The Regulatory Assistance Project’s (RAP) and ClientEarth’s Concerns with UK Capacity Mechanism’s State Aid Conformity – Follow-up

The Regulatory Assistance Project (RAP) and ClientEarth contend that the UK government (DECC), National Grid, and Ofgem have underestimated available resources, leading to an exaggerated resource adequacy problem. They argue that treating interconnectors as generation would add at least 2.6 GW of capacity and that conventional generation availability is likely in the mid to low 90% range. Consequently, the authors claim the market-wide capacity mechanism is unnecessary, risks over-procuring national resources, undermines EU interconnectivity goals, and may not comply with state aid requirements of necessity and proportionality.

• The UK's analysis of resource adequacy is based on overly conservative assumptions regarding interconnector capacity, which leads to an over-estimation of the adequacy problem and an exaggerated amount of procured electricity generation capacity.
• Treating interconnectors in the same manner as generation would increase available capacity by at least 2.6 GW, contradicting the UK's claims of uncertainty regarding future interconnector flows.
• National Grid, Ofgem, and DECC underestimate the availability of conventional generation; evidence suggests availability should be in the mid to low 90% range during scarcity when strong incentives exist.
• The combined effect of underestimating interconnector contributions and generator availability likely removes at least 4 GW of capacity from the capacity stack, overstating the need for capacity incentives.
• The proposed capacity mechanism may violate EU state aid rules because it is not necessary or proportional, and it threatens EU interconnectivity goals by excluding interconnector capacity from participation.
• Ofgem's 2014 Electricity Capacity report indicates that supply security will remain above DECC's reliability standard (1 in 8 years) even under pessimistic assumptions, with a predicted disconnection risk of 1 in 31 years.
• Demand Side Response (DSR) participation in capacity auctions has been hindered by harsher collateral requirements and a lack of access to longer contracts compared to new or refurbished generation.

APA

ClientEarth (n.d.). The Regulatory Assistance Project’s (RAP) and ClientEarth’s Concerns with UK Capacity Mechanism’s State Aid Conformity – Follow-up. https://www.clientearth.org/media/m41jjcni/the-regulatory-assistance-projects-rap-and-clientearths-concerns-with-uk-capacity-mechanisms-state-aid-conformity-xxx-follow-up-coll-en.pdf

Chicago

ClientEarth. The Regulatory Assistance Project’s (RAP) and ClientEarth’s Concerns with UK Capacity Mechanism’s State Aid Conformity – Follow-up. n.d. https://www.clientearth.org/media/m41jjcni/the-regulatory-assistance-projects-rap-and-clientearths-concerns-with-uk-capacity-mechanisms-state-aid-conformity-xxx-follow-up-coll-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=The Regulatory Assistance Project’s (RAP) and ClientEarth’s Concerns with UK Capacity Mechanism’s State Aid Conformity – Follow-up |url=https://www.clientearth.org/media/m41jjcni/the-regulatory-assistance-projects-rap-and-clientearths-concerns-with-uk-capacity-mechanisms-state-aid-conformity-xxx-follow-up-coll-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearthndregulatory, author = {{ClientEarth}}, title = {{The Regulatory Assistance Project’s (RAP) and ClientEarth’s Concerns with UK Capacity Mechanism’s State Aid Conformity – Follow-up}}, publisher = {ClientEarth}, url = {https://www.clientearth.org/media/m41jjcni/the-regulatory-assistance-projects-rap-and-clientearths-concerns-with-uk-capacity-mechanisms-state-aid-conformity-xxx-follow-up-coll-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }