Memorandum from the Association of United
Kingdom Oil Independents
The Association of United Kingdom Oil Independents
(AUKOI) is a Membership organisation representing independent
companies involved in wholesale sales, distribution and retailing
of petrol, diesel and other petroleum products in the United Kingdom.
The Members of AUKOI are variously involved with retail supply,
as both independent retailers and supermarkets and represent at
least 25% of the petrol/diesel retail market in the United Kingdom.
Your letter of 23 July invited our views on
the appropriateness or otherwise of the fuel industry not being
listed as a Category 2 Responder and able thereby to be aware
of the nature of the contingency planning process around the country.
Having consulted AUKOI Members, I would advise
you that this Association is of the opinion that none of its Member
companies should be included as Category 2 Responders within the
framework of the proposed draft Bill. We concur with UKpia's views
that this would in essence duplicate the requirements of the Downstream
Oil Emergency Response Plan leading to unnecessary duplication
of arrangements and possible confusion.
We are also concerned at the anti-competitive
issues that might arise from the sharing of information and joint
management of fuel supplies that might prove necessary under these
provisions. AUKOI would not engage in any practices in breach
of current United Kingdom or European competition law.
Thank you for giving us the opportunity to comment
on the draft Bill and I hope these comments prove useful for your
purpose. Please contact me again if you need any further information.
29 August 2003