The Weald Action Group has submitted a response to the Environment Agency’s consultation on the application by Horse Hill Developments Ltd to vary the environmental permit for their Horse Hill well site at Horse Hill, near Horley in Surrey.
In summary, we do not agree with the Environment Agency’s draft decision for the following reasons:
- The applicant has not demonstrated operator competency.
- The Cost Benefit Analysis of options within the Waste Gas Management Plan, which concludes that flaring is the ‘best available technique’ appears to use unrealistically low forecasts of gas volumes and out of date electricity and gas prices, hence undermining the case for gas to wire.
- We are aware of no new evidence in the form of recent seismic surveys etc. provided as part of Horse Hill Developments Ltd’s application. Hence there is no substantiated evidence that shows that existing geological faults will not become pathways of transmission for groundwater contamination.
- The regulatory process has to date failed to properly assess the risk of further seismic activity in the known critically stressed geological zone around Horse Hill. This is particularly worrying given that the Environment Agency is minded to approve water reinjection into two wells which could alter the pressure of the surrounding geology. Small pressure changes within critically stressed faults may be sufficient to trigger an earthquake.
- No volume cap and pressure limit regarding the use of acid at the site is currently proposed by the Environment Agency, risking that well stimulation may take place under the guise of acid washing.
- Six monthly monitoring of fugitive emissions will potentially allow leaks to go unnoticed and unaddressed for extensive periods of time, posing risks to public health and the wider environment.
The consultation is here: consult.environment-agency.gov.uk/psc/rh6-0rb-horse-hill-developments-ltd