UKPIA Consultation Responses

2021 Consultation Responses

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
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