We urge everyone to send a response to the Environment Agency’s consultation on the Horse Hill oil drilling site.

The site operator, Horse Hill Development Ltd (HHDL), has asked for changes to the environmental permit to allow them to drill and test four new oil wells, drill a water re-injection well and produce and store oil at the site.

They were granted planning permission in September (though this is currently subject to a legal challenge by campaigners).

HHDL also requires an environmental permit, issued by the Environment Agency, and the public consultation on this ends tomorrow. So far, objections are outweighed by 130 people who have written in support of the proposals (with messages like “I think on shore oil will be good for our country”)! We need to balance this out with some objections.

You can choose one or two topics that concern you the most and submit anything you can to support your point of view.  There are some suggested topics below.

How to object

• Find the online forms to submit here
• Email: PSCpublicresponse@environment-agency.gov.uk

Some topics you could mention

Unclear plans: HHDL talk about four wells and multiple sidetracks, which are set out in diagrams in the Waste Management Plan. But these aren’t accurate and without 3D seismic monitoring, which they have been asked to do but failed to carry out, there is no certainty about their plans. They show sidetracks going through the fault, yet we know that the faults aren’t accurately mapped. Drilling through a fault can lead to water pollution as well as destabilising the geology in an already unstable area. There should be proper mapping of faults and clear plans of wells and sidetracks in relation to the faults. The Environment Agency should make sure this information is available.

Water reinjection: They want to drill a new fluid reinjection well to inject ‘water’. But what returns to the surface is by no means ‘water’. What are the potential impacts on groundwater? Water reinjection has caused earthquakes in other countries. Horse Hill is already in an earthquake-prone zone. Damage has been caused to property and a lot of anxiety for local people. The permit should not allow anything that might trigger off more earthquakes.

Acidisation: The documents talk about hydrochloric acid being used in a 15% dilution, but not about the total volume of acid that will be used over the lifetime of the operations. What is the scale of the acid injection that is planned? You might want question whether HHDL proposed acidisation is a simple acid wash, as they say it is, or stimulation (out into the formation, at a certain pressure). Acid stimulation can cause groundwater pollution if wells are drilled through faults, or if wells fail. There may be difficulties in retrieving the oil, as happened at Broadford Bridge. The acid waste that is retrieved is toxic, not ‘like vinegar’, as the oil companies have told us. ‘Acid wash’ is greenwash – we need FULL details of their plans for this unconventional, extreme extraction method and for EA to monitor fracture pressure.

Gas flaring: There is a contradiction in the application documents over flaring. In the letter they refer to constant flaring through the series of extended well tests. The gas disposal document says flaring will be used only in an emergency. Which is correct, and what are the potential impacts on air quality and on the climate?

Air quality: Methane is both a local air pollutant as well as a potent greenhouse gas. It is not properly assessed in the documents provided by HHDL. We know that there can be significant methane emissions from the wells, oil storage and from gas flaring. Methane is typically under-estimated at onshore oil and gas sites, and is more from horizontal wells which are planned here. There have also been incidents at Horse Hill of local people and animals suffering breathing difficulties and bleeding from the nose, which may have been  caused by another chemical. And there is ancient woodland nearby which might be affected by poor air quality. We need proper data on the emissions to air.

Long-term management: What happens when the wells are abandoned: after the 25 year permission expires what will happen to the proposed complex network of wells and sidetracks? They will be capped, but who will monitor the integrity of the wells and pressure that might need to be released? Who pays for and carries out the long term safe monitoring and maintenance of the site?

How to find out more

• DrillOrDrop has an informative post about it here, including a handy list of points you could write about.
• Read a non-technical summary of the plans