Horse Hill: Environmental permit should be refused

The Weald Action Group has objected to the application by Horse Hill Developments Ltd (HHDL) to vary its permit for the Horse Hill oil production site in Surrey.

HHDL recently obtained planning permission allowing them to drill and test four new oil wells, drill a water reinjection well, and produce and store oil at the site (a decision that a local resident is seeking leave to challenge in a Judicial Review, with our support). But the operations must also be approved by the Environment Agency.

We argued that the permit application should be refused, as the development poses clear risks to the environment and to the local community, both now and in the long term.  Our objection covered:

  • Lack of clarity: Before any permit is granted, HHDL must provide detailed contour maps and cross sections of the areas it proposes to drill through, including the paths of every well and sidetrack.
  • 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 inserted at concentrations and pressure sufficient to fracture the rock). A groundwater permit should be required at Horse Hill.
  • 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 (eg by methane).
  • Seismicity: 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. Because this could pollute groundwater the EA should regulate this issue.
  • Waste water reinjection: Waste water reinjection is proven to cause earthquakes. Waste water from oil wells can include chemicals harmful to human health such as benzene and may contain naturally occurring radioactive material. The planned waste water reinjection well should not be permitted at Horse Hill.
  • Abandonment: Oil wells continue to pose a risk to the environment and to human health long after they have been capped and abandoned. The Environment Agency must 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.
  • Carbon emissions: The Environment Agency should require a full reassessment of the likely greenhouse gas emissions from operations at the site, as well as cumulative impacts of the oil produced.
  • Failure to regulate carbon emissions and seismicity: We also 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.

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Environment Agency consultation page

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