Elexon’s response to DCUSA’s consultation on Removal of Residual Charging for Storage Facilities in the CDCM and EDCM

Summary

Elexon’s response supports the overall intent of the modifications, which is to address concerns raised by Ofgem and BEIS by excluding imports to storage facilities from the calculation of residual DUOS charges. However, we raised concerns with the detail of the proposals:

  • Inconsistencies between the DCUSA proposals and related CUSC modification proposals (i.e. CMP280/281) may result in unintended or perverse outcomes
  • Aspects of the DCUSA proposals could have been explained in more detail

Elexon will continue to support the DCP341/342 workgroup and argue the case for alignment between the DCUSA and CUSC proposals.

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