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 2025COMAH 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 ReviewUK 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 2025Phasing 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 TransitionImplementing 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 CORSIAGovernment 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 RatesUK 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 TaxonomyEnvironment 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 EmissionsRTFO 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 SchemeEnvironment 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 RatesUK 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 2025/2026Workforce 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 energy2024 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 ResponseMoving 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 PeriodBSI 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 SettingsLord 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.
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 30Integrating 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.
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 2024Call 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.
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.
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.
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 IntervalsINTRODUCTION 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 2027SAF 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 ResponseNon-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 EvidenceEmpowering 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 MarketRenewable 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 IncentivesUK 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 PolicyUK 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 ReviewCarbon 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 TermsHydrogen 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 & DesignScope 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 LandscapeHiring 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 Consultation2023 Consultation Responses
CCUS Transport and Storage Business Model Revenue Support Regulations
25/10/23
Fuels Industry UK agrees with the proposals relating to the Secretary of State’s power to direct a counterparty to offer to contract.
CCUS Transport And Storage Business Model Revenue Support RegulationsHydrogen Blending into GB Gas Distribution Networks
26/10/23
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 NetworksExemptions from the requirement to hold a Carbon Dioxide Transport and Storage Licence
11/10/23
Fuels Industry UK agrees that there should be a class exemption for spur pipelines connecting emitters to the network.
Carbon Dioxide Licence ExemptionsEnabling Industrial Electrification
20/10/2023
Electrification is not considered as a prime option for decarbonisation of refineries.
Enabling Industrial ElectrificationPrice-based Competitive Allocation for Low Carbon Hydrogen - Call for Evidence
11/08/23
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 AllocationBritish Industry Supercharger: Network Charging Compensation Scheme
24/08/23
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 SuperchargerHydrogen Allocation Round 2: Market Engagement
30/06/23
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 2Future of Industrial Energy Transformation Fund
21/07/2023
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 FundBritish Energy Supercharger: Package for Strategic Energy Intensive Industries
29/06/23
Longer term policies are required to support early investment in EII decarbonisation projects, many of which may increase electricity consumption.
British Industry Supercharger Package For Strategic Energy Intensive IndustriesDeveloping the UK Sustainable Aviation Fuel (SAF) Mandate
22/06/23
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 MandateAddressing Carbon Leakage Risk to Support Decarbonisation
22/06/2023
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 DecarbonisationDeveloping the UK Emissions Trading Scheme
17/06/2023
The Association supports alignment of the UK ETS cap with a trajectory consistent with the Net Zero Strategy.
Developing The UK Emissions Trading SchemeEnergy Bill: Call for Evidence
12/06/23
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 EvidenceFuel tanker weight limits: temporary changes during periods of fuel supply disruption
09/05/2023
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
24/05/2023
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 MandateUK Low Carbon Hydrogen Certification Scheme
21/04/23
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
21/04/23
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 AirportCall for Evidence Soil Health
05/02/23
A soil health data gathering challenge that requires further consideration is the ‘end use’ of the soil.
Call For Evidence Soil HealthEnergy Intensive Industries Compensation Scheme Net Zero Conditionality Questionnaire
24/02/23
The Association does not support the attachment of conditions to compensation provided under the EII compensation schemes.
Energy Intensive Industries Compensation Scheme Net Zero Conditionality QuestionnaireCommission for Carbon Competitiveness Call for Evidence
14/03/23
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 EvidenceEnvironmental Permitting Standard Rules Consultation No 26
13/01/23
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 262022 Consultation Responses
Review of Hybrid and Distance Working
28/10/22
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 WorkingNet Zero Review
26/10/2022
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 EvidenceHydrogen Transport and Storage Infrastructure
22/11/22
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.
HydrogentransportandstorageBusiness Models for Greenhouse Gas Removals
26/09/2022
The Association agrees that the Government should develop a GGR Business Model which enables a diverse portfolio of GGR technologies to deploy at scale.
Domestic Maritime Decarbonisation
04/10/2022
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.
Supporting Recycled Carbon Fuels through the RTFO
19/09/2022
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 RtfoEnergy Intensive Industries Exemption Schemes
16/09/22
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.
Extending the UK Reach Submission Deadlines
01/09/2022
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 DeadlinesNational Air Pollution Control Programme
04/09/2022
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
12/08/2022
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.
Potential reforms to UK Capital Allowance Scheme
01/07/22
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 SchemeCCUS: Industrial Carbon Capture Business Model
10/06/2022
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: Dispatchable Power Agreement Business Model
10/06/2022
We agree that the proposed Availability Payment component of the DPA Contract incentivises efficient decarbonisation.
CCUS Dispatchable Power Agreement Business ModelHydrogen Business Model and Net Zero Hydrogen Fund: Market Engagement on Electrolytic Allocation
06/05/2022
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 ConsultationUK Emissions Trading Scheme Free Allocation Review
23/04/2022
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
03/04/2022
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 IdeasRESPONSE TO JET ZERO: FURTHER TECHNICAL CONSULTATION
21/04/2022
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 ConsultationEmbedding standards and pathways across cyber profession by 2025
20/03/2022
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 Scottish Government decapitalisation rates
11/03/2022
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.
Response to the Call for Evidence on hydrogen-ready industrial boilers
14/03/2022
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.
Response to the UK Reach - PFAS RMOA Call for Evidence
30/01/2022
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.
2021 Consultation Responses
Non-domestic rates - procedures in proposals and valuation notices etc: consultation
15/12/21
Non Domestic Rates Business Rates Response December 15 2021Review of Basic Principles Committee Practice
10/12/21
Review Of Basic Principles Committee PracticeMaking Flexible Working the Default
3/12/2021
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 2021Setting of Decapitalisation Rates
15/12/2021
UKPIA’s view continues to be that if set fairly, subject to consultation and within the context of existing case law, then continued prescription of decapitalisation rates is the preferred option.
Ukpia Response Setting Decapitalisation Rates For Northern Ireland For The Non Domestic Rates RevaluationDesigning a UK low carbon hydrogen standard
25/10/2021
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 ResponseDesigning the Net Zero Hydrogen Fund
25/10/2021
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 ResponseResilience Strategy Call for Evidence
27/09/2021
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 EvidenceDesign of a business model for low carbon hydrogen
25/10/2021
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 ResponseMandating the use of sustainable aviation fuels in the UK
19/09/2021
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 ResponseCO2 emissions regulatory framework for all newly sold road vehicles in the UK
22/09/2021
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 ResponseConsultation: more frequent revaluations: Fundamental Review of Business Rates
24/08/2021
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 240821Heavy goods vehicles: ending the sale of new non-zero emission models
3/09/2021
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 ResponseRole of Biomass in achieving Net-Zero
15/06/2021
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 industriesSchemes to compensate energy intensive industries
09/08/2021
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 schemesDecapitalisation Rates Wales
16/06/2021
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 2021Response to Downstream Oil Resilience Bill
12/07/2021
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 ResponseNext Steps for RTFO
23/04/2021
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 StepsMandatory climate-related financial disclosures
05/05/2021
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 ReportingUK ETS Free Allocation Review
23/04/2021
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 ReviewInquiry into the role of hydrogen in powering industry
20/04/2021
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 ResponseCCUS Market Engagement on Cluster Sequencing
10/03/2021
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 SequencingHydrogen in Wales
09/04/2021
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 Wales2020 Consultation Responses
Transport Decarbonisation Plan
06/01/2021
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 PlanGreenhouse Gas Removals Call for Evidence
26/02/2021
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 vehiclesBEIS Super Inquiry - COVID-19
8/10/2020
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 19BEIS Committee - Impact of COVID 19
10/06/2020
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 CommitteeCarbon Emissions Tax
29/09/2020
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 TaxRTFO Buy Out
11/08/2020
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 OutIntroducing E10 Petrol
03/05/2020
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: ConsultationUK Global Tariffs
05/03/2020
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