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.”
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.
“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”.
“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.”
“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.
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.
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.”