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. We do not want HEAVY INDUSTRY in our 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) therefore residents should be provided with the air study documentation to know more about it. 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. - Monitoring 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 it aside and don’t peek at it too much as you write! - Give your objection some local and personal colour. Tell the Environment Agency, for instance, ‘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. 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. Respond on line by midnight April 25th! https://consult.environment-agency.gov.uk/psc/rh17-6jh-cuadrilla-balcombe/ Or write to: Permitting Support Centre, Quadrant 2, 99 Parkway Avenue, Parkway Business Park, Sheffield, S9 4WF Further information: Read Ruth Hayhurst’s summary of Cuadrilla’s application on the excellent website Drill or Drop: https://drillordrop.com/2017/03/24/cuadrilla-reveals-details-of-tests-on-balcombe-oil-well/ Cuadrilla reveals details of tests on Balcombe oil well ... drillordrop.com A month-long public consultation began today on regulation of Cuadrilla’s plans to test its exploratory oil well at Balcombe in West Sussex. Visit FFBRA’s website http://www.frackfreebalcombe.co.uk/ For a detailed study on acidisation: https://drillordrop.com/2017/01/10/guest-post-by-kathryn-mcwhirter-everything-you-always-wanted-to-know-about-acidising/