We urge everyone to object it’s easy just click ‘Online Consultation’ here; https://consult.environment-agency.gov.uk/psc/rh6-0hn-horse-hill-developments-ltd/ (or search “EA Horse Hill permit”)
The consultation closes 21 April 2021.
Here are some sample points to get you started, pick a couple of points and then write your objections in your own words;
Gas flaring This amended application drops the previous commitment to produce electricity from the produced gas instead of flaring (wasting the gas). In ten months last year they flared 167 tonnes of gas. This application is for 4 new horizontal wells, each said to produce 3 times the output of the old vertical well. The UK has committed to the World Bank’s ‘Zero Routine Flaring by 2030’ initiative, it must make sense for the necessary capital investment for ‘gas -to-wire’ to be made at the beginning of the production phase.
Air quality: The proposed gas flaring will emit pollutants, which are likely to include particulates and sulphur- and chlorine-containing compounds, which are harmful to health. And because the Environmental Impact Assessment failed to assess the greenhouse gas emissions properly, the Environment Agency has no way of knowing how local air quality will be affected.
Seismicity: Reinjection is proven to cause earthquakes. While there is still debate over the cause of the Newdigate earthquake swarm, the case for employing the precautionary principle is obvious. Studies by structural geologists have shown that the local faults are critically stressed, and tiny changes in pressure are likely to cause earthquakes.
Wastewater reinjection: Formation water from oil wells can include chemicals harmful to human health such as benzene and naturally occurring radioactive material, and flowback may contain acid and chemical residues from the drilling process. There are only ancient, poor quality seismic surveys of the faults, which may be conduits for groundwater contamination. The planned wastewater reinjection well should not be permitted at Horse Hill.
Carbon emissions: The Environment Agency should require a full reassessment of the likely greenhouse gas emissions from operations at the site, the transportation of the oil from the site for the duration of its lifespan, as well as cumulative impacts of processing and burning the oil produced in the future.
Failure to regulate carbon emissions and seismicity: Weald Action Group has raised serious concerns about the failure of the regulatory process properly to assess and manage either the carbon emissions from the development or the risk of earthquakes. At present those two issues are falling between the regulators and the environment and the public are being put at risk.
Acid wash: HHDL considers that it does not require a groundwater permit. There is a loophole in our regulatory system which fails to distinguish between acid wash (a weak acid solution that cleans the well bore at low pressure) and stimulation (acid at higher pressure and often at higher concentration). A groundwater permit should be required at Horse Hill.
This production permit removes the previous limits for quantities of oil trucked off the site. This will add to noise and odour from additional traffic.
Water disposal from the well pad this application allows for well pad run off to be discharged into a tributary of Spencers Gill after passing through a simple oil-water separator, though 2 new outlets and during production activities.
Lack of clarity: Before any permit is granted, HHDL must provide up-to-date detailed contour maps and cross sections of the areas it proposes to drill through, including the paths of every well and sidetrack. New seismic analysis should be undertaken by HHDL to validate these, since previous plans for Horse Hill were proven to be outdated and inaccurate.
Abandonment: Oil wells continue to pose a risk to the environment and to human health long after they have been capped and abandoned. Unlike offshore wells, there is currently no legislation to ensure that abandoned onshore wells are monitored and managed as their subsurface infrastructure decay, releasing toxins and gas into strata and at the surface. The Environment Agency should clarify how the wells will be monitored and managed after the operator has left the site, and who will pay for any future clean-up work
Read more about the environmental permit application on Drill or Drop: drillordrop.com/2021/03/04/changes-sought-to-horse-hill-environmental-permit/
The planning permission for the expansion at Horse Hill is the subject of a legal challenge, which Horse Hill is supporting. It will be heard in the Appeal Court later this year.