How Do I Reply?
You can reply online here in a very simple process that just requires you to submit your name, email address and comments. Alternatively you can send an email a email with subject Application No: EPR/YP3735YK/A001 to pscpublicresponse@environment-agency.gov.uk
When Does The Consultation Close?
The consultation closes on 16th May.
Do You Have A Summary Of The Key Issues?
There is an excellent summary on Drill Or Drop here.
In addition you may want to consider some of the following points. N.B. To get your voice heard properly, it is much more effective to please makes sure you express the issues which concern you the most using your own words.
1. Concerning Water Risk
The EA’s water safeguard zone and water catchment area maps show that the proposed drilling site is located directly next to a Surface Water Safeguard Zone and in the catchment area of the Pipp Brook directly upstream of a Groundwater Safeguard Zone. The potential impact of this location to the local drinking water supply has already been previously highlighted by Sutton and East Surrey Water.
In the supplied Environmental Risk Assessment, the applicant identifies a number of Possible Sources of Accident with consequences of polluting the groundwater or surface water. They then claim that the overall risk is low providing the correct management techniques are followed. On this basis plus the related information supplied in their Waste Management Plan, they propose that they should be exempt from needing a groundwater permit. However:
- Even if the probability of an accident is low providing the correct management techniques are followed, given the proximity of the water safeguard zones then the impact of any such incident will be very large. There is no way the overall risk can be classified as low as a result.
- No consideration is given to accidents relating to a failure to follow correct management techniques. What secondary measures are being implemented to reduce impact in the instance something does go wrong?
- Given this is exploratory drilling, what safeguards are being employed to mitigate any possibility of ‘accidental’ horizontal drilling from the drill pad on the edge of the water safeguard zones into the actual safeguard zone?
- There is no indication of linked and/or compound risks in the Risk Assessment. Clearly the risks are not all completely independent. How is the risk of a contamination incident increased by fire for example, which might lead to a seal failure and pipe rupture?
- The high/medium/low risk classification is a subjective oversimplification that is clearly being misapplied in this application: the argument put forwards in the generic risk assessment table that the groundwater risk should only be classified as medium because it is not as severe as the surface water risk is nonsensical. Both risks are obviously high, it is just that one is larger than the other. A more quantitative approach would have avoided such problems and enabled a much more accurate risk profile to be described.
- Only short-term risks resulting from failures of storage tanks or pipe ruptures are considered. What about the risks from well casing failures? There there have been many instances of boreholes failing and becoming conduits of water contamination (see here, here and here). In the longer term these represent a greater risk than storage tanks rupture, but they are not mentioned at all.
- Many of the water risks identified in the risk assessment are examples of low probability, high impact risks which are notoriously difficult to manage effectively. Generally, a strategy of prevention/avoidance is the only truly safe policy. Given the fact that this well is likely to have a very limited lifespan anyway due to the ever increasing threat from climate change (on which point, the glaring omission in the applicant’s Global Warming Potential section is the product they are actually drilling), and abandoning the well will then only increase the risk of future contamination incidents, the only reasonable and rationally defensible strategy is most obviously not to drill for oil in this location.
- In the Waste Management Plan, the applicant is requesting exemption from having to apply for groundwater permit on the basis that the quantity of the acidisation pollutant would be small. However, the applicant only specifies the volume of acid per foot. What is the total volume they will be using? Also what about the other chemicals such as the anti corrosives, surfactants and demulsifiers used in the acidisation process? These are also clearly contamination sources.
- What is the limit of the applicant's liability insurance? Has the applicant sourced independent estimates of the clean-up costs of each risk identified in their Risk Assessment? Do any of these exceed their liability limit? In the instance that the applicant decided to cease trading following a contamindation incident, what insurances would remain in place and for how long?
2. Concerning Waste Management
The application uses the term ‘acid squeeze’. Assume this is in fact matrix acidisation, then the application should be amended to use standard industry terminology in the interests of clarity and transparency. Given the increasing regulation such techniques are being subjected to in other territories where they have not already been banned outright, this technique should not be allowed in the UK until a full impact assessment has been performed and regulatory guidance has been published.
- What happens to the spent hydrochloric acid solution once it has been used to clean out the geological fractures? How is this monitored, and how visible are the test results to the public?
- Hot oil will be pumped into the well to 'remove paraffin precipitates': What happens to the 'paraffin precipitates'? How is this monitored, and how visible are the test results to the public?
- Oil-containing drilling muds, Oil-containing rock cuttings: What happens to them? How is this monitored, and how visible are the test results to the public?
- Hazardous run-off water: How is this monitored, and how visible are the test results to the public?
- Radioactive materials: 'radioactive materials' are not all unnatural. Many shales are naturally radioactive due to the potassium isotopes in clays, as well as adsorbed uranium, radium, polonium and thorium. How will the applicant handle the processing of any naturally occurring and equally hazardous radioactive materials discovered during the exploratory drilling.
3. Concerning Local Authority Planning Permits
- On page 4 of the Site Condition Report, the site footprint is stated as being 0.79 hectares. This is incorrect. The site is now in fact 1.01 hectares, as the applicant has extended the site footprint by 28% as part of a subsequent security fencing application that has been submitted to Surrey County Council. Ref: 2016/0170 http://planning.surreycc.gov.uk/planappdisp.aspx?AppNo=SCC%20Ref%202016/0170
- On page 19 of Site Condition Report, the applicant claims that no baseline monitoring can be performed until the start of operations. This is incorrect: on 21st October last year they were granted planning permission to commence baseline testing: https://planning.surreycc.gov.uk/planappdisp.aspx?AppNo=SCC%20Ref%202016/0151
- Also, the applicant has a farm-out deal for this site with Angus Energy who are currently contesting with Surrey County Council a possible breach of planning regulations at their Brockham site. No environmental permit should be granted until the outcome of that case in known, as a confirmed breach will significantly undermine the applicant’s claims to follow industry best practice on which much of its risk mitigation plan depends.