I am writing to object to the permit that the Environment Agency is minded to approve for the

Europa Oil and Gas proposed drilling site at Holmwood/Leith Hill EPR/YP3735YK/A001. I am the MEP
for the South East of England, with many oil and gas sites within my constituency, and I receive many
letters of concern on this topic from constituents.

Thank you to the Environment Agency for the extended consultation period including the open day
on March 15​th​ which means residents had a chance to have their questions answered. Although this
is not part of normal practice it was helpful and constructive. The Environment Agency will have
noted the level of concern and interest in this application, not least the petition about water
protection which has over 102,000 signatures. This was started by local people near Leith Hill. I am
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not aware of any national campaign to whip up protest at Leith Hill, as has been implied , and most
of the opposition comes from the local community who are directly affected by these plans.

I have also recently written to the Environment Agency, requesting either an extension to the
consultation period or for the Environment Agency to withdraw the “minded to approve” status for
this application while it carries out further investigative work. This is to provide the appropriate
scrutiny to the methodology used in relation to the seismic data by Europa Oil and Gas. There needs
to be public confidence in the outcome of this decision and, without the due diligence that
independent experts recommend is carried out, that will be lacking.

My response is limited to some general points. I commend the detailed, independent submissions of
Professor David Smythe and the team of expert hydrogeologists and engineering geologists
commissioned by David Bruml/A Voice for Leith Hill. They have the necessary expertise to comment
in detail on what is being proposed and I would support what they are recommending to you.

Precautionary Principle
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The precautionary principle as set out as part of the Maastricht Treaty in 1992, is based on the idea
that developers must provide, to a legal standard, that their plans will not damage the environment.
In the case of Leith Hill the developer is relying on old data, which has not been independently
assessed, and is possibly misrepresenting the data. The main risk that the precautionary principle
would seek to avoid in this case is the pollution of the major aquifer supplying drinking water to
700,000 homes in Dorking and Leatherhead. The Environment Agency has provided reassurance
about this, but I am not confident that this is on the basis of the correct information having been
provided about the risks. It is widely recognised that geological faults act as conduits for pollutants
and that inevitably these will surface within a period of time (whether a couple of years or many
generations). The Environment Agency is aware that well failure is not uncommon. It is also aware
that the information provided about the faults in the area, and the proposed drilling plans, is
incomplete and unsatisfactory. The precautionary principle therefore applies and this permit should
not be approved until the public can have full confidence in the science and resulting assessments.

The unreliability of the onshore oil and gas industry in the Weald

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The Environment Agency said at a press conference on March 13 2018 that they couldn’t be seen to be
accepting a petition from 100,000 people about water protection: “​We welcome people who are passionate
about the environment. But this meeting is about the local people”.
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https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3Al32042
 The oil and gas industry operating in the Weald has been characterised by various commentators as
“a Ponzi scheme”, “penny share cowboy companies”. At the time of writing the two main
stakeholders at Leith Hill have share prices of 1.58p (UKOG) and 3.32p (Europa). Europa is
under-financed with a deficit a year ago of over £16m. UKOG has interests in other struggling sites –
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its Broadford Bridge site, where it has had cement bond failings , and the Markwells Wood site.
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Here, the groundwater risk assessment carried out by Envireau Water on UKOG’s behalf assessed
the magnitude of impact on groundwater as ‘negligible’. However, an independent hydrogeology
report by Environmental Geology & Geotechnical Consultants Ltd, commissioned by community
group Markwells Wood Watch, on the karstic features in the geology in and around Markwells Wood
found that the “​hydrogeological conceptualisation that underpins the risk assessment contains gross
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factual errors and misinterpretations of basic sources of information.” ​It was this vital ​evidence,
which may never have surfaced without the work of concerned residents, which suggested that the
planning application represented unacceptable risks. The water company (PW) and regulator (EA)
sustained their objections to the UKOG planning application and ​the South Downs National Park
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Authority recently placed an enforcement notice on the Markwells Wood site, ordering the oil
company to remove equipment and restore the site. I note that the hydrogeological assessment for
Europa has been carried out by the same company which did the work at Markwells Wood. Given
the above information, this should present cause for concern and underline the need for an
independent assessment at Leith Hill.

The Environment Agency has stated that no bond is required in this case for any failure of the
operation, to clean up environmental pollution or to rectify matters in the long term should
problems arise. Yet these companies have no apparent long term viability that can be relied on. This
means that there is no means to address any environmental pollution in the short or long term,
another reason why this permit should be refused.

Lack of faith in regulation of these oil consents

At the nearby Brockham oil drilling site Angus Energy drilled a one kilometre long horizontal
sidetrack without planning permission (December 2016-January 2017), but with the approval of the
Environment Agency and the Health and Safety Executive. This was a serious failure in regulation
with no clear lines of communication between the various regulators involved at the site. There was
also insufficient monitoring and the reporting was left to the protection camp at the side of the road
and locals who were concerned about what was going on. It is therefore hardly surprising that
objectors will express concerns about their ability to rely on regulation to ensure their health and
safety, and the safety of their environment. This is not a criticism of the Environment Agency’s

https://drillordrop.com/2017/10/10/cement-bond-problems-at-ukogs-broadford-bridge-well-announcement-t
o-investors/comment-page-1/
4

http://planningpublicaccess.southdowns.gov.uk/online-applications/applicationDetails.do?activeTab=docume
nts&keyVal=ODSXV0TU02R00
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​http://www.eggconsult.co.uk/critique-markwells-wood-hydrogeological-risk-assessment/
6

https://www.southdowns.gov.uk/wp-content/uploads/2018/03/Enforcement-Notice-Markwells-Wood-14-Ma
rch-2018.pdf
clearly stated good intentions as regards to monitoring at Leith Hill, but an expression of lack of trust
by the community in the system that regulates drilling in our sensitive landscapes and ecosystems.

Faults

Prof David Smythe will submit to you detailed information on this geologically complex area. I share
his concern that the seismic data being relied on is 37 years old and has not been subject to
independent analysis. Prof Smythe is particularly critical of the fault analysis which he claims is being
misrepresented by the applicant, either deliberately to mislead or because they have not carried out
a full assessment of current data. He points out that their portrayal of the faults has changed over
time, is inconsistent and that he disagrees with it. He is strongly recommending that modern seismic
data for the area is collected including a 3D seismic survey. I support this view. If the aspirations of
the oil industry to establish back to back industrial production in this area are to be carried out, this
study would provide vital information to inform future applications, including potentially for the
Leith Hill site itself if the exploratory drilling leads to further work at the site. In any case, it is
necessary in the application of the precautionary principle. The Environment Agency will not want to
rely on the partial view of the applicants, with which experts disagree. There is just not enough data
to help the assessment of risk. This is a failing in the assessment reached by the Environment Agency
and the permit should not be allowed for reasons of doubt and lack of public confidence.

Acidisation

The Environment Agency has provided reassurance that there will be limited use of chemicals and
that they are for well cleaning. Also that they will be safely removed by Europa who say “all of the
dilute acid solution will return to the surface once it has reacted, leaving no discernible trace of
product in the groundwater”. However, where similar processes to what is proposed have been
used, e.g. at Broadford Bridge, failure to retrieve all the acid have been reported. The acid has
remained underground for long periods of time, damaging the formation, and the terms of their
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permit are therefore not being met . Similar concerns arise for Leith Hill.

Only a few weeks ago, the Environment Agency published a report on the UK’s water quality, which
found that, already, “nearly half of groundwater bodies will not reach good chemical status by 2021.
For groundwaters protected for drinking water, nitrate levels were responsible for 65% of failures to
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achieve good chemical status.” There are, as yet, not fully understood risks from the acids and other
chemicals used in most stimulation techniques which is the cause of considerable concern.
Furthermore, the EU Water Framework Directive states that “The presumption in relation to
groundwater broadly should be that it should not be polluted at all.” So the applicant must
demonstrate that any risk of harm to our environment and water must be ruled out before any
operation is allowed to go ahead.

Flaring

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“In the light of results and analyses from tests 5 and 6, together with learnings from test 7 in KL5, the
Company and its consultants are currently investigating the possibility that zones 5 and 6, originally perforated
in summer 2017 and acidised during the original test programme, were damaged by a combination of the long
residence times of spent acid within the reservoir prior to current testing and the perforating technique
utilised”. UKOG RNS 20 Feb 2018
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https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/683352/State_of_the_envir
onment_water_quality_report.pdf
Constituents near to the Horse Hill drill site have previously raised concerns with me about the effect
of emissions from flow testing there on their health. One person living nearby has reported
continuing respiratory problems as a result. The modelling for the Leith Hill flaring is based on
computer simulation, whereas recent research indicates that the emissions are more damaging than
previously thought. I support the more detailed objections of others on this topic.

Not enough time for water monitoring

I understand that Europa has been carrying out groundwater monitoring for a few months and that
more will be required after consent is given and before work can start. I am concerned that not
enough time is being allowed for baseline monitoring, given the potential sensitivity of the
environment. The hydrogeological assessment that has been carried out does not allow for seasonal
variations, nor the variation between the same season over time. Climate change is leading to
greater seasonal fluctuations, and more weather extremes. The greatest level of concern on Leith
Hill is about the relationship of the proposed drill site to the Pipp brook, and the aquifer, and the
effect of the fault system on any risk.

In conclusion, I would urge you not to grant an environmental permit for RH5 6HN, Europa Oil and
Gas Limited, EPR/YP3735YK/A001.