Permitting

    What is the current permit for?

    Rathlin Energy (UK) Limited holds an environmental permit - EPR/BB3001FT (the ‘permit’) - in relation to the West Newton A well site.  There are currently two oil and gas wells at the site: ‘WNA-1’ and ‘WNA-2’.

    The permit includes a set of legally binding conditions designed to ensure safe and responsible operations. It outlines:

    • Strict controls on emissions to protect the environment
    • Safe storage requirements for waste and crude oil
    • Regulations on gas flaring to minimise environmental impact
    • Ongoing monitoring and reporting to maintain transparency and compliance

    Several activities are already permitted at this site. This includes the drilling of ‘side-track wells’ from WNA-1 and WNA-2, and drilling of up to six new additional wells. A side-track well is another path, which is drilled from the first well. This creates a new track to explore the reservoir without drilling a new well from the surface.

    Well clean up (a process used to remove debris, drilling fluids, and other materials from a well after drilling) and testing activities; hydrocarbon production; use of gas for electricity generation; flaring of gas; storage of crude oil; well plugging and decommissioning (permanently sealing the well) are also controlled by the permit.

    What is the new permit application for?

    The operator has applied to carry out ‘reservoir stimulation’ on the existing WNA-2 well, which is a process used by the oil and gas industry, designed to improve the efficiency of the flow of oil or gas through the reservoir rock and into the well.

    What does this technique include?

    The geological formation (the body of rock) in which the reservoir stimulation is proposed to take place is known as the Kirkham Abbey Formation (KAF). It’s located at a depth of approximately 1710m below the ground surface.

    The operator proposes to inject 60 to 70 cubic metres of oil-based fluid, with 12.5 tonnes of sand proppant into the rock formation, in a single stage. This will be done at a pressure of up to 9,000 psi, exceeding the fracture pressure of the rock. 

    After that, the fluid will be brought back to the surface in a controlled way.

    The sand proppant is included to ‘prop’ open the channels that are created.

    How is this activity authorised?

    The reservoir stimulation would need to be authorised as a groundwater activity under schedule 22, 8(I) of the Environmental Permitting Regulations 2016.

    The reservoir stimulation would leave some sand proppant and fluid in the ground, which will become extractive waste at the end of the period that the well is operating. 

    Rathlin Energy (UK) Limited has applied to change their permit to include a 'mining waste facility' to allow this. 

    Is this high volume hydraulic fracturing?

    The application is not for high volume hydraulic fracturing.

    The Infrastructure Act 2015 defines hydraulic fracturing as involving the injection of more than 1,000 cubic metres of fluid in any one stage, or more than 10,000 cubic metres of fluid in total. 

    The proposal from Rathlin Energy (UK) Limited is below these thresholds.

    The proposed reservoir stimulation is similar to hydraulic fracturing in that it involves injection of fluid into the rock (geological formation) at a pressure above the fracture pressure of the formation. 

    However, it is not regarded as hydraulic fracturing due to the smaller quantity of fluid involved.

    Why is this technique allowed?

    In England, reservoir stimulation is allowed because it involves much lower volumes of fluid compared to high volume hydraulic fracturing.

    Where can I find the application details from the operator?

    All permit application documents are available to view on the Environment Agency consultation web page.

    What risk assessment do you carry out?

    The application submitted by Rathlin Energy (UK) includes a hydrogeological risk assessment. This details the potential impact on groundwater (water that is stored underground in the spaces between rocks, soil, and sand) from the proposed reservoir stimulation.

    As part of the application, Rathlin Energy has also submitted a detailed assessment of potential environmental impacts. This includes:

    🌬️ Air emissions and odours

    🔊 Noise and vibrations

    💧 Discharges to ground and surface water

    🌫️ Fugitive emissions and visible plumes

    ⚠️ Accident risks

    🌍 Global warming potential

Hydraulic fracture plan

    Why is there no hydraulic fracture plan in the application?

    The Hydraulic Fracture Plan (HFP) will be submitted separately from the permit variation application. 

    The operator’s submission provides sufficient information for a permit determination (our assessment) to be made.

    Will a hydraulic fracture plan be needed?

    Yes. We require that a HFP be submitted to us, before any reservoir stimulation (aka proppant squeeze) takes place. This means that we can check that the details of the HFP (depths, pressure, fluid amounts, geology) match what was submitted and accepted in the risk assessment for the permit variation.

    The submission of a HFP will be set as a 'pre-operational condition'. 

    What is a 'pre-operational' condition'?

     A pre-operational condition is a specific requirement set out in an environmental permit that must be fulfilled before a facility can begin operations.

    These conditions are designed to ensure that all necessary environmental protections and operational safeguards are in place before any activities start.


    Who checks the hydraulic fracture plan?

    Specific details will be submitted to both the Environment Agency and the North Sea Transition Authority before any work starts.

    What does the pre-operational requirement ask for (related to the hydraulic fracture plan)?

    We have set a pre-operational condition 'POM5'. 

    This states that at least three months before starting the activity (listed as 'AR9' in the permit) the operator must send a written hydraulic fracture plan to the Environment Agency for approval. 

    Both the Environment Agency and the North Sea Transition Authority must approve the plan before work can begin. The plan must include specific details about the operation.

    What must be included in the hydraulic fracture plan?

    The hydraulic fracture plan must include:

    • A map showing nearby faults and a summary of the risk that operations could reactivate them
    • Information on any past seismicity in the area and the risk of causing new seismicity
    • A summary of the planned work, including stages, pressures and fluid volumes
    • Steps to check how far the fractures spread, both vertically and sideways, to make sure they stay within the permitted area
    • What actions will be taken in the event of fractures going beyond the permitted boundary and how this effect would be mitigated and limited
    • A comparison with any previous operations and how they relate to past seismic activity
    • Plans to monitor local seismic activity during the operation
    • How the operator will report during and after the operation, including details on the location and size of the fractures to show they’ve followed the permit

Regulation

    How do you keep the environment safe?

    The Environmental Permitting (England and Wales) Regulations 2016 provide a framework for regulating activities that could impact the environment, including reservoir stimulation.

    These regulations require operators to obtain an environmental permit for activities that involve the management of extractive waste, such as the fluids and proppants used in reservoir stimulation.

    We will always complete a detailed and thorough assessment of any environmental permit application on a site-specific basis before deciding whether the activity is acceptable or not, and whether an environmental permit can be granted. 

    We ensure environmental safety and compliance with regulations.

    What is the role of the Environment Agency?

    The Environment Agency is the environmental regulator for onshore oil and gas operations in England, and we ensure that oil and gas operations are carried out in a way that protects people and the environment. 

    We will only issue a permit variation if we believe that harm to the environment, people and wildlife will be minimised and that the operator has the ability to meet the conditions of the permit.  

Consultation

    When is the public consultation?

    The consultation on the draft permit decision is open from 29th July to 6th October 2025.

    You can participate in the consultation in several ways:

    The first consultation closed on 24th January 2025. You can view the consultation responses online.


    What do you take into account during the consultation?

    As part of our consultation, we can consider the following comments and information:

    We can take account of

    • Relevant environmental regulatory requirements and technical standards.
    • Information on local population and sensitive sites.
    • Comments on whether the right process is being used for the activity, for example whether the technology is the right one.
    • The shape and use of the land around the site in terms of its potential impact, whether that impact is acceptable and what pollution control or abatement may be required.
    • The impact of noise and odour from traffic on site.
    • Permit conditions by providing information that we have not been made aware of in the application, or by correcting incorrect information in the application (e.g. monitoring and techniques to control pollution).

    We cannot take account of

    • Issues beyond those in the relevant environmental regulations.
    • Anything outside the remit of the EPR, e.g. the proposed location of the site, which is done by the local authority via land use planning.
    • Whether a site should have a formal designation under Habitats Directive or other conservation legislation.
    • Whether the activity should be allowed or not as a matter of principle.
    • Land use issues when determining a permit application, even if changing the location of the activity would improve its environmental performance.
    • The impact of noise and odour from traffic travelling to and from the site.
    • The legally defined process we follow to determine a permit.
    • The granting of a permit/variation if the operator is able to demonstrate that they can carry out the activity without significant risk to the environment or human health.

Events

    Will you hold a public engagement event?

    We held a public engagement event on 9th January 2025 to discuss what the consultation is for and how to take part.

    Thank you to those who visited the event and spoke to our staff.

    We do not currently intend to hold another in-person event but we will use this page to answer frequently asked questions.