2025 Consultation Responses

UK sustainability reporting standards and climate-related transition plan requirements

Fuels Industry UK has responded to the sustainability reporting standards and consultations and climate-related transition plan requirements. While overall supporting alignment of UK sustainability reporting with international standards, care must be taken against introducing reporting that does not help stakeholders, and also to avoid duplication. New requirements must be proportionate, and consideration should be given to exemptions for UK subsidiaries of multinational groups to avoid unnecessary burden especially as it is not possible for investors to invest in such subsidiaries (only the parent company, often in another country). Transition planning should remain voluntary, flexible, and internationally interoperable, with a focus on simplification.

Climate Related Transition Plan Requirements UK Sustainability Reporting Standards

Consultation on modernising environmental permitting for industry

Fuels Industry UK responded to the DEFRA consultation on modernising environmental permitting for industry. Environmental regulation must support industrial innovation and growth and achieving permit determination is essential to de-risk investment decisions. The aim of our response was to inform improvements in environmental permitting for new and existing technologies to make sure that modernisation is proportionate and does not lead to project delays. However, we do not support providing the ability to write the regulations, to an executive agency, that it will then enforce and the removal of Ministerial approval of final BAT documents.

Consultation on modernising environmental permitting for industry

Hydrogen Blending into the GB Gas transmission network

Fuels Industry UK has responded to the Hydrogen Blending into the GB Gas transmission network consultation. Fuels Industry UK takes the view that the most appropriate way of supporting hydrogen into the natural gas networks is through the hydrogen business model. The HSE regulatory impacts of introducing hydrogen into the natural gas grid need to be adequately considered. We agree with the government’s minded to position that initially hydrogen should be introduced at a 2% level.

Hydrogen Blending Into The GB Gas Transmission Network

A policy framework to grow the market for low carbon industrial products

Fuels Industry UK has responded to a policy framework to grow the market for low carbon industrial products consultation. Fuels Industry UK takes the view that although refined products are not in the scope, we understand that the methodology may be used in the future if this situation changes. The UK is already a challenging place in which to attract investment, and any measures which may increase project costs need to be carefully considered to avoid harming growth. There needs to be robust and accurate verification of emissions to provide trust in the scheme, although this may again increase overall costs.

A policy framework to grow the market for low carbon industrial products

HSE Chemicals Legislative Reform Consultation

Fuels Industry UK strongly supports alignment between the UK and EU REACH and CLP regimes to facilitate movement of chemical substances between the EU and the UK, and also simplify the situation in Northern Ireland. This would avoid confusion where classification and hazard information differs between the two regimes, potentially leading to requirements for different safety data sheets and labelling in different parts of the UK.

HSE Chemicals Legislative Reform Consultation

Hydrogen economic regulatory framework consultation

Fuels Industry UK has responded to the Hydrogen economic regulatory framework consultation.

Fuels Industry UK takes the view that initial hydrogen networks are likely to be small and contained within industrial complexes, such as the Hynet cluster. There should be as much flexibility as possible in licencing, to allow flexibility as the networks develop. While there are synergies with the way in which the natural gas network is regulated, hydrogen regulation needs to consider the potentially different needs of the emerging sector.

Hydrogen Economic Regulatory Framework Consultation

Sustainable Aviation Fuel Bill: call for evidence

Fuels Industry UK’s view is that should any SAF Revenue Certainty Mechanism Levy be created, then it should operate under the following key principles: clarity, transparency, simplicity, and fairness. While the SAF RCM levy may provide investment opportunities for small SAF producers, it may deter wider investment in the fuel industry and cannot be looked at solely in isolation.The wider impact of additional levies needs to be carefully considered and developed. The use of any form of retrospective pricing is impossible to administer for fuel suppliers, creating significant financial risk.

Sustainable Aviation Fuel Bill Call For Evidence

Regulatory proposals for carbon capture utilisation and storage and offshore hydrogen production

Fuels Industry UK believes that CO2 should be classified as a dangerous fluid because it has hazardous properties, such as, displacement of Oxygen and asphyxiation. It must also be stored at extremely low temperatures. Operators of CO2 pipelines should be responsible for establishing comprehensive emergency arrangements, including robust communication plans, setting emergency planning zones, and providing training for first responders. This is because CO2 pipelines present unique hazards due to the properties of CO2, including its asphyxiant nature and the potential for rapid release and vapor dispersion. Therefore, an effective emergency response is crucial to minimize the impact of potential incidents and protect public safety.

Regulatory Proposals For Carbon Capture Utilisation And Storage And Offshore Hydrogen Production

Treatment of electrolytic hydrogen in the CCL and the changing energy context

01/05/25

Fuels Industry UK has responded to the Treatment of electrolytic hydrogen in the CCL and the changing energy context consultation. We agree that the climate change levy (CCL) costs should be removed from the electricity used in hydrogen. Due to rising electricity prices, the role of the CCL, in isolation, in improving energy efficiency is becoming lower. We support a wider review of the CCL against a changing energy landscape to ensure that energy intensive industries remain competitive in a challenging global environment

Treatment of electrolytic hydrogen in the CCL and the changing energy context

Fuels Industry UK response request for input on potential UK measures in response to US tariffs

02/05/25

Fuels Industry UK has responded to the DBT Call for Input.

Fuels Industry UK and its members strongly support all fuels and their feedstocks being omitted from any future tariff changes by the UK given the potential for large costs of production and supply increases which would have large knock-on effects on the wider economy. The US has chosen to exempt its own imports of oil and finished fuels from its tariffs which emphasises their importance to the economy and the risks of adding tariffs to these key goods.

Evidence To DBT Call For Input

Funding mechanism for the hydrogen production business model

10/04/25

Fuels Industry UK has responded to the Gas Shipper Obligation consultation on the funding mechanism for the hydrogen production business model. We have concerns that the consultation does not adequately consider the potential increase in costs from later hydrogen allocation rounds on the levy. There is also an impact from falling natural gas prices, which will increase the costs of hydrogen business model support and place a higher proportional burden on UK natural gas prices. Energy Intensive industries such as refining need to be exempted from the levy, or risk becoming internationally uncompetitive.

Funding mechanism for the hydrogen production business model

Extending the UK ETS Cap beyond 2030

10/04/25

Fuels Industry UK has responded to the Extending the UK ETS Cap beyond 2030 consultation. The main points in our responses are: The UK ETS currently plays an active role in UK deindustrialisation while driving emissions offshore. The current 10-year ETS phase is too long, with little opportunity for change or discussion, and does not provide more certainty than shorter periods. Strongly agree on a rollover of credits from Phase 1 to Phase 2, with recommendation that there are no limits to FAA roll over and that roll over credits do not lower allocation allowances.

Cover Letter Fuels Industry UK response to Extending the UK ETS Cap beyond 2030 Response On Extending The UK ETS Cap From Fuels Industry UK

Commission for Carbon Competitiveness - Carbon Leakage in the Export Market

14/03/25

Fuels Industry UK welcomes the opportunity to respond to the Commission for Carbon Competitiveness - Carbon Leakage in the Export Market.

Fuels Industry UK views that the principles behind the UK’s policies addressing carbon leakage are sound but practically they fall short. A UK CBAM must address exports as well as imports. Even with existing carbon leakage measures, since 2022 we estimate the cost of carbon on exports alone has been well over £100m per year across the sector.

Commission On Carbon Competitiveness Call For Evidence March 2025

SAF revenue certainty mechanism: approach to industry funding

Fuels Industry UK has responded to the SAF revenue certainty mechanism: approach to industry funding consultation. We have raised concerns with the assertion in the consultation that a levy should be placed on fuel suppliers under the “polluter pays” principle. This misunderstands this key principle.

The levy should be placed on aviation companies, in a similar way to the Airport Passenger Departure (APD) levy as this offers greater transparency on the costs being incurred. We have a number of concerns that the proposals on how the levy will operate which are unworkable and are keen to work with government to better understand the aviation fuel industry.

SAF Revenue Certainty Mechanism Approach To Industry Funding

COMAH Post Implementation Review

21/02/25

Fuels Industry UK pleased to submit our response to the HSE’s consultation on the COMAH Post Implementation Review. We believe that the Control of Major Accident Hazards Regulations 2015 (COMAH 2015) (S.I. 2015/483) are fit for purpose. Any amendments to the existing regulations that introduce prescriptivity and additional burden should be avoided.

COMAH Post Implementation Review

UK Emissions Trading Scheme Free Allocation Review: Carbon Leakage Consultation

10/03/25

Fuels Industry UK welcomes the opportunity to respond to the UK Emissions Trading Scheme Free Allocation Review: Carbon Leakage Consultation. The key points from our response include: Are the number of free allowances available for the refining industry set at the correct level to mitigate carbon leakage risk for UK refineries? While the methodology used to calculate UK-based CLI metrics is sound, and we support the approach of moving towards a calculation that is based on UK data, the information itself used to calculate the CLI for Refined products and Hydrogen falls short because of both data quality and (covid-based) anomalies in the years chosen. Our view is that a more appropriate CLI for Refined products is 5.13 not 2.35 and for Hydrogen 0.11 seems to be a significant underestimate. We explain our reasoning in Annex A, with a detailed analysis of the NERA report. We would agree that it’s important to implement an export mechanism which allows UK refined products to compete on global markets.

UK Emissions Trading Scheme Free Allocation Review Annex A Analysis Of NERA Report Clean From Fuels Industry UK To UK Emissions Trading Scheme Free Allocation Review Carbon Leakage Consultation March 2025

Phasing out the sale of new petrol and diesel cars from 2030 and Support for the Zero Emission Transition

18/02/25

Fuels Industry UK welcomes the opportunity to respond to the Phasing out the sale of new petrol and diesel cars from 2030 and Support for the Zero Emission Transition. The key points from our response include the need for a holistic approach to policies across government to encourage investment in both lower carbon fuels and vehicle manufacture and a technology neutral, life-cycle GHG reduction basis for transport decarbonisation rather than a focus on zero emission at the tailpipe. With the right complimentary policies the UK could become a leader in lower carbon fuels development, electric vehicle technologies and manufacture, and maintain its leading role in aviation as a hub for sustainable aviation fuels.

Phasing Out The Sale Of New Petrol And Diesel Cars From 2030 And Support For The Zero Emission Transition

Implementing the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)

10/02/25

Fuels Industry UK welcomes the opportunity to respond to the Implementing the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). We support harmonisation of the reporting requirements under CORSIA and the SAF mandate to reduce the administrative burden on fuel suppliers. We recognise that fuel meeting the UK SAF mandate can be used by airlines as an emissions reduction claim, as confirmed in the 2025 UK SAF guidance. To that end we support harmonised documentation between the UK SAF mandate and CORSIA to allow airlines to make their emissions reductions claims.

Implementing The Carbon Offsetting And Reduction Scheme For International Aviation CORSIA

Government Discussion Paper - Transforming Business Rates

24/01/25

Fuels Industry UK welcomes the opportunity to respond to the Government Discussion Paper on Transforming Business Rates. Our submission aims to highlight the flaw in the government’s proposal to reduce the UBR for the retail and hospitality sector, paid for by increasing the rate burden on other industries already facing higher taxes because of the November budget and also to highlight the impact of business rates on long term capital investment decisions, in particular that required to support the transition to net zero, and to suggest some additional measures which the government should consider aligning the business rates system with long term policy objectives.

Transforming Business Rates

UK Green Taxonomy

07/02/25

Fuels Industry UK welcomes the opportunity to respond to the UK Green Taxonomy consultation. Fuels Industry UK believes it is unclear if there is a clear value-add case for the introduction of a UK Green Taxonomy and we do not support its mandatory introduction at this point and any UK introduction of a taxonomy should look to align with other taxonomies at a high level to benefit from existing best practice, but look to deliver simplifications where possible.

A UK Green Taxonomy

Environment Agency charges proposal for greenhouse gas emissions

22/01/25

Fuels Industry UK welcomes the opportunity to respond to the consultation on the Environment Agency charges proposal for greenhouse gas emissions. We understand the challenges of delivering the range of regulatory services and the complexities associated with recovery of those costs for delivering services to regulated business. Charges for certain activities should increase based on the level of activity to deliver the service. It is also fair to work to the principle that the greater the environmental risk, the more resource is expended and the greater the cost to be recovered through charges. We believe that the charges presented in this consultation are a reasonable reflection of the value of services provided and that charges are in line with other government bodies.

Environment Agency Charges Proposal For Greenhouse Gas Emissions

RTFO Statutory review and future of the scheme

27/01/25

Fuels Industry UK welcomes the opportunity to respond to the consultation on RTFO statutory review and future of the scheme. We support a review of the targets that takes into account LCF production, feedstock availability and the ability of equipment to use them. We support the RTFO transition from a volume, to a GHG reduction based approach to reward the best performing lower carbon fuels. The development fuel definitions and targets have been successful in enabling refinery co-processing and should be continued. We recognise the significant GHG savings that have been achieved in the RTFO to date.

RTFO Statutory Review And Future Of The Scheme

Environment Agency: Reducing waste crime and updating time and materials charges

17/01/25

Fuels Industry UK welcomes the opportunity to respond to the consultation on Reducing waste crime and updating time and materials charges. Charges for certain activities should increase based on the level of activity to deliver the service. We believe that with an increase in charges, there needs to be visible improvements in the flexibility of the service to respond to innovation and the timeliness of delivery of the service and that the COMAH charges should be set at a rate that is in keeping with the Environment Agency’s Competent Authority partners.

Environment Agency Charge Proposals For Waste Crime And Hourly Rates

UK ETS scope expansion - CCS: non-pipeline transport of carbon dioxide

23/01/25

Fuels Industry UK welcomes the opportunity to respond to the consultation on the integration of NPT CO2 into the UK ETS. The main highlights of our response are that operating costs for road, rail and shipping solutions are likely to be higher than transporting the equivalent volumes by pipeline, there is a strategic element to the creation of an NPT sector within the CCS industry, that government needs to consider and we welcome cross-border CO2 which will encourage the development of the NPT sector in an appropriate manner, recognising that Carbon pricing may be different between countries.

UK ETS NPT Transportation Of CO2

Regulatory fees and charges for 2025/2026

10/01/25

Fuels Industry UK agree that charges for certain activities should increase based on the level of activity to deliver the service. However, with any increase in charges, there needs to be visible improvements in the flexibility of the service to respond to innovation and the timeliness of delivery of the service.

Response on NRW regulatory fees and charges for 2025/2026

Workforce needed to deliver clean energy

13/01/25

For the existing fuels sector workforce, there is relatively little upskilling that will be needed in our businesses as many of the skills needed for future clean technologies like carbon capture and hydrogen are skills we already have. However, existing and growing skills shortages exist which much be a focus for joint industry and policy intervention.

ESNZ Committee - Inquiry into workforce needed to deliver clean energy

2024 Consultation Responses

Industrial Strategy Green Paper Response

04/12/24

Fuels Industry UK welcomes the opportunity to respond to the Industrial Strategy consultation. It is important that the fuels sector be recognised in the industrial strategy for the benefits it brings to the economy, both as a potential driver of growth in clean energy technologies (CCUS, hydrogen and lower carbon fuels) and given that it can deliver against all of the Green Paper’s objectives of delivering net zero, regional growth, and economic security and resilience. Our response also made clear that it is also well above the average in terms of UK productivity -a key driver of growth. The industrial strategy must seek to address the current barriers to investment in the UK which include: high carbon and energy costs; old models of regulation that slow down the net zero transition; not considering full lifecycle emissions, particularly in the transport sector; current shortages in workforce skills to deliver net zero.

Fuels Industry UK Industrial Strategy Response

Moving the UK ETS Second Free Allocation Period

15/10/2024

Fuels Industry UK welcomes the opportunity to respond to the Moving the UK ETS Second Free Allocation Period consultation. Fuels Industry UK broadly welcomes the proposal to extend the current free allocation period to include 2026, and the start of the second period moving to 2027. However, government should take this opportunity to make a meaningful revision to the UK ETS free allowance allocation methodology and extend the scope of the proposed UK CBAM to include refined products.

Moving The UK ETS Second Free Allocation Period

BSI consultation regarding the Publicly Available Specification (PAS) for large hydrogen-fired equipment for use in industrial and commercial settings

30/10/2024

Fuels Industry UK welcomes the opportunity to respond to the BSI consultation regarding the Publicly Available Specification (PAS) for large hydrogen-fired equipment for use in industrial and commercial settings. In our response we highlighted concern that the technical detail within the PAS is confusing and ambiguous. Ambiguity within standards, codes of practice and specifications can cause unintended consequences such as regulatory uncertainty. To avoid ambiguity, we have requested that BSI clearly and explicitly state the scope of the PAS 4445 standard.

BSI Consultation Regarding The Publicly Available Specification (PAS) For Large Hydrogen Fired Equipment For Use In Industrial And Commercial Settings

Lord Industry and Regulators Committee - Apprenticeships and Skills

30/09/2024

Fuels Industry UK welcomes the opportunity to respond to the Lord Industry and Regulators Committee consultation on Apprenticeships and Skills. Fuels Industry UK believes the operation of the Apprenticeship Levy requires careful evaluation and potential reforms. Ensuring that all levy funding is spent, or can be reclaimed by inputting companies could help incentivise participation and address skill shortages among younger demographics. Increased flexibility on Levy spend would also be welcome – shorter courses, use to sponsor supplier companies’ apprentice intake, greater choice for companies on what funds can be spent on and moving funds to previously unfunded apprentices would all improve the current situation.

Fuels Industry UK Lord Industry And Regulators Committee Apprenticeships And Skills Response

Technical and operational amendments to the UK Emissions Trading Scheme: data publication, data sharing and Ultra-Small Emitter eligibility criteria for 2026-30

15/10/2024

Fuels Industry UK welcomes the opportunity to respond to the Technical and operational amendments to the UK Emissions Trading Scheme: data publication, data sharing and Ultra-Small Emitter eligibility criteria for 2026-30 consultation. We broadly do not support the proposal to publish the details of all UK ETS transactions made using the Registry, however we do support the proposal to allow a national authority to disclose UK ETS information to HM Treasury, HM Revenue and Customs and other government departments to facilitate policy development, in particular, development of a UK carbon border adjustment mechanism (CBAM). We believe the UK ETS Authority should not be allowed to disclose confidential installation level UK ETS information to the Climate Change Committee, unspecified third parties or external contractors, as this requires specialist knowledge and expertise to interpret.

Technical And Operational Amendments To The UK Emissions Trading Scheme Data Publication Data Sharing And Ultra Small Emitter Eligibility Criteria For 2026 30

Integrating Greenhouse Gas Removals in the UK ETS

16/08/2024

Fuels Industry UK welcomes the opportunity to respond to the consultation on the integration of GGRs into the UK ETS. Certainty for significant investment by UK industry in the face of an evolving UK ETS with a potential number of concurrent changes, as discussed in the recent consultations on free allocations, future market policy and Cross Border Adjustment Mechanisms (CBAM) with a coordinated approach to these elements. The implementation of a well-designed CBAM mechanism for sectors exposed to carbon leakage to prevent offshoring of production emissions. The integration of Greenhouse Gas Removals (GGRs) into the UK ETS in a manner which allows UK companies to continue to compete on an international basis.

Fuels Industry UK Integrating GGR Removals In The UK ETS Consultation Response

Consultation on Administrative penalties: statement of policy

23/08/2024

Fuels Industry UK welcomes the opportunity to respond to the Consultation on Administrative penalties: statement of policy. Broadly we are concerned that the proposed level of penalties are disproportionate for what is a new and unconfirmed administrative requirement on companies. We request greater reassurance that the higher levels of penalties will be reserved for only the most egregious violations—those that result in significant consumer detriment or constitute clear and deliberate breaches of the law. We trust that as the new requirements are developed that it is ensured that guidance for compliance standards is produced with companies in scope to ensure it is clear, understood, and achievable.

Fuels Industry UK Consultation Response CMA Administrative Penalties 2024

Call for evidence on non-pipeline transport and cross-border CO2 networks

18/07/24

Fuels Industry UK welcomes the opportunity to respond to the call for evidence on non- pipeline transport and cross-border CO2 networks. Operating costs for road, rail and shipping solutions are likely to be higher than transporting the equivalent volumes by pipeline. There is a strategic element to the creation of an NPT sector within the CCS industry, that government needs to consider. We welcome cross-border CO2 which will encourage the development of the NPT sector in an appropriate manner, recognising that Carbon pricing may be different between countries.

Fuels Industry UK Response to call for evidence on non-pipeline transport and cross-border CO2 networks

UK REACH

25/07/24

Fuels Industry UK welcomes the opportunity to respond to the consultation for DEFRA on UK REACH. We have a number of concerns with the proposals set out in the consultation - the assumption that businesses will be able to retrieve and submit the required hazard information from publicly available sources and the requirement to provide detailed, Great Britain-specific use and exposure information goes far beyond the use category and brief general description of identified uses under EU REACH and as previously required under UK REACH.

Fuels Industry UK Response UK REACH

Consultation on CO2 Transport and Storage Enforcement Guidelines and Penalty Policy

01/07/2024

Fuels Industry UK welcomes the opportunity to respond to the consultation on the Ofgem enforcement approach regarding CO2 transport and storage licensees. Fuels Industry UK agrees that the high-level approach to the CO2 T&S Enforcement guidelines and penalties statement documents is appropriate.

Fuels Industry UK Response To Consultation On Enforcement Approach Regarding CO2 T&S Licensees

Core fuel sector resilience measures: proposed guidance on criminal and civil sanctions and provision of information at specified intervals

8/07/2024

Fuels Industry UK welcomes greater clarity in the proposals that prosecution is planned to be the last resort only where there are serious concerns about regulatory compliance.

Response Proposed Guidance On Criminal And Civil Sanctions Response Provision Of Information At Specified Intervals

INTRODUCTION OF A UK CARBON BORDER ADJUSTMENT MECHANISM FROM 2027

13/06/2024

Fuels Industry UK strongly supports introduction of a well-designed carbon border adjustment mechanism (CBAM) to address high UK Emissions Trading Scheme (UK ETS) compliance costs and loss of competitiveness against international competitors with no or significantly lower carbon costs.

Introduction Of A UK Carbon Border Adjustment Mechanism From 2027

SAF REVENUE CERTAINTY MECHANISM

20/06/2024

Fuels Industry UK recognises and support the strategic elements on the vision for UK SAF resilience proposed in the consultation, particularly on economic growth and security of supply.

Fuels Industry UK SAF Revenue Certainty Response

Non-road mobile machinery decarbonisation options: call for evidence

25/03/24

Fuels Industry UK strongly welcomes the opportunity to respond to the Non-road mobile machinery decarbonisation options: call for evidence. We agree that increasing biodiesel blends for use in existing equipment is an achievable and suitable intermediate step to fully decarbonise NRMMs.

Non Road Mobile Machinery Decarbonisation Options Call For Evidence

Empowering drivers and boosting competition in the road fuel retail market

13/03/24

Price reporting should only be required for ‘standard’ forms of fuels - for example B7 diesel and E10 petrol and not for Super petrol and diesel.

Empowering Drivers And Boosting Competition Road Fuel Retail Market

Renewable Transport Fuel Obligation (RTFO): Addressing Multiple Incentives

18/03/24

The size of the UK market relative to international demand for low carbon fuels is an important consideration to any changes that may be made.

RTFO Addressing Multiple Incentives

UK Emissions Trading Scheme: Future Markets Policy

11/03/24

Fuels Industry UK believes strongly that the UK Government should seek urgently to mitigate against future carbon leakage risk, acting on domestic policy measures alongside international and multilateral action.

UK ETS Future Markets Policy

UK Emissions Trading Scheme: Free Allocation Review

11/03/24

Free allowance allocation under the UK ETS currently provides critical mitigation against carbon leakage for the refining sector.

UK ETS Free Allocation Review Review

Carbon Capture & Storage Network Code: updated Heads of Terms

16/02/24

The UK government should be clear that this version of the code has been developed for deployment of Track 1 and that it recognises that the code will need to change for future projects.

CCUS Network Code Heads Of Terms

Hydrogen to Power: Market Intervention Need & Design

22/02/24

Fuels Industry UK’s view is that the vision for hydrogen to power set out in the consultation is a reasonable and pragmatic way forward in the development of the sector.

H2 To Power Market Intervention Need & Design

Scope 3 Emissions in the UK Reporting Landscape

02/01/2024

In principle, Fuels Industry UK and its member companies are not opposed to disclosure of GHG emissions – most of the Fuels Industry UK member companies are subsidiaries of international oil companies who report Scope 3 emissions at a corporate level in their annual sustainability reports.

Scope 3 Emissions In The UK Reporting Landscape

Hiring agency staff to cover industrial action consultation

16/01/24

While supporting the rights of workers to take industrial action through the correct processes, Fuels Industry UK and its member companies would support the repeal of Regulation 7 of the conduct regulations as a means of potentially helping to ensure fuel supply chain resilience during industrial action.

Response To Agency Staff Industrial Action Consultation