Horse Hill: Respond to Environment Agency consultation by Monday 25 November

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

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

5 Responses

  1. Hilary Harris says:

    I am totally opposed to this application. We are in a climate emergency when we need to be transitioning from fossil fuels to renewable energy if we are to avoid an increase in extreme weather events and a global catastrophe. We cannot safely burn the fossil fuel reserves we already have so drilling for more is so totally irresponsible.

  2. Caroline Dooey says:

    We have to stop this madness, what future are we giving our children

  3. Caroline Dooey says:

    We have to stop this madness, what future are we giving our children and future generation s

  4. Deborah Flatt says:

    I am most concerned about the potential for methane emissions from the drilling when we are so far short of targets for carbon and other greenhouse gas emissions. We have NO TIME or justification for mining more fossil fuels. All efforts must go towards reducing emissions. There is a race against time and this project is going in completely the wrong direction. I would even say it is insanity in the light of all the recent scientific evidence. It needs to be halted immediately.

  5. Graham Dadd says:

    Surely known oil reserves are more than adequate to meet our needs as we progress towards a carbon free future. How can Surrey County Council declare a climate emergency and then support this application? Besides the emissions of green house gasses this oil exploitation is liable to lead to, the proposal appears to be poorly researched and if the programme does go ahead there is a strong risk of environmental damage through quakes and ground water contamination. Leave the resource where it is. Future technology developments may well materialise to enable it to be exploited in a much less damaging way.

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