Clean power

ESN responds to LDES cap and floor window 1 minded-to decisions

Date
August 19, 2026

The Electricity Storage Network (ESN) has responded to Ofgem’s consultation on the Long Duration Electricity Storage (LDES) Window 1 minded-to decisions. Our response highlights concerns about the impacts of concurrent market and regulatory reforms on storage and calls for further LDES cap and floor windows.

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.

Table Contents

At a glance

Key recommendations

  • DESNZ, Ofgem and NESO should undertake an urgent holistic review of storage policy and market reforms
  • Confirm that further LDES cap and floor windows will be opened and provide clarity on the timing and design of the next LDES window as soon as possible, including the capacity that may be required
  • Provide urgent clarity on LDES operational and licence conditions.

ESN will continue to engage with its members and policymakers on the development of LDES policy, with a focus on ensuring that reforms provide the investor certainty needed to meet Clean Power 2030 deployment targets. For more information or to discuss our response, please contact ESN lead Olly Frankland.

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