The operator of unlawful oil production at Horse Hill in Surrey has not given a date when equipment will be removed from the site. The company has also not acknowledged a formal request for more information on its operation.

Planning permission for the site near Horley was quashed by the Supreme Court more than 250 days ago in a landmark climate judgement.

The court ruled that the permission unlawfully failed to take account of greenhouse gas emissions from burning the Horse Hill oil.

The decision must now be reconsidered by Surrey County Council if Horse Hill is to continue production. But before that can happen Horse Hill Developments Limited (HHDL) must provide new information to officials. It must also revise the site’s environmental statement, a detailed assessment of environmental impacts.

The council sent the company a regulation 25 request for the information more than two months ago.

It emerged today that HHDL and its parent company, UK Oil & Gas plc (UKOG), have not responded to the request.

A meeting of Surrey’s planning committee heard that the companies have also not submitted a final date by which equipment would be cleared from Horse Hill.

The details emerged following questions from members of the public.

The committee meeting heard that the regulation 25 request had been sent on 18 December 2024.

Sian Saadeh, the council’s planning development manager, said:

“I have set out what I think is necessary to be included in a revised environmental statement to address the decision of the Supreme Court, as well as other matters that have changed, as guidance has changed over the years since the original determination.

“We have not had a formal response to that, though. I am seeking confirmation from the applicant’s agent as to when we will see that.”

The public will have a chance to comment on the information in a formal consultation. See the section, Information request, below for more on what HHDL/UKOG must provide.

Site clearance deadline

Ms Saadeh said the council had also asked the companies for their work programme to remove equipment from Horse Hill. She said:

“At this point in time, we do not have a final programme of work from UKOG.

“It is subject again to still ongoing discussion and we are seeking to understand the timeframe that they [the operating companies] are looking to work to and that will then inform what next steps we may or may not take.”

She added:

“It was made clear [to the site operator] from our monitoring officers that there is still an expectation that equipment is cleared from the site but there is no final date put to us by the applicant.”

Production continued

DrillOrDrop reported that oil production at Horse Hill continued after the Supreme Court ruling, despite the quashing of planning permission.

In October 2024, HHDL announced it was voluntarily stopping production. But DrillOrDrop reported official data which showed that oil extraction continued into November 2024.

Ms Saadeh said the operator had advised the council that “the site needed to enter a period of ‘minimum maintenance flow’”. She said:

“SCC [Surrey County Council] remained clear that the development at the site was unlawful and sought to engage with regulatory partners to interrogate the operator’s claims that the ‘minimum maintenance flow’ was necessary for safety reasons whilst they removed the development from the site.”

She said the discussions continued and the operators said the maintenance flow had stopped on 15th November 2024.

A site inspection on 28 November 2024 confirmed that extraction was no longer practically possible because the pump was not operating and the gas flare had been removed, Ms Saadeh said.

At a further site visit on 4 February 2025, officers were satisfied that production had stopped and the site continued to “move towards suspension”. Ms Saadeh said officials would continue to monitor Horse Hill. But she was unable to say what level of production had constituted ‘minimal maintenance flow’.

Information request

Oil production at Horse Hill got permission in September 2019.

The formal regulation 25 request from Surrey County Council confirmed that the original environmental statement must now be updated before planning permission could be reconsidered. The update must address the Supreme Court judgement and changes in guidance and best practice.

The key change is that there must be an estimate of greenhouse gas emissions from burning oil and gas extracted at Horse Hill.

The revision must estimate the maximum amount of crude oil and associated gas that could be extracted over the operational life of the Horse Hill well site. This will form the basis of a “worst case scenario assessment of the ghg [greenhouse gas] emissions linked to the project”, the council said. The letter added:

“It must be assumed that all extracted crude oil will be converted to fossil fuels and combusted.”

The revision should also include mitigation measures required or proposed to off-set emissions, the regulation 25 notice said.

Other details

The council also required the operator to review and update four other chapters of the environmental statement. Baseline information should be updated and the revision should take account of all relevant standards and good practice guidance on:

• Noise
• Surface and groundwater protection
• Traffic
• Lighting

The notice also required reviews and updates of previously submitted planning reports, dated November 2019, on:

• Air quality
• Landscape
• Ecology
• Trees
• Transport
• Major accident and disaster risk assessment
• Ground investigation report
• Waste management

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