UKOG tells inquiry the site of its proposed Loxley drilling site is not in a valued landscape

This post has news updates from the afternoon of the opening day of the public inquiry into plans by UK Oil & Gas plc to drill exploratory gas wells near the village of Dunsfold in Surrey.

The county council refused planning permission for the site, known as Loxley, in November 2020. The council said it would have unacceptable impact

Click here for background to the inquiry and here for key points and updates throughout the hearing, scheduled to last for nine days.

This is not a verbatim report. Please let us know about any mistakes or misinterpretation.

3.15pm Timetable update

The inspector, Mike Robins, says he cross-examination of UKOG’s landscape witness will begin tomorrow.

He says statements are going onto the Surrey County Council inquiry website. The agreed timetable will be added to the website.

The inquiry adjourns until 9.30am on Wednesday 28 July 2021.

2pm: UKOG landscape evidence – Will Gardner

Will Gardner

David Elvin QC for UKOG introduces his landscape witness, Will Gardner, of the consultancy, Environmental Dimension Partnership.

Mr Gardner says the proposed drilling site cannot not be considered “valued landscape”. He says:

“All landscape possesses inherent value, but it is clear this is not the same as possessing landscape value worthy of the ‘protect and enhance’ status.

“It would be inappropriate and (from a planning perspective) impractical to conclude that the appeal site is part of a valued landscape simply by virtue of its being within the setting of the AONB.”

He says an assessment of the site’s value had been undertaken. He says:

“there is no basis to afford the appeal site the elevated status of being or forming part of a valued landscape”.

“Short-term adverse effects”

On the effects of the wellsite, he says:

“There would be short term adverse effects on the landscape characteristics of the appeal site; however, these would be limited to a geographically discrete area given the relatively low level change arising from the removal of a section of hedgerow at the access track junction with High Loxley Road, introduction of security gates and fencing, and the change from agricultural land to compacted hard core for the track and Well site.”

He said the long-term effects on the landscape would be neutral:

“At the end of the development operation and following dismantling and removal of equipment and materials, the agricultural land and removed sections of hedgerow would be restored and enhanced. The residual effect of the development would be at worst case neutral.”

On nearby woodland, Mr Gardner said the landscape assessment assumed there was no woodland because it could be felled.

Impact on local visual amenity

Mr Gardner says

“This is a very contained site in terms of the wider effects of the proposals on visual amenity. The potential effects have been studied carefully and viewpoints/modelling locations agreed with relevant consultees. 6.8 Analysis shows that there will be no significant changes to visual amenity from the wider countryside to the north, from which the primacy of the AONB will remain unaffected.”

Effects on Surrey Hills AONB

Mr Gardner says:

“The site lies in close proximity to the Surrey Hills AONB, thus lying within the setting of the AONB. The proposed development would not have any direct effects upon the nationally designated landscape.

“the proposed development would have limited effects on the landscape character of the ‘Grafham to Dunsfold Wooded Low Weald’ LCA setting of the AONB, and its perception in views out from the AONB. The majority of views from the AONB would not be impacted by the proposed development.”

He adds:

“Visual analysis has determined that the incidence of woodland blocks, combined with a relatively low-lying site, undulating topography and Hascombe Hill to the north, create partial containment and therefore limit the extent to which effects would impact upon selected visual receptors.

“The potential for the greatest adverse effects is on users of the local PRoW to the south of, and in close proximity to, the Well site and part of the access track. Effects upon High Loxley Road, a quiet rural road accessing farmsteads, would be limited by its meandering alignment, gently undulating landscape and tree and hedgerows lining the road.”

Mr Elvin asks about a landscape assessment by the AONB planning advisor, Clive Smith. Mr Gardner says Mr Smith concluded that the impact would not be sufficiently adverse to be significant.

Mr Smith said it was hard to justify refusal of UKOG’s application on landscape grounds, Mr Gardner says. Mr Gardner also says Surrey County Council’s landscape consultant agreed with this.

Will Gardner

“Temporary effects”

Mr Gardner says the most important issues that should be considered when deciding a planning application are the long-term residual effects.

He says the UKOG application is for three years and for long periods there is no activity.


Mr Gardner says permanent irreversible landscape effects would be significant, or if there was a complete loss of a baseline situation.

There are no significant landscape effects of the UKOG application, he says.

Mr Garner disputes that it would take five years to achieve a neutral impact.

Will Gardner


Mr Gardner defends the accuracy of the visualisation montages submitted by UKOG and the methodology of the landscape and visual impact assessments.

He also defends his Zones of Theoretical Visibility (ZTVs). These are computer-generated tool to identify the likely extent of a development’s visibility.

UKOG and the council have disputed each others ZTVs, which produced different results.

Mr Gardner says his ZTVs show there would be limited views of the site from the edge of the AONB with nearby woodland in place. The council’s consultant over-predicted the impact, he says.He says the felling of trees from nearby woodland would not make the site more visible from the wedding venue at High Billingshurst Farm.

Night-time impacts and lighting

The council’s consultant has criticised the company for not undertaking a night-time assessment in its landscape and visual impact assessment.

Mr Gardner says a lighting impact assessment was carried out an submitted with the application.  

He adds there would be a “discernible addition” to night-time light but this would be just for 18 weeks during drilling the first well, and more if a sidetrack were needed.

Will Gardner


The council’s consultant questions the effectiveness of mitigation measures proposed by UKOG. Mr Gardner says these were introduced by the company in response to concerns from the council.

He says there was a commitment from the first phase to strengthen hedgerows to ensure biodiversity gains as soon as possible.  

High Billinghurst Farm

Mr Gardner says topography effectively screened low level activity on the wellsite from nearby Billinghurst farm.

He says the proposed 4m site fencing would also filter low-level activity from the property.

Mr Gardner says the council’s consultant had not taken account of vegetation on the site boundary.

Heavy goods vehicles (HGVs)

Mr Gardner says HGVs would not be using the site for the full three years of the proposal.

Evidence from the morning session of Day 1 is here

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20 replies »

  1. I was actually just going to read through the statement of Mr Gardner until this little gem appeared at the bottom of the text. I surpressed a sudden laugh of astonishment until I read it again. I must admit, I still dont believe Mr Gardner could have actually said such an outrageous statement.

    May I ask, did Mr Will Gardner really say this?:- (quoted from the last line in the text above)

    “Mr Gardner says HGVs would not be using the site for the full three years of the proposal.”

    Pardon me? Unless there is another way of constructing an industrial site on remote agricultural land that no-one was previously aware of? Such an worrisome enterprise can not be even remotely possible without the use of many HGV arriving, operating and departing daily.

    For example how does UKOG intend to deliver the construction materials, the fences, the rig and its associated equipment, the materials for the pad and the base for the surface, the trackway materials and compaction processes? Heavy lifting gear? The site huts and the generators, cables and rigging?

    Maybe Mr Gardner would care to explain how an entire oil and gas exploration site could be constructed without the use of HGV’s if not larger vehicles? I would hesitate to have to interpret that statement as suggesting that UKOG would use any viable alternatives to do the work of transportation of Heavy Goods and the on-site engineering by any other fashion? All by shank’s ponies perhaps?

    I could conjure up a possible list, but maybe that’s best left to every ones imagination, which appears to be commensurate with Mr Gardners statements. Conjuring up that is.

    Just from that one statement alone, I would call into severe doubt anything else Mr Gardner stated during his presentation. And I was not even trying to find fault, but only to read through the statements as they appeared.



  2. Astonishing that someone thinks this site would take 3 years to construct, especially when detailed operation plans have been submitted!

    [Edited by moderator]

  3. But isn’t it the case, as we have heard during previous planning inquiries, that seldom is one well drilled on a site, that waste water often has to be removed during the production phase, not just immediately after drilling or any well stimulation, that routine maintenance is required, and all this frequently necessitates HGV traffic? Other planning applications and inquiries have stated HGV traffic albeit less than in construction would continue and increase again significantly with any subsequent drilling or stimulation activities. Even if they only drill one well in three years, surely there will be HGV traffic for the full three years – to some extent?

    • Hi KatT, yes, I’m sure you are correct. That is my understanding too. That is what I was saying. Not what Mr Collyer misrepresented at all. A rather odd interpretation of the reported words I must say.

      [Edited by moderator]

      And the fact remains, that during the proposed three year life of the UKOG project, should it ever be approved by whatever means, will most certainly have regular HGV’s arrivals, departures, and operating procedures during the proposed three year life of the project, just as you have pointed out KatT.

      It will be interesting to read what the cross-examination of Mr Gardner, UKOG’s expert landscape witness reveals later today.

      • [Edited by moderator]. It’s not as if UKOG ever had any success, it’s just ruining the countryside and peoples lives .
        The minuscule amount of oil they have found is hardly worthy of mention let alone of National importance .

        • Hi Jono, yes, as you say, for some its a game of snakes and ladders. Unfortunately without the ladders. It’s much more enlightening to read the individual witness statements of News updates: Loxley/Dunsfold drilling inquiry – Day 1 morning and afternoon, and also of Liz Brown of Atkins Consultancy and others on the News updates: Loxley/Dunsfold drilling inquiry – Day 2 council landscape evidence.

          At least their statements contain none of those factually exclusive absolutes denying all logic. Particularly Liz Brown’s comments are based upon reason and the facts of the case. [Edited by moderator]

          I look forward to tomorrow’s witness cross examinations. I must say thank you to Ruth Hayhurst and Paul Seaman for their stirling work on reporting this Loxley/Dunsfold inquiry too. Credit where credit is due.

    • The Appeal considers this application, KatT!! (ie. for a period, for a purpose.) Just like every other application.

      It really is that simple.

      Subsequently, if production, or any other use was required, then another process would be gone through. (ie. another application, which might be passed or might be refused. So, the two bed bungalow planning application doesn’t cover the possibility that it could be turned into a mansion later. That has to follow as another application.)

      [Edited by moderator]

      The most common complaint about developments is concern as to what subsequent intentions are, and the standard response from the planning department is that is not what is being considered here, and will not be relevant to this application.

      • [Edited by moderator]

        It will be much more rewarding to read what the cross-examination of Mr Gardner, UKOG’s expert landscape witness reveals later today.

        Facts not fantasy.

        • David King

          I really can not believe your comments spread over so many words.

          If the Appeal grants the permission which would be for 3 years as soon as one day has passed his statement becomes true.

          [Edited by moderator]

          • [Edited by moderator]

            Appeals are there to clarify, so, reality and fantasy should be separated. If not, then probably round two, when I suspect costs will be sought. That is all part of the standard process, and is not open to a local UDI. The Inspector knows that, the Council knows that and UKOG know that. Others may not, but will probably get a polite hearing.

            • Martin Frederick Collyer

              I find it very ironic that the County council seem to be in dispute with there own professional planning professionals that they employ?

              This morning certainly seems interesting with Ms Wigley appearing to not really know if she is coming or going with her cross examination & her documents.

              The last cost of this type of planning enquiry were very high awarded to UJO & could be higher here which will ultimately be felt in there services.

              • I wander if Ms Wigley will be cross examining the County councils own planning department which have brought this application to the planning committee on 2 occasions with the application being recommended for approval on both occasions?

                It appears that she picked the short straw!

              • It is not unusual with Planning Appeals, MH.

                Usually, the Inspector is pretty aware of how that sits with regard to the applicant. Those Appeals I have been to, it is noticeable that it is taken on board pretty quickly. However, I suppose different Inspectors have different approaches, so only time will tell, but I suspect some cross examining is to come that will focus on that point.

                I do smile about the country lane approach. Why are most of the country lanes there? So, that agriculture can take place and farmers can reach their various pieces of land. Any serious restriction put upon agricultural machinery? Pea viners (huge pieces of kit) etc? Nope. Do the farmers manage to get on with the leisure users? Usually-but not exclusively. It is accepted that give and take is required.

                By the way, when the pea viners, that run day and night, break down, then mechanics are flown into the field by helicopter. Ban Birds Eye?

                • Thank you Martin.

                  Below is the dictionary definition of agriculture:

                  The science or practice of farming, including cultivation of the soil for the growing of crops and the rearing of animals to provide food, wool, and other products.

                  The products that are proposed to be harvested by being raised though the soil with the development remain relevant.

          • It will be much more rewarding to read what the cross-examination of Mr Gardner, UKOG’s expert landscape witness reveals later today. Than to be concerned over apparent wild speculations, wrong assumptions and ruffled feathers. Not to mention inadequate words.

            No beliefs required. Just facts not fantasies.

  4. Facts are not apparent, or assumptions. They are facts.

    [Edited by moderator]

    It will be the substance that determines this Appeal, not incorrect comments from the sidelines.

    I am more interested in how traffic levels that were recommended by Council officials as being okay-twice-will now be explained as not okay under cross-examination, together with whatever advice they gave behind the scenes previously, under cross-examination.

    But, good old UKOG, not seeking costs-at this moment. Protectors of the community!

  5. “But, good old UKOG, not seeking costs-at this moment. Protectors of the community!” = Oxymoron on steroids!

    • See what I mean, MH!

      I think you, and others, will remember the Wressle Enquiry, and the £400k cost to the local community. Fact.

      One of the comments for why that was ruled?

      “A transfer of production to a more local source.” Fact.

      Inconvenient, but both facts.

      • Ahh. The deafening silence of the cheerfulful pessimist.
        The sparklingly clear muddied water emerges and shines darkly in the light.
        Its said that you can tell whats being said, by understanding what is meant, rather than by just reading the words.
        An Oxymoron is, as Oxymoron does.
        For some, a way of life. For others an aspect to be recognised for what it is.
        A contradiction.
        A fantasy of opposites.
        An unreality in a real world of fake illusions.

        However, meanwhile back to reality. The Loxley/Dunsfold drilling inquiry continues today and the expert landscape witness Mr Will Gardner will be cross examined to find the truth. Perhaps much more reality will become apparent from what the cross examination will reveal. As I have said several times to little avail or compliance.

        But rather than wait for that, it appears that some would prefer to pre guess and pre judge the results. Amidst concerns over apparent wild speculations, wrong assumptions, oddly ruffled feathers and faulty oxymoron logic. However, I will wait for the truth to be revealed patiently to see what emerges. Others can speculate and pre judge as wildly as they wish, as I’m sure they will still do so yet.

        Its of no concern in the real world.

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