Our response to Ofgem’s consultation on the financial framework for the LDES cap and floor scheme

Our submission draws on insights from Electricity Storage Network members, industry workshops and wider stakeholder engagement. This is part of our ongoing work to ensure that the LDES regime can support delivery of Clean Power 2030 and a reliable, decarbonised electricity system.

A full list of recommendations is included in our consultation response, which aims to ensure the scheme is accessible, fair and strategically aligned with Clean Power 2030 delivery.

Our top five recommendations

1. Clearer guidance and transparency on how non-administrative cap and floor levels will be scored
2. Reforms to ensure the scheme reflects the greater risk and cost profile of LDES technologies compared to interconnectors
3. Clarity on how projects will be assessed, including use of standardised templates and definitions
4. A published LDES target capacity for window 1, with engagement from NESO and alignment with other assessments (SSEP and FES 2025)
5. Revisions to incentives, inflation assumptions, and treatment of residual value to avoid deterring investment.

What’s next?

The Electricity Storage Network will continue to engage with Ofgem, DESNZ and NESO as the scheme is developed.

At our next innovation and technology working group meeting on 16 September, we will discuss the latest developments on the LDES cap and floor. Book your place here.

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

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