Horse Hill oil expansion plans are back! Have your say

Following our Supreme Court victory with the ‘Finch’ Judgment in 2024, the 2019 planning permission for the expanded oil production and development at Horse Hill was quashed. The oil company, Horse Hill Developments Ltd (HHDL)*, has now submitted a revised application, including a new climate assessment.

Although the formal consultation by Surrey County Council (SCC) closed on 13 July, they are still accepting objections and have confirmed to us that they will assess all submissions received before the planning decision date. The earliest Planning Committee meeting which could discuss this application is September, so please don’t assume it’s too late to respond.

You can respond directly via the website here ‘Comment on this application’ or via email to: mwcd@surreycc.gov.uk quoting ‘SCC_Ref_2018/0152 / RE18/02667/CON’, and importantly include your name and address.  Your name and address will not be displayed on the Council’s website.

Every individual objection helps demonstrate the level of public concern so it is important that SCC receive many objections in people’s own words, and that you respond as soon as possible.

There are 61 new documents on the SCC Planning Portal, but the main ones to read if you want to delve into the detail are the two documents titled ‘Horse Hill Further Environmental Information (2026) Part 1_redacted’ and ‘Horse Hill Further Environmental Information (2026)’ Part 2_redacted’. If you just want an overview, read the ‘Horse Hill Non-Technical Summary (2026)_redacted‘.

Included below are some pointers of the type of information you can include in your objection. You don’t need to cover every point, just pick the issues that matter most to you, as a few well-written paragraphs in your own words are valuable:

Climate Change: The original planning permission was quashed because the climate impacts of burning the oil weren’t properly considered. The applicant has now included those emissions in its new climate assessment, estimating that the proposed development would result in around 2.3 million tonnes of greenhouse gas emissions over its lifetime. However, they still conclude these emissions are “not significant”. But Horse Hill should not be looked at in isolation. Its emissions add to those from existing and approved fossil fuel projects around the world, which together exceed what we can afford to emit if we are to have the remotest chance of stopping catastrophic climate change. EVERY new fossil fuel development makes the climate crisis worse. We should be urgently accelerating the transition to homegrown clean energy, not wasting our time fighting fossil fuel proposals. 

Earthquake Risk: The Newdigate earthquake swarm in 2018 near the existing Horse Hill wellsite saw more than 100 earthquakes, including one of magnitude 3.18. A 2025 peer-reviewed study by Dr Matthew Fox concluded that the earthquakes may have been triggered by oil extraction at Horse Hill. Professor Stuart Haszeldine has since concluded there is now a substantial body of evidence linking Horse Hill operations to the earthquake sequence and that seismic risks cannot be ruled out.

SCC states that seismicity is the responsibility of the North Sea Transition Authority (NSTA). However, national planning guidance does not remove the Council’s responsibility. Before granting planning permission, Surrey County Council must be satisfied, having taken advice from the NSTA, that seismic risks can or will be properly addressed. 

Furthermore, it is clear that the wellsite now sits within a seismically active zone regardless of whether activity at Horse Hill caused the original earthquakes in 2018 or not, and this issue deserves careful scrutiny.

Energy Security: Horse Hill will not enhance our energy security as most of the UK’s oil and gas is sold on the open international market to the highest bidder. The applicant repeatedly claims that the oil produced at HH will reduce the need for imports, yet previous bulletins from HHDL/UKOG show that it is taken by road to the BP Hamble terminal, from where crude oil is exported by sea. 2024 figures show 92% of our domestic oil production was exported.

Gas to Grid: HHDL say they will use the gas produced to generate electricity for the site. They made the same claim in the 2018 application but after receiving planning permission, they abandoned this plan and were given permission to flare (burn) up to ten tonnes of gas a day – highly polluting and a waste of this non-renewable resource. This shows they can’t be trusted. If this polluting project is approved, it should be a pre-condition that the developer has gas capture infrastructure up and running before the site becomes fully operational.

Methane Emissions: Independent infrared camera surveys in 2021 detected methane and other hydrocarbon gas emissions from multiple sources at Horse Hill despite the infrastructure being in place for less than two years. Given methane’s powerful global warming effect, and local health impacts, this raises concerns about expanding oil production at the site. Will the applicant guarantee regular independent monitoring?

Financial Assessment/Bond for Site Restoration: The NSTA’s own financial guidance (Section 1.6 of Financial Guidance) is explicit that its assessments of an operator are not a substitute for financial due diligence by Mineral Planning Authorities. Considering the developer, Energy b’s, reported financial losses and their Auditor’s concern on the group’s ability to continue as a going concern (see * below), SCC should carry out its own assessment of financial risk, and whether restoration liabilities should be properly secured. National planning policy allows for this where there are exceptional cases that restoration may not be delivered. Clearly this is a risk given the operator’s previous accounts and history plus the industry’s poor track record of delayed or incomplete site restoration overall.

Precautionary Principle: Where there is uncertainty about the risks of a development, planning decisions should err on the side of caution. Significant concerns remain about the competency of the consultant who wrote the 2026 Environment Statement, the seismicity risks, and the climate impacts of methane emissions and scope 3 greenhouse gas emissions. Given the oil and gas industry’s record of regulatory breaches, unplanned emissions and permit non-compliance, Surrey County Council should apply the precautionary principle and refuse planning permission.

*Note that the company behind HHDL is no longer UK Oil & Gas (UKOG). They sold their stake in the project to new operator, energy b. However, they aren’t new to us – Energy b’s Board Chair, David Lenigas, and CEO, Neil Ritson, have been previously involved in Horse Hill. Lenigas was chairman of UKOG up to 2015, and Ritson was CEO of Solo Oil, which also had interests in Horse Hill until 2018. They are a relatively new company with limited operating history as an oil producer and a history of recurring financial losses. A recent auditor’s opinion cast significant doubt on the group’s ability to continue as a going concern.

We hope you take the time to speak up, and voice your objection. Every single objection helps show Surrey County Council that local communities continue to oppose the expansion of oil production at Horse Hill.

The Weald Action Group will be submitting detailed technical and legal objections, and will share those on this website.