While there were mixed views among ESN members on many aspects of the consultation, reflecting their different views on the LDES cap and floor, a survey of our working group focusing on LDES showed broad agreement in support of further application windows. Members also highlighted the need for urgent clarity and certainty regarding licence conditions for how LDES assets will be expected to operate to ensure continued investment in electricity storage.
While ESN members recognise the benefits of deploying long duration energy storage at scale, they are increasingly concerned that this and several other significant market reforms are being developed in isolation. Individual reforms to national pricing, locational procurement of response and reserve services, network charging, CMP470, BSC P462 and repetitive re-trading solutions could fundamentally reshape the commercial and operational environment for storage. ESN members therefore believe there is an urgent need for a holistic review of the policy and market reforms for storage, assessing how these interact, establishing a clear direction for implementation and providing greater certainty over the future market landscape.