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2024 Consultation Responses



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


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
Renewable Transport Fuel Obligation (RTFO): Addressing Multiple Incentives


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


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


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


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


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


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


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

2023 Consultation Responses

Hydrogen Blending into GB Gas Distribution Networks


We agree that the strategic role of blending is to support the growth of the hydrogen economy while supplies to alterative end users who need it to decarbonise are established.

Hydrogen Blending Into Gas Networks
Exemptions from the requirement to hold a Carbon Dioxide Transport and Storage Licence


Fuels Industry UK agrees that there should be a class exemption for spur pipelines connecting emitters to the network.

Carbon Dioxide Licence Exemptions
Price-based Competitive Allocation for Low Carbon Hydrogen - Call for Evidence


The UK approach makes investment in UK low carbon hydrogen less attractive, with a consequent risk that international companies will not invest here with significant impact on the UK Energy Transition.

Low Carbon Hydrogen Allocation
British Industry Supercharger: Network Charging Compensation Scheme


It is important that the UK continues to consider use of a full set of policies (including electricity pricing policy) to manage the risk of carbon leakage.

British Industry Supercharger
Hydrogen Allocation Round 2: Market Engagement


The UK approach must be revaluated to ensure that the UK offer remains competitive with other jurisdictions in order to ensure the UK is an attractive place for international investment. 

Hydrogen Allocation Round 2
Future of Industrial Energy Transformation Fund


UKPIA understands that the main barriers to investing in deep decarbonisation or energy efficiencies are access to finance and to staff with the appropriate skills, as well as the competitiveness of UK projects relative to other projects for international companies.

Industrial Energy Transformation Fund
Developing the UK Sustainable Aviation Fuel (SAF) Mandate


The setting of targets needs to provide a clear trajectory for decarbonisation providing certainty for investment in SAF production, and downstream supply infrastructure.

Developing The UK SAF Mandate
Addressing Carbon Leakage Risk to Support Decarbonisation


The Association 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.

Addressing Carbon Leakage Risk To Support Decarbonisation
Developing the UK Emissions Trading Scheme


The Association supports alignment of the UK ETS cap with a trajectory consistent with the Net Zero Strategy. 

Developing The UK Emissions Trading Scheme
Energy Bill: Call for Evidence


The Association and our member companies have concerns in relation to the Bill’s provisions on “core fuel sector resilience” (Part 11 as brought from the Lords).

Energy Bill Public Bills Commitee Call For Evidence
Fuel tanker weight limits: temporary changes during periods of fuel supply disruption


The Association agrees with the principle of fuel tankers being permitted to operate at increased weights with conditions in place to ensure the tankers are operated safely and risk is minimised during a fuel supply disruption.


Fuel Tanker Weight Consultation
Zero Emission Vehicle Maandate


Zero Emission Vehicles – defined by DfT by their exhaust emissions- will have a hugely important role in reducing the UK’s transport emissions and we have provided feedback so that this mandate can support their rollout. However, the Association disagrees with the narrow definition of ZEVs within the Mandate’s scope.

Zero Emission Vehicle Mandate
UK Low Carbon Hydrogen Certification Scheme


The Association agrees with the design features set out in the introduction, except for the treatment in the UK Emission Trading Scheme.


Low Carbon Hydrogen Certification Scheme
2040 Zero Emissions Airport Target


We recognise the intent in the definition; however, it can be difficult to define in absolute terms due to the variation and complexity of airport operations.

Ukpia 2040 Net Zero Airport
Call for Evidence Soil Health


A soil health data gathering challenge that requires further consideration is the ‘end use’ of the soil. 

Call For Evidence Soil Health
Commission for Carbon Competitiveness Call for Evidence


The Association stands ready to support the development of a methodology that ensures a high level of fairness when comparing the carbon intensity of products made in the UK and elsewhere.

Commission For Carbon Competitiveness Call For Evidence
Environmental Permitting Standard Rules Consultation No 26


The standard should be the UK version of the HVO standard, which is BS EN15940, rather than the CEN version without any appropriate national requirements, EN 15940.

Environmental Permitting Standard Rules Consultation 26

2022 Consultation Responses

Review of Hybrid and Distance Working


Companies which may not have already implemented changes to hybrid and distance working as yet have indicated that they are considering changes in future.

Hybrid And Remote Working
Net Zero Review


Decarbonisation must be enabled by clear government policies which give certainty to operators and investors. These allow projects, often at scale and with significant investment to proceed in a cost-effective manner.

Net Zero Review Call For Evidence
Hydrogen Transport and Storage Infrastructure


The Low Carbon Hydrogen Transport and Storage Business Model needs to be available much sooner than outlined in the Consultation as it takes developers a long period of time to execute the project after the Final Investment Decision.

Business Models for Greenhouse Gas Removals


The Association agrees that the Government should develop a GGR Business Model which enables a diverse portfolio of GGR technologies to deploy at scale.

Business Models For Greenhouse Gas Removals
Domestic Maritime Decarbonisation


We strongly disagree with the assumption that biofuels will not be used by the maritime sector, despite this being the advice of the CCC. Renewable fuels offer the fastest short-term reduction in GHG emissions while alternative technologies for fuels and vessels develop and are deployed.

Domestic Marime Decarbonisation
Supporting Recycled Carbon Fuels through the RTFO


A principles-based approach is the best option for determining RCF feedstock eligibility in an open and fair way, creating a level playing field in a technology neutral approach.

Response Supporting Recycled Carbon Fuels Through The Rtfo
Energy Intensive Industries Exemption Schemes


For the refining sector, the exemption scheme does not address carbon leakage or competitiveness issues, due to the limited eligibility for individual refineries imposed by the business-level test.

EII Exemption Schemes
Extending the UK Reach Submission Deadlines


The Association strongly supports Option 1 extending all of the current submission deadlines for each tonnage band by three years, giving submission dates of October 2026, October 2028 and October 2030.

Extending The Uk Reach Submission Deadlines
National Air Pollution Control Programme


Within the refining sector, PM2.5 emissions from point sources are derived from estimates of PM10 emissions based on monitoring (continuous or periodic) of dust emissions using factors. This introduces significant uncertainty in PM2.5 emissions levels reported for the sector. The Association is continuing to work with the environmental regulators to improve the estimation methodologies.


National Air Pollution Control Programme
Exemptions for permitted uses of Persistent Organic Pollutants


UKPIA believes that fluorine-free foam can be a suitable alternative to Aqueous Film Forming Foams for some fire scenarios. We are aware that large scale testing of the efficiency of fluorine free foams to respond to the specific fire scenarios is still ongoing.

Exemptions For Permitted Uses Of Pops
Potential reforms to UK Capital Allowance Scheme


To meet Net Zero for our sector requires transformational investment in the UK of plant and machinery, as well as other key infrastructure. Enhanced Capital Allowances (ECAs) may be a way to support capital intensive investment where larger projects can cost hundreds of millions of pounds.

Potential Reforms To UK Capital Allowance Scheme
CCUS: Industrial Carbon Capture Business Model


Generally, the structure of the Industrial Carbon Capture Business Model (ICCBM) does create an investable proposition.

Some elements of the ICCBM could be improved in order to further incentivise investment.

CCUS Industrial Carbon Capture Business Model
Hydrogen Business Model and Net Zero Hydrogen Fund: Market Engagement on Electrolytic Allocation


The Association broadly agrees with the proposed evaluation criteria for the first 2022 allocation round. We do have some concerns that economic benefits are scored equally to cost considerations, as the economic benefits are often outside the control of the project once it is delivered.

Response Market Engagement On Electrolytic Allocation Consultation
UK Emissions Trading Scheme Free Allocation Review


The Association believes a broad range of policy measures will be required to mitigate against carbon leakage/competitiveness impacts arising from carbon pricing policies and to support the high levels of investment required in decarbonisation and transformation projects.


Response Market Engagement On Electrolytic Allocation Consultation (1)
Low Carbon Fuels Strategy - Call for Ideas


The Association’s view is that all suitable Low Carbon Fuels (LCFs) should be considered as available options in the energy transition, not just renewable fuels. Fuels such as RFNBOs, RCFs, liquid and gaseous fuels associated with Carbon Capture, Utilisation and Storage (CCUS) offer significant opportunities for decarbonisation.

Low Carbon Fuels Strategy Call For Ideas


The focus on 2050 provides industry with a long-term pathway when considering investment. However sourcing Biomass for SAF will be in competition from other industry sectors including renewable diesel. An update focusing on the next 5 – 10 years would assist industry in focusing on the immediate targets and allow it to plan accordingly. 

Jet Zero Further Technical Consultation
Embedding standards and pathways across cyber profession by 2025


The Association believes that an exemption for digital service provider small and micro- businesses should be modified to enable a small number of critical providers to be brought under scope of NIS Regulations. This is because of the digital interconnectivity of the value chains of the businesses involved in the Downstream Oil Sector. However, once the system is implemented and reached a mature state it may then be worth considering a widening of the scope to include more entities. This would strengthen the UK’s Cyber resilience.

Response To Proposal For Legislation To Improve The Uk Cyber Resillience
Response to Scottish Government decapitalisation rates


The Association and our members encourage the Scottish Government to continue prescribing the appropriate de-capitalisation rate for the 2023 revaluation. The prescribed rates are well established in practice. Since the prescription has been set by Government since the 1990 Revaluation, there is now little debate to the appropriate rate to be adopted for the Non-Domestic properties valued using the contractor’s method.

Scot Gov Response Decapitalisation Rates 2022
Response to the Call for Evidence on hydrogen-ready industrial boilers


As outlined in the BEIS Hydrogen Strategy, low carbon hydrogen (LCH) has an essential role to play in delivering a Net Zero UK1. Whilst hydrogen is already used in many industrial processes as either a feedstock or energy vector, it is normally produced at the same site it is consumed at, with said site likely to be regulated for Greenhouse Gas (GHG) emissions by the UK Emissions Trading Scheme (ETS), but no sustainability requirement associated with the hydrogen itself.

Technical Consultation Response
Response to the UK Reach - PFAS RMOA Call for Evidence


Aqueous Film Forming Foams (AFFFs) are the predominant firefighting foams used in the UK Refineries and Terminals. Perfluorooctanoic acid (PFOA) and related substances have been used in the formulation of many of these foams.

Many if not all Major Accident Hazard sites have significant stocks of AFFF as part of their inventories for emergency planning measures as this is required under Seveso III and implemented as Control of Major Accident Hazards [COMAH].
The Association and our members are keen to help the UK Government to meet the commitment to phase out the use of PFOAs. 

Response To Fuelling The Future

2021 Consultation Responses

Making Flexible Working the Default


The principle of a right to request flexible working from day 1 is not supported. Due to the operational nature of the downstream sector, flexible working cannot be offered to all employees regardless of their time working at the company.

Ukpia Flexible Working The Default Consultation Dec 2021
Designing a UK low carbon hydrogen standard


The low carbon hydrogen standard (LCHS) should not include end-use in scope and must also be applied to hydrogen imported to the UK to ensure a level playing field for producers for the UK market.

Ukpia Lchs Response
Designing the Net Zero Hydrogen Fund


Whilst support in the FEED and pre-FEED stages may mean multi-year time frames for the fund’s benefits to be realised, supporting these stages is likely to enable more innovative projects to be designed and assessed.

Ukpia Nzhf Response
Resilience Strategy Call for Evidence


UKPIA agrees with the need to have a resilient UK and believes that the principles outlined are appropriate for a vision of the National Resilience Strategy (NRS). However, the Strategy should not dismiss or underestimate the current resilience of the UK.

Ukpia Response To National Resilience Strategy Nrs Call For Evidence
Design of a business model for low carbon hydrogen


As such an integral part of the refining process, the downstream sector has decades of experience in producing and handling hydrogen and is already beginning to utilise this expertise for the deployment of LCH.

Ukpia Hydrogen Business Model Response
Mandating the use of sustainable aviation fuels in the UK


UKPIA agrees that a dedicated Sustainable Aviation Fuel (SAF) mandate is the most appropriate domestic policy mechanism to support the deployment of SAF in the UK and welcomes the opportunity to respond to the DfT’s consultation on a SAF mandate. The downstream sector looks forward to working closely with government and broader industry to decarbonise aviation.

UKPIA SAF Mandate Response
CO2 emissions regulatory framework for all newly sold road vehicles in the UK


UKPIA does not have a specific view on what threshold new cars and vans should be required to meet from 2030. However, any chosen metric should be carefully considered on a lifecycle GHG basis and provide a suitable framework to encourage the reduction of lifecycle GHG emissions – not just tailpipe emissions.

Ukpia New Road Vehicle Co2 Emission Consultation Response
Consultation: more frequent revaluations: Fundamental Review of Business Rates


UKPIA agrees with the overall objectives of the consultation paper in terms of reducing the revaluation frequency to 3 years and providing greater transparency for ratepayers. We understand that to achieve these objectives that other changes are necessary, some of which place greater onus upon the ratepayer.

Ukpia Revaluation Consultation Response Draft Hmt Revaluation Cycle 240821
Heavy goods vehicles: ending the sale of new non-zero emission models


In UKPIA’s Future of Mobility in the UK report, the range of technology options available to heavy goods vehicles (HGVs) is technically assessed, with low carbon fuels, hydrogen, and battery electrification each having a role in this difficult to decarbonise sector.

Ukpia Hgv Phase Out Consultation Response
Role of Biomass in achieving Net-Zero


UKPIA believes biomass has an essential role to play in the decarbonisation of the UK economy and delivering Net Zero by 2050.  Biomass represents the most technology ready alternative to crude oil in the production of both low carbon energy vectors (such as renewable fuels) and non-energy products (such as petrochemical feedstocks).

Schemes to compensate energy intensive industries
Schemes to compensate energy intensive industries


UKPIA welcomes the opportunity to respond to the consultation on Review of the schemes to compensate energy intensive industries for indirect emissions costs in electricity prices. The majority of UK industries face higher electricity costs than most countries in the EU-27, leading to competitive distortions and increased risk of carbon leakage.

Review of the schemes
Decapitalisation Rates Wales


If set fairly, subject to consultation and within the context of existing case law, then continued prescription of decapitalisation rates is the preferred option. This can help avoid expensive litigation and assist predictability and accuracy in budgeting and forecasting which are important particularly when making location and investment decisions within our industry.

Decapitalisation Rates Wales 2021
Response to Downstream Oil Resilience Bill


The powers in the DSOR Bill are in some cases too broad and, at worst, have the potential to negatively influence industry decisions to invest in the UK – this applies both to investments to maintain supplies today, but may also influence decisions for decarbonisation related investment.

Downstream Oil Resilience Bill Response
Next Steps for RTFO


UKPIA supports an increase to the Renewable Transport Fuels Obligation (RTFO) main obligation by 1.5% from 1st January 2022 and believes that more ambitious increases in deployment of low carbon fuels are possible in the near term.

RTFO Next Steps
Mandatory climate-related financial disclosures


UKPIA has concerns regarding the increasingly complex and multiple legislative instruments covering carbon emissions and energy use, each with their own monitoring reporting and verification requirements, which are a growing and increasingly duplicative reporting burden on companies.

Mandatory Climate Reporting
UK ETS Free Allocation Review


The ETS Free Allocation Review should be broader in scope. Complementary measures such as carbon border adjustment mechanisms (CBAMs) should be considered alongside the review of free allowance allocation, since nether mechanism by itself is likely to provide the level of protection required at higher carbon prices.

ETS Free Allocation Review
Inquiry into the role of hydrogen in powering industry


For the refining and downstream oil sector, hydrogen has an important role to play in replacing refinery fuel gas (RFG) as a source of energy in the refineries themselves, but also to meet other demand from transport and industrial commercial and domestic heating.

Hydrogen Economy Response
CCUS Market Engagement on Cluster Sequencing


Given the magnitude of the Net-Zero challenge, it is important that all of the CCUS cluster projects are progressed as soon as possible. In reality, the projects will proceed at different rates depending on many factors including the complexity involved, availability of project finance and timescales for planning and regulatory approvals.

CCUS Cluster Sequencing
Hydrogen in Wales


By reinventing itself, using its extensive resources to decarbonise its activities and products, the sector has an important role also in future supply of new energy carriers and technologies such as hydrogen, energy storage and carbon capture, utilisation and storage.

Hydrogen In Wales

2020 Consultation Responses

Transport Decarbonisation Plan


UKPIA member companies own and operate a number of sites designated as Critical National Infrastructure and a high proportion of their downstream assets will likely be captured under the requirements of the National Security and Investment Bill.

Transport Decarbonisation Plan
Greenhouse Gas Removals Call for Evidence


Using its extensive resources to decarbonise its activities and products, the sector has an important role also in future supply of new energy carriers and technologies such as hydrogen, energy storage and CCUS as well as to greenhouse gas removals (GGR) where companies such as bp, ExxonMobil and Shell are already investing in nature-based solutions.

Ending the sale of new petrol and diesel vehicles
BEIS Super Inquiry - COVID-19


With three distinct yet interlinked challenges in the form of: recovery from the pandemic; adjusting to changes following Brexit; and meeting Net-Zero, UK Government’s actions need to ensure that they can provide both certainty and security to businesses now, while not being in conflict with the long-term goal to make the UK economy net-zero by 2050.

Super Inquiry - COVID 19
BEIS Committee - Impact of COVID 19


The petroleum industry is supporting the national effort to combat coronavirus. Demand for Fuel in the UK has reduced overall causing major issues for the sector. The downstream oil industry has been affected significantly by coronavirus but in working with regulators, has kept the country moving through the ready supply of liquid fuels.

Impact of Covid 19 - BEIS Committee
Carbon Emissions Tax


The UK refining sector has previously strongly supported continued membership of the EU Emissions Trading System (EU ETS) until at least the end of Phase III in December 2020, and its subsequent replacement by a linked UK ETS.

Carbon Emissions Tax
RTFO Buy Out


UKPIA is supportive of an increase to the buy-out price of the RTFO effective from 1st January 2021 in light of the ending of the motor fuels GHG emissions reduction target on 31st December 2020.

RTFO Buy Out
Introducing E10 Petrol


The UKPIA membership are supportive of the mandated introduction of E10 in the UK and welcome an enhanced route for the adoption of low carbon fuels. Of course, as with any modification to the UK fungible fuel mix, there are practical considerations to consider. However, UKPIA is confident that, done properly, E10 can be introduced in the UK with minimal impact on the consumer. 

Introducing E10 Petrol: Consultation
UK Global Tariffs


UKPIA and its members are - in principle - in favour of most of Government’s objectives of this consultation. Simplifying and making more consistent arrangements for tariffs & removing nuisance tariffs are worthy objectives. The downstream oil sector is a commodity market of fungible, highly tradeable, products which despite high trade volumes tends to be traded with low margins.

UK Global Tariffs
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