Opinions and Papers
These papers are distilled dispatches from the energy frontline. None of the collations of notes and materials below is intended to indicate that legal materials needed to make an assessment are complete. No legal advice is offered in providing these materials.
They are, however, food for thought.
2026
More Connection Barriers (March 2026)
Our future, the government has decided, fundamentally and throughout all areas of our lives, will depend upon AI and if we are to have a competitive economy we must take steps to facilitate it urgently.
AI requires energy-hungry data centres. How can they connect to the network in any reasonable period of time? How can there be any urgency in play when the connection queue is far greater than the capacity available?
In the connection queue for demand projects, perhaps surprisingly, data centres are...
2025
Unfair Competition (November 2025)
There is an interesting case by Zenobe Energy Limited before the Competition Appeal Tribunal.
The core of the Zenobe claim is that short-duration energy storage (SDES) earning its income from revenue stacking is being disadvantaged by the introduction of the cap and floor scheme because:
(a) the scheme supports long duration storage (LDES) with an investment floor (a percentage of the investment floor will be supported by the scheme); and
(b) projects with that investment floor support are assumed...
Cheaper Clean Power (September 2025)
Electricity has both costs and prices. Labour promised a £300 reduction in domestic electricity bills by 2030 and said that only clean power would run the electricity system by that date. That promise makes sense if there are plans to bring prices down and to keep costs low.
What will Make Prices Come Down?
GB electricity costs are high. Gas sets the price for wholesale costs for ~98% of the time. Thus for ~98% of the time gas is needed...
Energy Policy End-to-End (August 2025)
There are multiple problems facing the growth of renewables, all the way from rooftop solar (caused by issues with rental agreements, re-sale values, network hold-ups) to there being insufficient heavy plant to create traditional inertia on networks.
As well as these problems and others of the same order (many being addressed in government policy papers, in NESO decisions or in promised consultations), there are bigger problems, each with their own...
The Future for Renewables Generation (July 2025)
Developers of small to mid-sized renewable energy generators - anything up to 99MW solar farms or 20+ wind turbines and most biomass and short-duration batteries – would have experienced a check to their business as a result of the introduction of the new revolutionary connections regime. While the connections process paused to allow the changes to be made to its arrangements, all these developers would have been forced to pause, too.
The big question for these developers (and the sheer number of outstanding applications for connections shows there are...
Cap and Floor Scheme: Will there be a Window 2?
(June 2025)
We are now at the start of the first bidding round for the cap and floor long duration battery energy storage (LBESS) scheme. The doors for applicants closed on 9 June. Some have asked whether that’s a deadline: Ofgem describes it as such but fudges the possibility of extension when it says:
The deadline for submitting applications is 9 June 2025. After this date, applicants will not have the automatic right to...
Cap and Floor Scheme Update (May 2025)
The cap and floor scheme is a state-aid subsidy scheme aimed at supporting long duration energy storage (LDES). The floor, or guaranteed income, covers project cost (debt and equity) and a profit cap limits upside to a level (yet to be determined) that is judged to be ‘fair’.
Ofgem recently announced the scheme target as (in sum) >50MW 8 hour batteries.
The scheme has been put together in haste (not a criticism). It is still being put together, although Window 1 opened for applications on 8 April; it closes on...
The New Connections Regime (February 2025)
Connections are ‘paused’ until the new connections regime is in place, i.e., it isn’t possible to obtain a connection at present. That pause affects both transmission and distribution connections. Once the pause has ended, a new regime for both comes into effect and changes the development landscape.
The scale of the change is intended. The new regime aims to...
The Connections Pause (January 2025)
New applications for connections needing a TIA or transmission impact assessment (all plant on all networks over 1MW, shortly to be 5MW) are subject to a pause, ending no later than 31 May 2025.
NESO, the transmission system operator, has ceased dealing with applications until its new connections regime is in place or, if sooner, 31 May 2025.
The distribution networks (DNOs) will accept applications but...