UKPIA Consultation Responses

2023 Consultation Responses

Commission for Carbon Competitiveness Call for Evidence


UKPIA 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

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.

Hydrogen Transport and Storage Infrastructure
Business Models for Greenhouse Gas Removals


UKPIA 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
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


UKPIA 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. UKPIA 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
Developing the UK Emissions Trading Scheme


UKPIA supports alignment of the UK ETS cap with a trajectory consistent with the Net Zero Strategy. However, although the additional objectives of providing a smooth transition for participants have been considered, the cap and trajectory must also take into account the availability and affordability of the technologies enabling installations to reduce their emissions in line with the cap trajectory.

Developing The UK Emissions Trading 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


UKPIA 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.

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


UKPIA 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.


UK Emissions Trading Scheme Free Allocation Review Call For Evidence
Low Carbon Fuels Strategy - Call for Ideas


UKPIA’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.

UKPIA 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. 

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


UKPIA 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.

UKPIA Response To Proposal For Legislation To Improve The UK Cyber Resillience
UKPIA response to Scottish Government decapitalisation rates


UKPIA 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.

UKPIA Scot Gov Response Decapitalisation Rates 2022
UKPIA 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.

UKPIA Hydrogen Industrial Boilers
UKPIA 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].
UKPIA and our members are keen to help the UK Government to meet the commitment to phase out the use of PFOAs. 

UKPIA Response To The UK REACH – PFAS RMOA Call For Evidence
Business Rates Review Technical Consultation


The proposed system of penalties is overly complex and penal. The proposed penalty placed upon failure to notify of changes of 2% of RV could be material for some ratepayers. An initial cap of £500 should be introduced before a warning letter is received.

UKPIA Technical Consultation Response
Fuelling the Future, Motive Power and Connectivity


A broad range of approaches will be required in order to meet future transport needs and connectivity while achieving the lowest possible Greenhouse Gas (GHG) emissions. A joined-up approach to Government fuel policy is therefore required to meet future transport requirements, taking account of the needs and technologies suitable for each transport mode. 

UKPIA 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.

Flexible Working The Default
Setting of Decapitalisation Rates


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.

Setting Decapitalisation Rates For Northern Ireland
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.

Low Carbon Hydrogen Standard
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.

Net-Zero Hydrogen Fund
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.

National Resilience Strategy 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.

Hydrogen Business Model
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.

New Road Vehicle CO2 Emission
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. 

HMT Revaluation Cycle
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).

The Role of Biomass in Achieving Net Zero
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
National security and investment: mandatory notification sectors


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


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


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


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


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 Tariff
Share this