The previous planning permission for new infrastructure and oil production at Horse Hill was quashed by the Supreme Court in June 2024 following our five-year legal fight.
Now, two years later, the operator has submitted a new planning application. It again seeks permission for four new production wells (bringing the total to six), a new oil processing area, tanker loading facilities and a fluid reinjection well. The proposal would allow the extraction of more than 600,000 tonnes of oil over 20 years.
They have also submitted a new climate assessment. It was their failure to properly assess the project’s climate impacts that led to the previous planning permission being quashed. This new assessment estimates the project would result in more than 2 million tonnes of greenhouse gas emissions over its lifetime, yet they claim these emissions would be “not significant” for the climate.
Climate assessment has serious shortcomings
We have analysed the chapter on Greenhouse Gas Emissions & Climate Change in the new Environmental Information – and found that it is flawed in multiple ways. For example:
- The technical competency of the consultant who prepared the assessment of climate significance is in question.
- The assessment of significance does not comply with the new government supplementary guidance for assessing the effects of downstream scope 3 emissions on climate from offshore oil and gas projects published as a result of our Supreme Court win. Though written for offshore projects, this guidance is widely accepted as being equally relevant for onshore projects like Horse Hill. Nor does it comply with the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 or the Institute of Sustainability & Environmental Professionals’ Guide to Assessing Greenhouse Gas Emissions and Evaluating their Significance 2026.
- It fails to describe the current dire state of the climate. Scientists have forecast that the maximum amount of carbon we can emit and stay within the legal 1.5 °C temperature limit is 130–170 gigatonnes of CO2, which will be breached in just a few years. And it fails to assess the actual effects of the scope 3 greenhouse gas emissions on, for example, human health and biodiversity, as required by the Environmental Impact Assessment Regulations.
- It contains multiple errors, plus misleading and irrelevant information about projected UK oil production and demand, and global energy and climate model scenarios.
- It makes unfounded claims that oil from Horse Hill will remain in the UK, even though more than 80% of domestically produced oil and gas is exported. (In 2024 92% of UK oil was exported.)
- It fails to place Horse Hill’s greenhouse gas emissions within a global cumulative context of all current and approved fossil fuel projects. In 2022, scientists writing in Environmental Research Letters journal forecast that the emissions from these projects equate to 936 gigatonnes of CO2.
As a result of these and other failings, the applicant concludes that the emissions from Horse Hill are ‘not significant’ for the climate. We strongly disagree.
Read our submission in full here: WAG Horse Hill Scope 3 submission
Kirsty Clough of the Weald Action Group said, “The oil company’s assessment of greenhouse gas emissions and climate impacts is fundamentally flawed. Had they done the job properly, they could not have avoided concluding that the effects on the climate would be highly significant. The Council cannot grant permission on the basis of such a deficient assessment.”
Have your say
Although the formal consultation by Surrey County Council (SCC) on the Horse Hill application closed on 13 July, the Council has confirmed they will assess all submissions received before the planning decision date.
You can respond directly via the website here ‘or via email to: mwcd@surreycc.gov.uk quoting ‘SCC_Ref_2018/0152 / RE18/02667/CON’, and importantly include your name and address. You can request to redact your address.
Read our suggestions on how to respond
The Weald Action Group will be submitting further objections, including on the issue of seismicity and earthquake risk. Watch this space.