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Clean power

Electricity Storage Network response to Ofgem’s Frequency Risk and Control Report consultation

Date
September 12, 2025

Table Contents

At a glance

The Electricity Storage Network has submitted its response to the 2025 FRCR Ofgem consultation, supporting key proposals and calling for changes to ensure storage can continue playing its vital role in energy system security. The world-leading frequency response services, managed by NESO and delivered by battery storage, continue to enable the clean energy revolution in GB and help deliver Clean Power 2030, while reducing costs for consumers. The maturity and liquidity in these critical system services provides NESO the ability to move forwards and propose further reductions in the minimum level of system inertia, while maintaining a secure energy system.     

We welcome and agree with NESO’s proposals to:

  • Reduce the minimum system inertia requirement to 102 GVA.s
  • Procure an additional 200 MW of Dynamic Containment-Low.

These changes recognise the proven ability of fast-acting battery storage to reduce consumer costs and maintain resilience. This is a capability that will only become more important as GB heads towards Clean Power 2030 and with increased largest loss from new assets like Hinkley Point C.

However, our members are concerned that the timeline and connection requirements for NESO’s long-term stability tenders are likely to exclude viable projects, particularly in light of delays to NESO’s connections portal. We’re recommending:

  • Extending the long-term 2029 invitation to tender deadline to Q1 2026
  • Ensuring stronger industry engagement in the move to locational procurement of response and reserve services and assessing how these changes will impact future FRCR reports.

For further information or to discuss our response, contact Olly Frankland (ESN lead).

Key recommendations

  • Ofgem to approve the NESO FRCR report recommendations for the reduction of the minimum inertia level to 102 GVA.s and the additional procurement of 200 MW of DC Low.
  • Ofgem to recommend that NESO should extend the long-term (Y-4) invitation to tender period until the end of Q1 2026 to allow further time for industry due to restrictions and delays (caused in large part by the NESO portal issue).
  • Ofgem to recommend that NESO ensures considerable effort is put into engaging the industry in the shift to locational procurement of reserve and response services.
  • Ofgem to recommend that NESO assesses the impact of locational procurement on the FRCR reporting process.
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