, side track drilling and production from a total of six oil wells at the site for 25 years.

If approved, the site would increase in size from 2.08ha to 2.8ha, adding another area of open arable farmland for oil storage, processing and transport.

There have been more than a thousand objections to the application.


The Environment Agency had asked questions about the impact on the site of the spate of earthquakes centred on Newdigate, near Horse Hill.

The company responded that monitoring infrastructure and mitigation of effects from seismic events would be considered during the environmental permitting process.

It added:

“For the purposes of the planning process, the Applicant has established there to be no relationship between the recent sequence of low-level seismic events close to Newdigate, Surrey and the activity undertaken at the Horse Hill well site.”

UKOG also responded to a briefing paper, sent to the council in February 2019 by academics at Edinburgh University. This predicted future earthquakes and suggested a hypothesis that bleeding the well could have altered the fault stress balance and led to seismic activity. Since the date of the letter, there have been 20 more earth tremors. Four of them were felt and measured between 2 and 3.1 on the local magnitude scale.

The company said there were “many significant factual errors” on a subject “which falls outside their specialist field and in which they are not recognised experts”.

It said the paper, which was not peer-reviewed, “serves as a source of misinformation” unworthy of the university’s “high academic standards”.

It concluded:

“We regard the promulgation of demonstrably false and poorly researched comments by persons occupying a position of public trust to be wholly unacceptable in any open and democratic society.”

Risk of major accidents or disaster

UKOG said an assessment under the Control of Major Accident Hazard (COMAH) regulations found that the site was:

“sufficiently remote from land-use hazards to render any risk low, unlikely and not major.”

It added:

“There will be no increase in the Site’s vulnerability given that the same considerate construction and drilling practices employed to date will be engaged again.”

Restoration and decommissioning

UKOG said restoration may not take place for 25 years from the date of permission. It said

[the] “host landscape and the legislative framework that governs well site decommissioning, environmental protection and mitigation may have changed. It would not be prudent to generate detailed plans at this stage.”

But it added:

“The outline plan contains sufficient detail to demonstrate the site can be restored and managed to a high standard”.

The company would follow a principle of restoring the site to its “original character and biodiversity levels without delay”.

Environmental protection and pollution control

The company said the proposed extension to the site would be separate from the existing well pad. This meant that the new impermeable membrane, designed to prevent spills contaminating soil or groundwater, would not be connected to the existing membrane.

It also said the membrane would be installed using Environment Agency guidance documents. These are primarily designed for landfill sites but were “material” to installation in other industries, the company added.

Surface water

The new documents said the current drainage system would be retained. This would keep the existing well site a “hydrologically contained area”. No changes would be made to site liner and drainage to existing access track, they said.

The proposed well site extension would have a separate and independent drainage system, using the same concepts as the current site.

A clarification statement said:

“water would be collected in a below ground tank or sump to enable isolation if required and pumping into a road tanker for off-site disposal or pumping to the produced water system for reservoir pressure support if required.”

The company said it had changed the site design to prevent any connection between surface water systems at the tanker loading bay.


In response to comments by the county highways authority, the company agreed to a condition which would limit heavy goods vehicle (HGV) movements to 16 in and 16 out per day.

A traffic management plan would include driver awareness training and other measures to ensure that HGVs kept to their side of the road when turning in and out of the site.

Other issues

The company stated that issues including water re-injection, drilling muds, chemical use, waste management, air quality, noise and vibration were “relevant to the environmental permitting process”. It added:

“For the purposes of the planning process the proposed development can be considered appropriate for its location consistent with national planning policy.”

Link to planning application SCC Ref 2018/0152

Link to comment online on the application 

Link to Surrey County Council planning committee web page


15 replies »

  1. “many significant factual errors” Go on, name them for us please UKOG.

    …on a subject “which falls outside their specialist field” Manifestly incorrect. Professor Haszeldine was arguably the expert with the most relevant expertise at the OGA “inquiry” and the only one there truly independent.

    “Demonstrably false” Go on then, demonstrate away. If you have nothing to hide release full, original work-logs for March and April 2018, prove Edinburgh wrong.

    What have you got to hide?

    • Haszledine has zero expertise in this area. His background is sandstone diagenesis and he then moved into CCS. He has never conducted research into geomechanics or seismicity.

        • If it’s nonsense I’m sure you can point to the academic papers that he’s written on geomechanics and/or seismicity. I won’t hold my breath

          • Just think about the skillset required for a Professor in Carbon Capture and Storage, all the elements are there.
            Unlike the majority on the OGA inquiry who were seismologists, a smaller area of study, and were either unwilling perhaps even unable to engage with the detailed study Edinburgh presented them with in October. Quotes from Dr Luckett in the Surrey press suggested he thought the hypothesis relied on connecting a gauge to the well! Sounds like he wasn’t even listening at the workshop. No one engaged with the data behind the hypothesis, perhaps because the head of the inquiry had opened the meeting by saying “let’s not take too long over this”.

            • Dorkinian – thanks for confirming that Haszledine hasn’t got any publications in geomechanics or seismicity.

              • Don’t thank me Judith, I didn’t comment on his publications and I haven’t done any research into them. But he is clearly well qualified to investigate the Newdigate Swarm and isn’t compromised by his reliance on oil and gas money unlike the other parties, the ones that excluded Horse Hill as a possible cause. Three kms away from the epicentres and drilled through the fault.

                • Dorkinian – you are clearly totally clueless in this subject. The main qualifications. One needs is expertise in house pore pressure and horizontal stress are coupled. If you bother to do your research you will find that several people giving evidence had such expertise – Haszledine wasn’t one of them

                • More nonsense. Yawn.

                  We have had a history of nonsense from you haven’t we Judith? First you thought Edinburgh’s hypothesis was that Brockham caused the earthquakes, next it was the “fracking”, now the experts aren’t experts in house pore pressure.


                • Typo – should be “how” not “house”

                  Dorkinians usual fact free post. I attended a lecture last week that claimed that a recent survey on fracking showed that people’s views on evidence in the non-science community was strongly correlated with their opinions on fracking. In other words, they make up their mind on what to trust without looking at the evidence and simply by hearing the bottom line of the conclusion. Dorkinian seems to provide an excellent example of such wrong minded thinking.

                • Your comments around how people take positions Judith are enforced by a headline in todays Times-

                  “Australia opening coalfield the size of Britain in climate change U-turn”

                  “Climate change was supposed to have won the Labor Party the Australian election. But yesterday, after having been routed by voters, its panicked leaders backed the mining of a coalfield bigger than the UK. Fearing a wipeout in state elections next year amid a rise in pro-coal workers and a rebellion against its plans to halve Australia’s carbon emissions…”

                  Another 27 BILLION tonnes of coal to be extracted and burned.

                  There are flights from Gatwick, Dorkinian, to Australia or China to help you to make a real difference. Fawley Refinery will be pleased to supply the aviation fuel and on the way you could contemplate whether some oil from HH was enabling you to get to where the real action is.

                • If someone is about to be run down by a fossil fuel industry corporation HGV carrying toxic fracking waste water, do they consider for one second how qualified they are to understand the physics of velocity and acceleration, the qualifications to understand the engineering of HGV’s and tyre and road construction, the qualifications to assess wind the weather, the qualifications to understand optical and audio physics of sight and sound, or the medical qualifications required to asses the effects of the impending impact and the costs and complexities of funeral arrangements and insurance? Not to mention the effects of contaminated water supply and where water comes from?

                  No, you just get the hell out of the way and call the police.

                  No physics or science qualifications required, just simple logic and self preservation.

                  Qualifications stated as an elite exclusive preserve by which an individual is inclined to look down upon anyone who has not had that opportunity or desire to do so, is just a self defeating illusion trotted out by those who consider themselves superior to everyone that has not achieved or needed such a narrow institutionalised indoctrination.

                  It took me a long time to realise that all my qualifications are as nothing compared to the simple action of caring for my fellow human beings, and in fact, because i spent so much time getting academic qualifications to get a good overseas well paid position, i was simultaneously missing out on being with my growing children and my wife, who needed me there, not in some dreaming spire of high academe or far away spot where much was about finance and status.
                  They are mere illusions.
                  It was only by returning to my family that i began to really learn what life is all about, and i now regret that illusion of academic and working diversion from the real truth. I hope i have made up for that since, only my children and their children can attest to that.

                  Those who understand the true value of a good education will seek to inform and advise others without the worrying need to look down upon those who either didn’t have that privilege, or have not had the need any such illusion since common sense and intelligence is not the preserve of those who set themselves up as being in the least bit superior by qualifications. In fact the opposite is true.

                  There are many i know who understand more, and i would trust more, by the sheer capacity of their innate intelligence and open humanity.
                  Any who seek to dictate by means of a sense of illusory superiority are mistaken compared to the really intelligent who serve to help everyone towards a better future, and that for future generations, regardless of how much, or how little they have had the opportunity to learn at an institution that only serves to proliferate elitism and not give a damn about about the consequences of their actions, as is clearly demonstrated here daily.

  2. This is so poorly researched and the bias is so obvious. The professor has very wisely himself accepted that he is biased against oil and gas due to his commercial involved in carbon capture storage. I am not sure how you conveniently ignore research by Stephen Hicks and other siesmology experts who are perhaps more knowledgable about the subject. [Edited by moderator]

  3. Some of us could gain our qualifications and have a family life. The vast majority of people do, even when needing to work abroad.

    But, in a good humour and willing to help others here’s a novel suggestion:

    Let UK produce UK oil from HH and prevent our drillers having to work the other side of the world and miss out, maybe, on family life.

    Another note to the SCC indicating that extra benefit is called for!

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