Markwells Wood, is a designated ancient woodland in the South Downs National Park. An exploratory well was drilled there in 2010 but has since been abandoned leaving an ugly collection of industrial debris in the midst of beautiful mature woodland. UK Oil & Gas (UKOG) have applied for four additional wells, including a water injection well and a side-track well, to drill and to produce oil for 20 years. The proposed method of drilling involves the injection of acid, chemicals and water (acidisation) under pressure through the underground layers of chalk, into the limestone below.
There are huge concerns about the proximity of the Aquifers to the Havant and Bedhampton Springs, which are important sources of drinking water for Portsmouth. UKOG claim that the dangers to the water supply would be ‘negligible’. The South Downs National Park Authority (SDNPA) requested more detailed information about the water, traffic, ecology, noise, etc and UKOG have submitted a revised application; a decision from WSCC is expected in April 2017.
UK Oil and Gas Investments (UKOG) submitted 22 additional documents in early March to support its planning application including their hydrogeological report, revised transport statement, report on emissions, light, noise and ecology.
This was in response to a request by the South Downs National Park Authority for more information about various impacts of the scheme. Details of the revised application have just been made available and new objections can be submitted until 10 May 2017. Members of the public can inspect copies of the application (SDNP/16/04679/CM). The planning officer would like comments lodged by April 6 but will accept objections up to the decision day on May 11th.
Anyone wishing to make representations about this application should do so on-line from the website http://planningpublicaccess.southdowns.gov.uk/online-appli…/, or by email or in writing to the address details given below, quoting the case reference SDNP/16/04679/CM.
Please see the amended Air Quality Assessment (submitted 06.03.17), Transport Statement (submitted 06.03.17) and Environment Statement (various uploads submitted 06.03.17)
Thank you to everyone who have already objected to the application f you object again this won't supersede any of the points raised in your original objection. All of your objections will be carried forward, but you have the right to object to the further information UKOG submitted on 6 March.
Here you will find Emily Mott from Markwells Wood's full objection.
Markwells Wood Watch fundraised £3500 for their own independent commissioning of a hydrogeological report. Hydro-geologist, Dr. Aidan Foley, eviscerates UKOG’s Groundwater Risk Assessment:
"Lack of conceptual rigour is demonstrated throughout the Envireau Water (2017) report. The report contains gross factual errors and misinterpretations of basic sources of information”.
They also have a petition which has reached over 1,000 signatures. Please sign and share in your networks.
Further info: http://www.markwellswoodwatch.org/
Four Lessons From the U.S. for Countries About to be Fracked:
1. Fracking Companies have Systematically Run Over Communities in the U.S.
2. Fracking Contaminates Water and Water Wells and Can Suck Entire Towns Dry.
3. In Spite of Industry Claims, They Can’t Predict Exactly What Will Happen Underground During Fracking.
4. Fracking Leaks Methane and Other Dangerous Chemicals Into the Atmosphere at Alarming Rates.
THIS HAS NOW CLOSED
Mon 13th March 5pm: Help stop oil drilling and fracking in West Sussex and the South Downs National Park
There is less than 24 hours left for you to have your say on new policies that will affect oil drilling in Sussex for the next 15 years.
Beautiful parts of our Sussex countryside are at risk of being drilled like a Swiss cheese to extract oil. West Sussex Council and the South Downs National Park have drafted new policies to guide decisions on future fracking and other oil drilling operations.
This is your chance to have a say on the policies that decision makers must follow.
There’s very little time left - the consultation closes 5pm March 13th
So send in your comments now. We’ve suggested a response below, but please try and use your own words for an even bigger impact.
The draft plan fails to:
- reduce climate changing emissions
- protect the South Downs National Park and other areas from oil exploration
- fully consider the risks of all types of testing and extraction techniques
- take on board local people’s concerns about the impacts of oil exploration, including landscape, transport, air and water quality
DRAFT EMAIL - PLEASE UPDATE IF YOU CAN. THIS WILL HAVE GREATER IMPACT. YOU CAN GET MORE NOTES AND INFO HERE UNDER 'OBJECTIONS'
Dear Minerals Plan team,
WSCC/SDNPA Minerals Plan consultation
I object to the draft minerals plan as it is not sound or robust. The minerals plan needs to govern all types of drilling and extraction techniques. It should also contribute to a reduction in climate change emissions.
There are policies for fracking and non-fracking developments, but these still allow fracking under the South Downs National Park. (1) The policies should presume against fracking in and under the National Park whether there is a national need or not.
The policies should also cover the process of “acidising” where acid and other chemicals are used in horizontal wells to extract ‘difficult to reach’ oil deposits.(2) There is a lack of evidence showing the impacts of acidising on the environment and communities (3) and therefore the precautionary principle should apply and these operations should not be allowed in the National Park or elsewhere in West Sussex.
I am also concerned about the cumulative impacts of oil exploration due to the unknown impacts of fracking and acidising. There has been little, if any, monitoring of impacts to water, soil and air quality from existing oil operations, nor of indirect impacts.(4) I therefore believe that a precautionary approach should be taken in all relevant policies.
The policies as a whole also fail to respond adequately to climate change, and do not include measures to address the extraction and burning of fossil fuels, nor methane leakage.
In order to safeguard our countryside, and in particular our most cherished areas such as the South Downs and Areas of Outstanding Natural Beauty, it is important that the plan is amended. It is my view that the draft policies do not appear legally compliant and are unsound due to:
- not fully addressing climate change
- not adequately covering exploration and production that uses acidising, horizontal drilling techniques and reinjection of fluid wastes underground.
- allowing fracking under protected areas and significant oil and gas operations within protected areas
- not providing a precautionary approach in respect of unknown water and air quality impacts.
I object to the following policies for the above reasons:
- M7a Hydrocarbon development not involving hydraulic fracturing;
- M7b Hydrocarbon development involving hydraulic fracturing;
- M23 Design and operation of minerals developments;
- M17 Biodiversity and Geodiversity; and
- M22 Cumulative Impact
ADDRESS (important to include to validate your response)
- Acidising is when acids and other chemicals are pumped into a well to improve productivity. In matrix acidizing, the acid treatment is injected below the rock fracturing pressure. In fracture acidising, acid is pumped above the fracturing pressure. Acidizing - Treatment in Oil and Gas Operators. Briefing paper. American Petroleum Institute (API) 2014. http://www.api.org/~/media/files/oil-and-natural-gas/hydraulic-fracturing/acidizing-oil-natural-gas-briefing-paper-v2.pdf
- Abdullah et al., 2017. Toxicity of acidization fluids used in California oil exploration. Toxicological & Environmental Chemistry, 99(1), 78-94. http://dx.doi.org/10.1080/02772248.2016.1160285
- It appears that the Environment Agency has exercised little oversight of acidising operations in the past, relying on self reporting by oil production companies due to the way the permit system worked. Responses to Freedom of Information Act questions indicate there is no monitoring data available regarding historic chemical use in sites where acidising has been used in West Sussex.
Objection Guidelines to Env Agency re Broadford Bridge, nr Billingshurst
TAKING THE CON OUT OF CONVENTIONAL
Please object to the Environment Agency planning variation request by Kimmeridge Oil and Gas Limited (KOGL), subsidiary of UK Oil and Gas, license holders of Broadford Bridge site, Adversane Lane, RH14 9EB.
BY APRIL 13TH - please write a short letter of objection, just a paragraph or two, including your name and address, to KOGL’s permit variation to acidise the well at the Broadford Bridge site. Have a look at other responses already on the site as examples. If you don’t want your name and address made public be sure to state that in your response.
Kimmeridge Oil and Gas Ltd, subsidiary of UKOG – the company that is planning to EXPLORE for oil has applied to the Environment Agency (EA) for a variation on their environment permit for their Broadford Bridge site, West Sussex.
Originally planning permission was given to the PEDL 234 predecessor, Celtique Energie in Feb 2013 and that company gave local Planning Department, Parish and District Councils assurance that:
“…..Celtique Energie Weald Ltd would use conventional rather than unconventional drilling methods at this site should planning permission be granted.
“The target reservoir for Celtique Energie’s well at Broadford Bridge is (was) the Triassic sandstone. This is a conventional (non-shale) reservoir anticipated to contain gas, and the rock is sufficiently permeable that gas should flow naturally into the well from the reservoir when produced. Therefore Celtique Energie can guarantee that it will not be using hydraulic fracturing on this well.” Letter sent to WSCC Planning Dept, 5/10/2012):
KOGL plan to target 'tight oil', an UNCONVENTIONAL resource in the Kimmeridge limestone using a different UNCONVENTIONAL method – ACIDISATION – with less pressure but with other impacts, which haven’t been assessed
We only learned this from UKOG accounts in February 2017 where they said: “Our prime focus is upon a new type of oil deposit within Kimmeridge Limestone rocks which we are pushing towards commercial production…
“UKOG's overall exploration and appraisal strategy is geared towards oil extraction from previously unrecognised naturally-fractured rocks within the Weald and the Purbeck-Wight Basins of southern England…”
“Importantly, the licence acquisition included the existing Broadford Bridge well pad, planning permission and EA consent to drill the Broadford Bridge-1 ("BB-1") exploratory well.
“The BB-1 well, planned for Q2 2017, will be a deviated or "slant" well, designed to penetrate the entire Kimmeridge section, targeting the four naturally-fractured Kimmeridge Limestones (KL1-KL4) to confirm that KL oil is contained within a resource or continuous oil deposit.”
Our concerns are:
- Chemical use is greater in acidisation than in hydraulic fracking.
- Solid and liquid waste will be toxic, highly saline and radioactive, a risk to groundwater, surface water and soil should accidents occur.
- The EA Midlands office stated that there are no suitable disposal facilities in southern England.
- The risk of spills and other accidents.
- Wells may be acidised repeatedly and there is little research on the subject of repeated acidisation. The cumulative effect on our environment and human health
- Lack of public consultation.
- Absence of discussion of these issues in the Environmental Statement originally submitted by Celtique Energie.
Lack of information provided:
FAULTS: The Weald is very faulted. Faults are complex and unpredictable in their hydrogeological behaviour and should be regarded as leaky. The site is situated near a fault which could take liquids to the River Arun.
SUBSURFACE KNOWLEDGE: Natural Environment Research Council is setting up a research project The Energy Security and Innovation Observing System for the Subsurface (ESIOS) capital project. “The research aims to understand how the underground environment could respond to disturbance caused […]by unconventional oil and gas” “there isan urgent need for an improved evidence base to inform decision making by government, industry and civil society”. It will start early 2017. So, still no answers to all those sub-surface issues.
Sounds like KOGL is trying to pull the wool over people’s eyes!
Help us object to these proposed changes by filling in the forms here:
Act now! Help stop Cuadrilla coming back to Balcombe
Deadline midnight April 25th!
Cuadrilla has applied to make changes to its Environmental Permit, an important element of its planning permission at Balcombe. Please write a personal objection to the Environment Agency’s consultation. The more objections they receive, the stronger our voice.
Although for the moment Cuadrilla says it has no intention to frack, Lower Stumble would be no simple little free-flowing well with a nodding donkey. Cuadrilla would acidise, a sister process of fracking raising similar serious concerns.
It’s easy to object, on-line or by letter. It need take only a few minutes. Even if your objection is very brief, it is important to give the industry (and the Environment Agency, and local government) an idea of strength of feeling against this work.
What is wrong with Cuadrilla’s application?
Of course we do not want Cuadrilla here at all. Balcombe do not want HEAVY INDUSTRY in their village, and the TRAFFIC it will bring, not to mention the RISK to our HEALTH and ENVIRONMENT. Balcombe would be a ‘foot in the door’ for the industry, who would need A GREAT MANY WELLS across the Weald to access the unyielding rocks they are now targeting.
But arguments that will carry weight with the Environment Agency relate specifically to the changes Cuadrilla now wants to make. You could pick out just one of the following three issues for a short objection, or cover all three, or you could read the ‘further information’ at the end of this email (or even Cuadrilla’s 94 pages of documents!) and give a more detailed response.
These are the changes:
> A new flare
Cuadrilla have designed a new 45ft (nearly 14m) flare to burn off unwanted gas. But a study of the probable emissions from this new flare is missing from the documents. Cuadrilla should be asked to provide such a study. Flares are extremely noisy and give off serious pollutants. This flare is only 500m away and upwind of many residents. The top of this flare, like the one previously proposed, would be lower than the centre of the village, because Lower Stumble lies down in a dip. A study on pollution from the new flare is missing from the documents. The new flare, burning at a higher temperature will mean increased levels of NOx (which is causing such problems for inner city air at the moment). Also, Cuadrilla’s original application was based on the wrong assumption that no sulphur compounds would be present in the oil here – even though sulphur compounds were found when a well was drilled on the site in 1986. Public Health England said in 2014 that Cuadrilla should address the risk to the community from toxic sulphur dioxide from the flare. They have not done so. Public Health England were critical of Cuadrilla's lack of complete air study data in the previous application. As we know, Cuadrilla lost air samples when they drilled the well. It is vital to have up-to-date, complete information on air pollution.
> Waste water
The waste water flowing back from the well would be extremely salty, and could contain radioactive and toxic substances, a mix of the original chemicals used (far more than 'just' hydrochoric acid), the products of their reactions underground, and substances leached out from the rocks. Cuadrilla says the ‘salty water’ flowing back would be ‘low risk’ and ‘non-hazardous’. Yet this waste water will contain much more than common salt. No one can tell beforehand the composition of the waste liquid . Cuadrilla admits in the documents that the composition of the liquid waste will change over time. The Environment Agency is allowing Cuadrilla to declare that the liquid waste will be 'non-hazardous'. Cuadrilla's old permit included a 'mining waste facility', allowing Cuadrilla to leave liquids in the ground. Cuadrilla now say they do not need this mining waste facility. They say they will get back all the waste and deal with it at the surface and they do not intend to leave any waste underground. This is not possible. The EA has admitted there is a hydraulic link between lower stumble and Ardingly reservoir which provides water for thousands, therefore this mining fluid should be very closely scrutinised.
Cuadrilla have proposed new yet still inadequate methods for monitoring air, ground and surface water. There should be many more collection points for samples, and sampling should be done continuously, rather than the spot checks that are proposed. For instance, it is proposed that laser monitors to check for escaping methane would be used only on two occasions during testing, for ‘up to eight hours’ – so a few minutes’ use would count! We believe continuous monitoring should be carried out by an independent body (such as the EA), not just by the company itself.
A couple of important ‘don'ts’
> Don’t mention the F word! At this point in the exercise (testing the well, by acidising) Cuadrilla do not need to frack. Mentioning fracking may make the Environment Agency believe that you don’t understand the issues, and they may discount your objection.
> Don’t fill in the ‘Organisation’ box – leave it blank.
What you can do to strengthen our case:
> Write it in your own words. If the Environment Agency thinks you are simply copying a template objection, they may count all such objections as one. Read the simple guidance above, then put this leaflet aside and don’t peek at it too much as you write!
> Give your objection some local and personal colour. If you are connected to the village, tell the Environment Agency, for example, ‘My granddaughter is at Barn Meadow Nursery School in Balcombe village and I am concerned because the top of the flare is below the level of the school so that the lie of the land and the prevailing wind would carry pollutants towards the school.’
> Get your friends and family to respond – they don’t need to live locally.
Respond on line by midnight April 25th!
Or write to: Permitting Support Centre, Quadrant 2, 99 Parkway Avenue, Parkway Business Park, Sheffield, S9 4WF
Some Background on Acidisation:
The industry is hiding behind the idea that it is 'not fracking' to get its drills in the ground. Remember the government changed the definition of fracking in 2014 to be determined not by pressure but by volume of water used. The target in the Weald is what the industry has traditionally termed 'tight oil', and we know that Stephen Sanderson, CEO of UKOG, has said that 'this type of oil deposit very much depends on being able to drill your wells almost back to back, so it becomes very much like an industrialised process. You have to drill a lot of wells close to each other so that you can maintain a certain level of production'. Acidisation still needs multi-well pads, multiple underground horizontal sidetracks, multiple flaring sites, and heavy traffic. Combined with this are the issues of how to deal with the toxic produced water from the well, the possibility of this fluid travelling through our multi-faulted Weald geology (the EA have admitted there is a hydraulic link between Lower Stumble and the Ardingly reservoir) and the increased risks of seismicity. But because this work is not afforded the same 'protections' as high-volume slick water hydraulic fracturing, it will be much easier to get the work going. Balcombe is one of numerous other sites in the Weald and we need to anticipate the effects of these wells.
There are many reasons to try and stop the industry getting started, before we even bring in considerations of our climate change obligations.
To retain its current PEDL (Petroleum Exploration and Development Licence) Cuadrilla will need to drill and flow-test this well and drill another one in the same PEDL area by 2019. For those living nearby, the suspicion is that if this next well is not in Balcombe it might possibly be at Bolney as there is a previous well site there already.
Read Ruth Hayhurst’s summary of Cuadrilla’s application on the excellent website Drill or Drop: