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TOPIC: HMRC Consultation on White Diesel

HMRC Consultation on White Diesel 17 Aug 2019 19:34 #108755

  • Andy Soper
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A reminder - this consultation closes on 10 September and HMRC are expecting to be flooded with responses from individuals! Although I am attending a meeting with HMRC on 28 August it would help if others could respond.............Any more comments?

My personal draft response is:
Questions for diesel fuelled craft users and owners
5.6 If you own more than one craft please answer the questions for each craft

Q9) Where do you use your craft? If more than one type of location please estimate in percentage terms the amount of time per year your craft spends in these areas.

21m Dutch Barge
 A river (please specify which) Thames - 90%
 A canal (please specify which)
 Inland lakes / broads (please specify which)
 The coast (please specify where) Thames estuary 10%
 International (please give details) Has cruised in Netherland, Belgium and France in past years.

13m Narrowboat
 A river (please specify which) Thames – 70% Wey - 5%
 A canal (please specify which) Grand Union, Oxford, Basingstoke 20%
 Inland lakes / broads (please specify which)
 The coast (please specify where) Thames tideway - 5%
 International (please give details)


Q10) What do you use your craft for? If more than one type of use please estimate in percentage terms the amount of time per year you use your craft for.
 Commercial only - 0
 Private use only - 100%
 Predominantly commercial use with some private pleasure use - 0
 Predominantly private pleasure use with some commercial use - 0
 Permanently moored houseboat with occasional short distance propulsion by diesel motor to another mooring - 0
 Fixed mooring, residential only (i.e. no propulsion) - 0
 Continuous cruiser/boat without a home mooring - 0

Q11) Where do you usually buy your diesel fuel? If more than one type of location please estimate in percentage terms the amount of time per year your craft uses these areas.
 Marina (please specify which) Bourne End 20%
 Port (please specify which)
 Delivered by supplier 80%
 Other (please specify)

Q12) How much diesel do you purchase at any one time?

1000Litres HLP and 50-500 litres propulsion

Q13) How often do you refuel your craft?

3 – 4 times a year

Q14) If the place where you currently buy fuel did not supply white diesel, where would you buy fuel from? What difficulties would you encounter?

Local garage using 20ltr jerry cans. Some garages do not realise that the rules for petrol and diesel carriage are different! Added risk of pollution when fuelling from jerrycans against using hose and nozzle.

Q15) Approximately how many litres of diesel fuel do you use in a typical year:
 for propulsion for private use - 200

 for propulsion for commercial use – None

 for on-board non-propulsion use - 1200

 for other purposes (please specify)? - None

Q16) Are the purposes specified in question 15) fuelled from the same tank? If “yes”:
a. Would it be possible to fit a separate fuel tank for non-propulsion purposes? If not, please outline your reasons;

The Barge has two tanks – one for propulsion and the other for cooking (diesel Rayburn) heating (C/H boiler) and power generation (diesel powered generator).

The narrowboat has only one tank integral to the stern of the boat. The engine is used for power generation, water heating and there is a diesel fired stove for space heating. There is no space in the engine area to fit a second tank and significant re-modelling would be needed to achieve this.

b. How costly would this be and how prohibitive would this be for you?

Probably £5000 to re-model engine area and the bathroom immediately forward of it.

c. How long typically would it take to run down your red diesel stock? 12 months


Q17) Do you foresee any problems with refuelling if you are required to use white diesel for propulsion e.g. areas where you would be concerned that white diesel would be unavailable? Please provide details of the likely implications.

If the local marina changes over its tank to white diesel then there would be some concern as to how soon they could deliver white uncontaminated with red traces. However it is likely that they and all inland RDCOs will change from red to white. However - below Teddington the Thames tideway is predominantly commercial and it is unlikely that fuel suppliers will want to provide white.

Q18) If you use your craft for a mix of commercial and private pleasure use, how easy would it be to completely remove red diesel from your fuel tank after commercial use, before using white diesel for private pleasure use? Please provide details.
N/A


Penalties
Q19) Do you agree with aligning penalties for misuse of red diesel in private pleasure craft with the current penalties for misuse of red diesel in road vehicles is appropriate? If not, what difficulties do you foresee?
Yes – after a suitable period of transition for both RDCOs and Boat owners – suggest two years.

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org

HMRC Consultation on White Diesel 03 Aug 2019 19:37 #108249

Hi Andy,
I prepared for this day years ago by installing an additional fuel tank which meant that I could receive deliveries by road.
Unfortunately there don't seem to be any suppliers willing to do that these days so the cost of running my boiler and generator has risen considerably already. I've taken to buying white diesel in Jerry cans because my old Daf seems to run much better on it. and the price is favourable against the price of propulsion only red. Going by today's base prices for red diesel at around 90 ppl it doesn't take a genius to work out that white will be around £1.64ppl at the same boat yards so it looks like I am going to have to invest in some more Jerry cans, some for red from land based suppliers and some for white from the cheapest nearby filling station.

Keith

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HMRC Consultation on White Diesel 18 Jul 2019 19:25 #107765

  • Andy Soper
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And for convenience I have attached the Consultation questions in a .doc format to allow easily edited responses

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org

HMRC Consultation on White Diesel 18 Jul 2019 19:23 #107764

  • Andy Soper
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Diesel Fuel for Propulsion – Implementation of the Court of the European Union (CJEU) judgement on diesel fuel used in private pleasure craft in UK – HMRC Consultation.

( www.gov.uk/government/consultations/implementation-of-the-court-of-justice-of-the-european-union-cjeu-judgment-on-diesel-fuel-used-in-private-pleasure-craft )

Explanation:

The CJEU have now ruled that the UK system of allowing pleasure craft to buy and use red diesel, with the full rate of duty paid, for propulsion is contrary to the Fuel Marker Directive. Propulsion fuel must be unmarked without a dye or chemical marker and bought with full duty paid – in short – white road diesel.

So what you say – we are leaving the EU. However if we leave without a deal on 31 October we will continue to need to have only white diesel in our propulsion tank when we have crossed into the EU. If we leave with a deal we are subject to EU regulation throughout the transition period – currently expected to be 2 years from 31 October 2019.

The UK government intends to remove the option of private pleasure craft to use red diesel for propulsion and require them to use white diesel because the other options available have been ruled illegal by the CJEU. They propose to align the penalties for using red diesel for propulsion with the current penalties for illegal road use.

The consultation is principally about the transition period that is needed for boat owners to ensure that their propulsion tanks contain white diesel without any contamination and for the trade to make supplies of white diesel available at the waterside.

In the consultation link above boat owners are requested to answer the questions in paragraph 5.6 – numbers 9 – 19. (Questions 1-9 are for fuel suppliers).

Most of the questions are about your craft and its use.

The key ones are:
14 - If the place where you currently buy fuel did not supply white diesel where would you buy your fuel from? What difficulties would you encounter?
16 – Are the purposes specified in Q15 (propulsion and heating) fuelled from the same tank? If 'Yes' Would it be posible to fit a separate fuel tank for non-propulsion purposes. If not, please outline your reasons; How costly would this be and how prohibitive would this be for you? How long typically would it take to run down your red diesel stock?
17 – Do you foresee any problems with refuelling if you are required to use white diesel for propulsion e.g. areas where you would be concerned that white diesel would be unavailable? Please provide details of the likely implications/
19 – Do you agree with aligning penalties? If not what difficulties do you foresee?

There is also the statement that 'All respondents should tell us about concerns they have about the impact of the proposals that is not covered by their answers to specific questions.'

As HMRC have specifically rejected organisations collating responses it is important that individuals respond. Responses are required by 9 September to This email address is being protected from spambots. You need JavaScript enabled to view it.

Commentary:

HMRC believe that there are 150,000 pleasure craft in UK and alledgedly 4,000,000 UK adults took part in a boating activity in 2017(this misses the point as this includes unpowered craft). Some 6.4 million litres of red diesel were supplied to pleasure craft in 2017-18 – and the figures suggest an average of 43 litres per boat per annum! Barges can be expected to consume a little more!

Barges with separate propulsion and a heating, cooking, power generation (HLP) tanks will be little affected – except that obtaining waterside RED diesel is likely to become more difficult as many marina and boatyard pumps and tanks will be changed over to dispensing white diesel only.

Residential boats owners whose primary or only residence is their boat at fixed moorings and only move occasionally will continue to be able to purchase red diesel at the lower duty rate for all purposes by providing documentation such as a Residential mooring licence, council tax bill for the mooring or other documentation showing permanent residence. This continues the current practice in Excise Notice 554 - Article 4.7.

The hardest hit will be the 'continuous cruiser' (boat without a home mooring) with only one fuel tank who will have to buy all fuel, propulsion and HLP, at the full duty rate. I would be particularly interested to hear from members who come into this category.

The standard HMRC test for red diesel is by taking a fuel sample and checking for both red dye and the hidden chemical marker. I will be making representations to ensure that continues and that staining of pumps, pipes and filters is not seen as proof of historic crime!

There is some small advantages to be seen in these proposed changes – it is EU proof – so if you are legal in UK then you are legal throughout the EU. It will be much easier in the future to ensure your propulsion tank is filled with white diesel.

Happy to take questions or comments. I expect to attend two HMRC meetings on this subject before the implementation and transition periods are announced. I would be delighted if you copied me on any response you make to HMRC.

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org
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