Dear Sirs,
Planning ref: SCC Ref 2021/0165: MO/2021/2103: Angus Energy: Felton’s Farm, Brockham.
I am writing to convey Dorking Climate Emergency’s opposition to the above planning proposal on the following grounds:
- Climate Emergency: the government and Surrey County Council have declared a Climate Emergency, with the clear aim of achieving carbon neutrality by 2050. It contravenes all the principles of this to permit further oil extraction. The well in question (BRX4) is not at present in production and has not been for some time.
- The validity of their proposal. I) The history of oil production at Brockham is complex. Production was always from the Portland Sandstone, with later ventures into the deeper Kimmeridge via sidetrack BRX 4Z. However, one feature of oil production both at Brockham and other Wealden sites, is water incursion. This was pointed out as long ago as 2006 and disposal of surplus water has always been a major problem where water production has often exceeded that of oil by a large amount. The situation has not changed. How will this be dealt with? Will it be re-injected or sent for decontamination?
ii)Although their proposal is filled with details of how AE will comply with various rules and regulations, this vital aspect of how they will cope with surplus water has been omitted. They do not at present have Environment Agency (EA) permission to use BRX-3 for re-injection (see 3 iii) and iv)) as they provided insufficient information about the well’s integrity (see 4ii)).
iii) the future viability of Portland Sandstone: Application Variation 200825__422_07154_00002_Brockham_Inject_Issue_Rev_06.pdf (environment-agency.gov.uk) page 5: “The field discovery well, Brockham-1 (BRX-1) was drilled by British Petroleum (BP) during 1987 and found oil in the Portland Sandstone while drilling through to the primary objective in the Great Oolite Limestone. Since this discovery, the Brockham field has produced approximately 490,000 bbls of fluid (78,400m3 ) in primary recovery mode, resulting in recovery of between 5% and 10% of oil initially in place (OIIP). Brockham is now close to the end of that phase with current recovery of around 8% OIIP. The reservoir pressure has dropped by circa 500 pounds per square inch (psi), which represents a major reduction in reservoir energy. At current reservoir pressure production is only viable for a very limited period of time.” Dated August 2020.
- The integrity and professionalism of Angus Energy. This saga since 2017 at Brockham involves: i) drilling a sidetrack well to BRX4 (BRX4Z) in 2017 without the knowledge or permission of SCC and when directly advised by them (twice) that this was not permitted development. ii) working out of hours for 9 nights (including a weekend) in 2017 for reasons which still remain unclear as none of the regulatory bodies appear to have taken responsibility for this (refs: private correspondence). iii)Despite repeated requests from the Environment Agency, not providing essential information to back up their proposal for water re-injection at Brockham via XR-3 in Nov. 2018. (Page 9, 233_08_SD50 Decision document new bespoke (publishing.service.gov.uk) iv) A more recent application in 2021 was withdrawn in July of that year: [Withdrawn] RH3 7AU, Angus Energy Weald Basin No.3 Limited: environmental permit application advertisement – EPR/BL9763IN/V005 – GOV.UK (www.gov.uk) Despite this withdrawal, AE continued to state, in an RNS (Regulatory News Statement) dated 26 Oct 2021: Angus Energy Regulatory News. Live ANGS RNS. Regulatory News Articles for Angus Energy Plc Ord Gbp0.002 (lse.co.uk)
Brockham Licence PL235: “We continue to expect determination of our Environment Agency application to re-inject produced water during Q4 which, if granted, will also provide reservoir support to increase Portland production and reduce truck movements and the environmental cost of incinerating produced water off-site.
Also:
v) Production from the Lidsey oilfield (nr Bognor) has shrunk to nothing in the past year because of 2 factors – a malfunctioning pump and AE’s admission in Feb 2021 that they were drilling in the wrong area of the licence. Angus Energy to seek new drilling target at Lidsey – DRILL OR DROP?
4. Well integrity: i) The spate of low-level earthquake tremors in 2019, felt from Crawley to Dorking, could have caused problems to oil- wells. Their vulnerability to even the slightest of earth movements is a given fact and we refer you to the paper submitted by Prof. David Smythe for the EA : smythe-objection-to-angus-energy-permit-variation-may2021-v1.1.pdf (wordpress.com) which recommends: The Applicant be required to acquire, process and interpret a new high-resolution 3D seismic survey of 5-8 sq km in area, before submitting a revised application. The survey should be designed to encompass the oilfield, and be parametrised to identify the fine detail of the geological structure at Portland and higher levels – in effect, a high-resolution survey.
ii) It is also significant that AE have failed to provide adequate evidence of their well integrity to the Environment Agency and detailed proposals of how they propose to dispose of surplus water. BRX 3 was proposed for water reinjection in 2018. We quote from the EA report in 2018 in response to AE’s application: EPR/BL9763IN/V004 Date issued: 22/11/2018: “With regards to well integrity for reinjection well BRX3 the revised HRA states, in Section 5.2.2 (Page 24), “BRX3 cementing data for BR3 is not available, but the diagram of the well in Appendix 3 and discussions with the operator indicate that the 7” casing will be cemented down to at least 600m TVD at the kick off point and is likely to be cemented below this depth towards the base of the well at 754.6m TVD.” As with the previous HRA (June 2018) there is a schematic diagram of the proposed well, but no log to confirm the cementing of the well or the integrity of the well following installation.
We have requested information on the “as installed” well and its integrity prior to the re-permitting process commencing and during the re-permitting process. We last requested this information during a meeting with the operator and their consultants on 7 September 2018, however this information was not provided.
We have checked with colleagues in the Health and Safety Executive (HSE) to see if they hold information from the operator or from previous owners/ operators of the Brockham site (Midmar and Key) for the re-injection well. While they do have data for the site it does not provide clarification of the “as installed” well, cementing details or its integrity.”
Pages 10 / 11: In conclusion, the operating procedures for the Brockham site are not up to the required standard. They lack appropriate detail, do not demonstrate that appropriate management systems are in place and do not clearly show procedures that demonstrate that the integrity of the well is being maintained and the reinjection of fluids is behaving in the manner it is expected to during and post every re-injection event. It is important to note that we do not have any specific information about an impact on the groundwater environment from the previous activities. However, the reinjection well, BRX-3 which is from BRX-1, were installed in 2007 and 1987 respectively and it is critical that appropriate infrastructure and procedures are in place to carry out reviews of the integrity.”
NB: Angus Energy have withdrawn their most recent application to the Environment Agency ( ref: 2.iii))
5. Their financial viability: Recent documents available online show a worrying trend in their finances. Annual-Report-and-Accounts-and-Notice-of-Annual-General-Meeting.pdf (angusenergy.co.uk)
AE state on page 5: “Revenue from oil and gas production during the year was down to £0.068m (2019: £0.2m) on production of a gross 1,594 barrels (2019: 5,346 barrels). This was the result of the Lidsey Oil Field being shut in due to problems with the downhole pump during the year coupled with low oil prices.
The Group recorded a loss of £2.516m (2019: £5.043m)…”
They have now reduced admin costs by £1.916m to £2.060m (2019: £3.976m). This means that their total revenue from oil production comes nowhere near covering even their admin costs, let alone the considerable costs involved in production. At present they have no active sites: progress at Saltfleetby has slowed and nothing is expected before April / May 2022: Angus Energy Regulatory News. Live ANGS RNS. Regulatory News Articles for Angus Energy Plc Ord Gbp0.002 (lse.co.uk)
They have made several share issues in the last year and I point you to this graph of share prices; to set this within context, three years ago in Sept 2017 their share price reached an all-time high of 35.75: now their shares are worth approx 0.66.
Angus Energy PLC Re-evaluation of Lidsey Field (PL 241) – ADVFN
It is an essential part of due diligence to ensure that companies have sufficient funds to carry out their obligations and we are not convinced that Angus Energy are in a position to do this, or that they can fulfil their obligations to restore the site at Brockham if they decide to cease production.
In 2019 they tried to sell the site but failed to find a buyer. Angus looks to sell Brockham after sidetrack found “uncommercial” without fracking – DRILL OR DROP?
In conclusion we remind you of the words of Chairman of the Planning Committee, Tim Hall, when passing AE’s application in August 2018. (Breaking: Angus Energy application on disputed Brockham oil well approved – live news updates – DRILL OR DROP? : )
“…you have been the least reliable hydrocarbon applicant we have dealt with. ..
consistency of approach and validity and evidence will be expected at every stage …
We will expect the maximum standards of professionalism from you and your advisors throughout the next 3 years … and we will expect the maximum transparency from you as well.”
We trust that you will consider our objections carefully.
Mrs P Smith,
Dorking Climate Emergency
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