Questions arising from virtual consultation January 2021
This industrial development is proposed within an Area of Outstanding Natural Beauty, a designated exceptional landscape whose distinctive character and natural beauty are precious enough to be safeguarded in the national interest. In what specific way does this development contribute to sustaining this exceptional landscape and its biodiversity?
National planning guidance requires applicants for major development within the AONB to demonstrate that the development is in the public interest. Applications should include an assessment of the need for the development and the impact upon the local economy; the cost of developing outside the AONB or meeting the need in some other way; and any impacts on the environment, the landscape and recreational opportunities and how they could be moderated.The planning statement, the socio-economic report and the Environmental Statement which will accompany the planning application will assess these criteria to demonstrate why the proposed development is in the public interest.
It is asserted ‘Our previous drilling exercise in this location did not cause any issues for local people in terms of disruption’. What evidence is exists for this claim and how is ‘disruption’ defined and measured?
Disruption can only be measured where it is made known to us and this is either directly to Egdon or via the local planning authority. There was one complaint made to us directly about the operations of the site which was around lighting and was dealt with directly. In this forthcoming application the lighting strategy has been designed to address this issue and this has been communicated directly to the person who raised the issue. Other issues were raised directly with the local planning authority who independently investigate and verify and issues. The points raised were all either found to be in accordance with the planning permission or were dealt with immediately.
It is suggested that ‘Other matters such as climate change’ will be considered. How will this be done and what exactly will be considered?
The Environmental Statement that accompanies the planning application will include assessments of a number of environmental topics in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended). In addition to climate change, the ‘other matters’ referred to include cumulative effects and interactions, community and socio-economic, population and human health and major incidents/accidents and disasters. With the exception of economic benefits which can be quantified, each of these other matters is considered in qualitative terms. In respect of climate change impacts specifically associated with the proposed development, the primary impacts are considered to be those on surface water runoff, flood risk and biodiversity net gain. These impacts are covered in the technical assessments accompanying the Environmental Statement. Where necessary, mitigation measures are proposed to ensure impacts are minimised. In relation to wider aspects of climate change and the future role of fossil fuels, projections of future oil demand and the important role of lower pre-combustion emission domestic production are considered in the context of government policy.
How will the AONB benefit from this development?
National planning guidance requires applicants for major development within the AONB to demonstrate that the development is in the public interest. Applications should include an assessment of the need for the development and the impact upon the local economy; the cost of developing outside the AONB or meeting the need in some other way; and any impacts on the environment, the landscape and recreational opportunities and how they could be moderated. The planning statement, the socio-economic report and the Environmental Statement which will accompany the planning application will assess these criteria to demonstrate why the proposed development is in the public interest.
Please ensure regular updates as to the planning and operational progress as our property is shown to be on the edge of the prospective extraction area.
Egdon has established a local Community Liaison Group which ensures the dissemination of up to date information on the proposed development. In addition Egdon has a community website www.egdon-community.com which also has up to date information on the project.
Please confirm the direction the side track well will take (we were told in recent meeting it will be south west from the site)? You state there is natural screening – I have a direct line of sight to the site, so this is not true. What is the noise threshold above ambient background noise? What were the conclusions of the assessments?
The side-track well is to be in a South-Westerly direction from the existing site. In relation to lighting, a detailed lighting assessment has been undertaken (and forms part of the Environmental Statement) to assess the potential for light pollution and the mitigation and design changes required to minimise this. There is natural screening around the site, but it will be the case that the site is in view from certain aspects and we don’t claim that the natural screening will mitigate views from all directions. In respect of noise, a detailed noise assessment has been undertaken (and forms part of the Environmental Statement) and has concluded that “the proposed development, during any or all of the phases anticipated, will not give rise to significant effects as a result of its noise emissions”. The report is highly detailed and has assessed the background noise levels and the potential noise levels associated with all stages of the proposed development and their impact on noise levels at the nearest properties to the site. Previous planning Condition 10 (planning permission reference (E)N59/2259/14, dated 17th October 2014) required that the noise arising from drilling, at the boundary of any noise-sensitive residential property, must not exceed 42dB LAeq,1h during the hours 07:00h and 23:00h (daytime and evening), and 42dB LAeq,5min between 23:00h and 07:00h (night-time). These limits would not be exceeded during any of the stages of the proposed development. Please note also that we had noise monitoring applied during the drilling of the Biscathorpe-2 well, and this showed that no noise thresholds were breached at the nearest properties. We intend to repeat noise monitoring during all phases of the development.
Even clean water being introduced into the local watercourses in volume will impact on the biodiversity of this fragile environment.
Egdon operates responsibly and abides by all relevant laws and regulations. Government policy makes it clear that oil and gas remain an important part of the UK’s energy mix and the Committee on Climate Change (CCC) has acknowledged that the UK will still be using fossil fuels even with the Net Zero UK carbon emissions by 2050. The sources of fossil fuels should be from that which generates the lowest emissions footprint. This is domestically produced onshore oil and gas. Oil produced at Biscathorpe will help displace imports, which generally have a higher pre-combustion carbon intensity (up to 300% higher). The proposed development at Biscathorpe is therefore consistent with current government policy on climate change and the adoption of a net zero target.
I would like you to consider your reasons for this operation bearing in mind the imminent catastrophe which is climate change. This is a small quantity of oil as against the potential disruption it will and may cause to a pristine environment.
The site is already in existence and provides for the least disruption to the area – minerals such as oil can only be worked where they are found. Government policy makes it clear that oil and gas remains an important part of the UK’s energy mix. This was recently reiterated in the Energy White Paper (2020) which stated that “The projections for demand for oil and gas though much reduced is forecast to continue for decades to come”. The Committee on Climate Change (CCC) has acknowledged that the UK will still be using fossil fuels even with the Net Zero UK carbon emissions by 2050. The sources of fossil fuels should be from that which generates the lowest emissions footprint. This is domestically produced onshore oil and gas. Oil produced at Biscathorpe will help displace imports, which generally have a higher pre-combustion carbon intensity (up to 300% higher). The proposed development at Biscathorpe is therefore consistent with current government policy on climate change and the adoption of a net zero target.
Where are the plans on how you will decommission the site? What profits are forecast for the site?
Following cessation of production, or in the event that drilling or testing does not result in commercially viable hydrocarbon volumes, the well will be”plugged and abandoned” in accordance with industry best practice applicable at that time. This involves placing a series of cement plugs within the well to provide a series of barriers between the oil reservoir at depth and the surface. The well head is then removed and the casing cut off below ground level and a steel plate welded onto this. The Site will then be restored to its former agricultural use and monitored. The operation is regulated by the HSE and the Environment Agency also has oversight via the environmental permit for the site. It is not possible to define the profits for the site until a) oil has been proven by the siderack drilling operation, b) the quantity that can be produced is determined by the testing phase and c) the likely oil price, operating costs and capital costs are fully understood. However, Egdon did publish an assessment in April 2020 which stated that the project had an estimated un-risked Net Present Value (10%) of £55.6 million with a break-even oil price of US$18.07 per barrel of oil.
Why are you so selfish? Why do you think this project is a good idea?
Government policy makes it clear that oil and gas remains an important part of the UK’s energy mix. This was recently reiterated in the Energy White Paper (2020) which stated that “The projections for demand for oil and gas though much reduced is forecast to continue for decades to come”. The Committee on Climate Change (CCC) has acknowledged that the UK will still be using fossil fuels even with the Net Zero UK carbon emissions by 2050. The sources of fossil fuels should be from that which generates the lowest emissions footprint. This is domestically produced onshore oil and gas. Oil produced at Biscathorpe will help displace imports, which generally have a higher pre-combustion carbon intensity (up to 300% higher). The proposed development at Biscathorpe is therefore consistent with current government policy on climate change and the adoption of a net zero target.
What steps can be taken to alleviate subsurface leakage and or groundwater contamination in and around well bores. “Earthquakes of any magnitude have potential to create or enhance subsurface leakage in and around well bores, in active and abandoned wells… The vast majority of subsurface leakage (including those enhanced or caused by earthquakes) are likely to go undetected”. Kang, Lui, Williams, Douglas, McKenzie, Environmental Research Communication, Vol. 1, No. 12, 2019. It should be noted that the Biscathorpe area experienced a 5.2 magnitude earthquake in 2008
The well is designed to ensure that there are multiiple barriers to any possible pathway for fluids from the oil bearing reservoir (at a depth of c. 2000 m below ground level) to the groundwater aquifers in the top few hundred metres below ground level. The well design is independently assessed by the Environment Agency to ensure groundwater protection. The well is constructed using a series of cemented steel casing strings which are tested for integrity during installation. The well will be monitored for integrity throughout its lifetime in line with best industry practice and at the end of its life will be plugged with a series of cement plugs back to surface to ensure robust and tested barriers are in place to prevent any flows of oil or gas from the well. There is no evidence from the many hundreds of oil wells in Lincolnshire and elsewhere that deep seated regional earthquake activity (such as the Market Raisen event mentioned) has had any impact on well integrity.
Can Egdon categorically state whether it intends to explore (and possibly develop) other sites within PEDL 253? And if it does not intend to, why not, given that output from Biscathorpe will be insignificant on a national scale? (Total UK oil production is 1.55 million bbl/day, the estimated figure for Biscathorpe is 300 bbl/day).
Egdon has no current plans to explore at other sites within PEDL253. Government policy makes it clear that oil and gas remain an important part of the UK’s energy mix and this was recently reiterated in the Energy White Paper (2020) which stated that “The UK’s domestic oil and gas industry has a critical role in maintaining the country’s energy security and is a major contributor to the economy”. Oil production at Biscathopre would contribute to maintaining security of supply whilst the UK transitions to a low carbon economy whilst having a lower pre-combustion carbon footprint than imported oil reducing climate change by reducing the need for imports, and thereby the associated transport and other greenhouse gas emissions.
How much money Egdon will be providing local communities and for what projects? specifics rather than their usual generic statements.
A percentage of revenues (1%) will be put into a local community fund run at arms length from Egdon. A list of projects and uses will be agreed and are likely to include support to local community projects and clubs, local environmental, energy efficiency and energy transition related projects plus sponsorship to local young people for specific personal development activities. Until we know whether the site is viable in terms of production, and what the production rates are, it’s not possible to predict a figure.