UKPIA Consultation Responses

2021 Consultation Responses

Decapitalisation 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 2021
Response 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 Response
Next 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 Steps
Mandatory 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 Reporting
UK 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 Review
Inquiry 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 Response
CCUS 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 Sequencing
Hydrogen 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 Wales
National security and investment: mandatory notification sectors

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.

National Security and Investment
Greenhouse 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.

Greenhouse Gas Removals

2020 Consultation Responses

Transport Decarbonisation Plan

31/08/2020

Transport is now the highest in-use emissions producing sector in the UK. Whilst efficiency improvements in internal combustion engine (ICE) technologies have improved average per-vehicle emissions, overall miles travelled have increased. Evidently, transport has proven a stubborn sector to decarbonise in the UK.

Transport Decarbonisation Plan
Ending Sale of Petrol and Diesel Vehicles

31/07/2020

UKPIA is supportive of the role of electrification in decarbonising UK transport – one technology of many – and calls for close government-industry partnership, and regular and frank assessment of available technologies to ensure up-to-date, evidenced policy making. UKPIA will continue to work with government on the challenge of reaching net zero.

Ending the sale of new petrol and diesel vehicles
BEIS 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 19
BEIS 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 Committee
Carbon 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 Tax
RTFO 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 Out
Introducing 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: Consultation
UK 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 Tariff
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