Dear Minister Burke TD,
I am writing to you on behalf of the Irish Petrol Retailers Association (IPRA). Our members represent independent forecourt owners who provide essential energy infrastructure and local employment across Ireland’s urban and rural communities.
The IPRA and its members share the Department’s absolute commitment to maintaining world-class safety and environmental standards on Irish forecourts. We fully support the objectives of the Dangerous Substances (Flammable Liquids and Fuels Retail Stores) Regulations 2019. However, based on our members’ practical experience on the ground, we believe there is an excellent opportunity to collaborate with your Department to refine how these regulations are administered. By working together, we can ensure the framework remains highly effective, consistently applied, and economically sustainable for small businesses.
To that end, we would welcome the opportunity to discuss two constructive proposals based on highly successful European regulatory models:
- Transitioning Toward a Centralised Inspection and Licensing Framework
Currently, the administration of dangerous substances licensing is decentralized across individual local authorities, creating localized variations in timelines and compliance benchmarks. The IPRA proposes working collaboratively with your Department to explore the creation of a centralized, specialized national licensing body, drawing on international best practices:
• The United Kingdom Model (DSEAR System): The UK utilizes a uniform, centralized legislative framework under the Dangerous Substances and Explosive Atmospheres Regulations. Critically, the UK has largely replaced burdensome periodic re-licensing loops with an indefinite Petroleum Storage Certificate. Once a station successfully clears a standardized national safety audit, the certificate remains valid indefinitely unless major infrastructure alterations occur. This drastically eliminates administrative overhead while preserving safety.
• The French Model (ICPE System): In France, fuel distribution facilities are regulated under a centralized national classification framework (Installations Classées pour la Protection de l’Environnement). Instead of localized rules, stations are neatly categorized strictly based on their annual fuel capacity thresholds. This guarantees that technical expectations are predictable, proportional to business size, and uniformly enforced by specialized state engineers, removing any local council ambiguity.
The IPRA believes a centralized framework combining elements of these systems—perhaps managed via a dedicated petroleum unit within the Health and Safety Authority (HSA)—would establish a predictable, uniform, and fair environment for Irish operators.
2. Implementing Pragmatic 3-to-5-Year Compliance Roadmaps and State-Backed Green Grants
Achieving and verifying full compliance with the 2019 regulations—such as installing advanced Petrol Vapour Recovery (PVR) systems and conducting triennial underground tank integrity testing—frequently demands capital investments that reach tens of thousands of euros per site. Tight lending environments mean that even deeply committed, safety-conscious owners require a practical financial buffer.
We urge the Department to integrate the compliance loop with financial partnership strategies used successfully abroad:
• Phased 3-to-5-Year Compliance Roadmaps: Mirroring continental approaches, when sweeping environmental or technical mandates are updated, operators should be granted formal, multi-year compliance windows of 3 to 5 years based on site capacity. This gives smaller, independent stations a manageable, structured runway to schedule technical works and allocate capital smoothly without facing immediate closure.
• State-Backed Green Transition Partnerships: In line with Ireland’s broader National Energy and Climate Plan targets [1.1] and the EU Just Transition funds [1.2], we propose that forecourt upgrades be legally integrated into green enterprise funding. Independent stations are rapidly evolving into multi-fuel hubs accommodating EV charging and alternative fuels. We ask the Department to partner with the Strategic Banking Corporation of Ireland (SBCI) [1.3] or the Sustainable Energy Authority of Ireland (SEAI) [1.4] to establish low-interest green compliance loans or capital grant schemes. These mechanisms would help independent family businesses finance these high-cost safety and emissions modifications.
Independent forecourt retailers want to do the right thing and keep our communities moving safely. We believe that by fostering a partnership approach between the industry and the Department, we can achieve our shared safety goals while safeguarding local businesses.
We would be grateful for the opportunity to meet with you and your policy officials to discuss how we can work together on these constructive initiatives.
Thank you for your time, consideration, and continued partnership with the Irish retail sector.
Yours sincerely,
Michael Griffin
CEO
Irish Petrol Retailers Association