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Feb 4, 2026 Tired of BESS commissioning delays? Start the process earlier than you think Teams often treat the commissioning of battery energy storage systems (BESS) as a late-stage checkbox rather than a project-defining discipline. Projects can succeed or fail during commissioning. However, most commissioning failures stem from organizational, contractual, and procedural lapses rather than technical issues. While many engineers and project managers bring deep experience in solar and wind, you can’t apply the same approaches to energy storage. Energy storage systems are more complex — both technically and commercially — and require a higher degree of integration, training, and engineering discipline to commission a battery energy storage system successfully. A structured, phased commissioning plan brings every discipline together from the outset with clear tasks, ownership, dependencies in their sequential order, and minimizes surprises and delays. This approach not only safeguards project integrity and compliance but also establishes clear responsibilities, fosters ownership, collaboration, and accountability among project stakeholders. Ownership, transparency, and accountability are non-negotiable. Commissioning is not simply that final checkbox at the end of the project. Instead, effective commissioning begins at project initiation and continues as an ongoing process, overlapping with construction, through to acceptance testing. Risks from early decisions made in isolation are often overlooked. However, their impacts become evident later in the project — triggering delays and costly fixes precisely when the schedule can least absorb them. Commissioning problems often result from a lack of a cohesive, integrated plan that considers all stakeholders. While each contractor may have its own comprehensive Responsible, Accountable, Consulted, and Informed (RACI) matrix, minimizing commissioning risks requires a single, fully integrated RACI matrix that addresses all the project’s components and phases. Defining ownership, clear roles, responsibilities, accountabilities, and dependencies at the outset of the project ensures smooth handovers. EPCs, subcontractors, OEMs, owners, and other involved parties often identify scope gaps too late to avoid scheduling delays. These details, although small, are easily overlooked, yet can cause massive headaches and costs. A fully integrated commissioning may seem prohibitively long, detailed, and too complicated for practical use. However, the lack of a master plan often results in rework, confusion, back-and-forth, and ultimately, schedule delays and liquidated damages. Planning for the entire commissioning sequence from the beginning through to project final acceptance reduces surprises later in the project. A good rule of thumb is to plan for the worst and be pleasantly surprised at the end. From silos to signal: coordinating the whole commissioning team Facilitating communication across the entire team helps close gaps. While large calls with multiple parties may seem inefficient, so are commissioning delays! As painful as these calls may be, they remain a necessary investment of time to catch inconsistencies and miscommunication. Daily check-ins focused on commissioning and testing serve as essential touchpoints, breaking down silos, synchronizing activities, and clarifying accountability. At this stage, a third-party commissioning expert becomes invaluable. A seasoned facilitator knows which questions to ask, spots potential red flags long before they turn into schedule killers, and guides both live discussions and asynchronous communication to keep progress on track. Robust standards exist, but compliance doesn't always follow. A common misconception is that BESS is too new and lacks robust regulatory standards, especially for fire risk and safety compliance. In reality, the National Fire Protection Association (NFPA) and the National Electrical Code (NEC) have evolved in step with the industry, with meaningful updates such as UL9540A (5th edition), UL9540 (3rd edition), and new ESS-specific requirements in the upcoming 2026 NEC edition. Additionally, long-standing international standards, like IEC 62619 and the IEC 62933 Series, provide comprehensive safety and performance codes and standards that are well-established, vetted, and globally referenced for decades. The real issue with standards isn’t their existence — it lies in how seriously they are taken. It may be tempting to accelerate the design or testing process by selectively interpreting statutes and accepting the “minimum viable compliance” rather than delivering true industry best practices and high-quality adherence. This pressure often stems from the substantial financial incentives tied to the contractual completion milestones. When completion milestones trigger large contractor payments and give owners progress to report to investors, both sides feel the pull to “just get it done.” Under pressure, shortcuts can start to look appealing. Common shortcuts I’ve seen include incomplete test reports, missing serial numbers and calibration certificates, omitted verification steps, and insufficient photographic documentation. In the worst cases, critical equipment such as medium‑voltage transformers or battery modules — impacting system capacity — end up on the punch list. Once that happens, the finger-pointing begins, or worse, teams walk away assuming “someone else will deal with it.” Experienced contractors know the compliance standards. Shortcuts rarely result from ignorance — they come from gaps in structure, accountability, and oversight. A robust, well-designed commissioning plan is the strongest tool you have to minimize the opportunity for mistakes, both intentional and unintentional. Commissioning ultimately tests project leadership, and many projects stumble right at the final stages. Yours does not have to be one of them. Don’t let your project fall into these preventable pitfalls; develop a well-informed plan from the beginning. Lynn Appollis Laurent < Back Back

Aug 26, 2025 Constructability Part 2 In the last Camelot Energy Group constructability article, we discussed the importance of gathering detailed topography data as it is critical to reduce costly redesigns, permitting delays, and unexpected construction obstacles and issues. In this second constructability article, we are going to go through some considerations that owners and developers need to be taking when putting together project layouts and designs to set the project up for permitting, construction, and long-term success. As we discussed in the last article, in the early stages of development, a preliminary design is typically put together using the sometimes minimal public information on hand. The goal of this initial design is to verify project feasibility, usually in the form of DC and AC system size. Where a lot of project designers go astray is that they primarily focus on module layout and creating as large of a project as possible without considering the other layout considerations that are critical for the project’s success. Doing the due diligence and putting together an accurate and realistic project should always be the goal! Even during the early stages of a project, there are specific layout considerations that should be discussed and ironed out, including site and construction access, medium voltage configurations, module layout, equipment pad locations, wetland locations and mitigations, and overall site hydrology. Site Access: The Forgotten Risk Multiplier Once a potential parcel is identified and a preliminary module layout has been put together, the project team then needs to verify how the site will be accessed for construction and long-term asset management. Project sites will also need access ahead of construction mobilization to do onsite testing for racking as well as for potential tree clearing and site work. Site access may sound simple, but without de-risking how the project will receive racking, modules, transformers, and other equipment, the project is at risk of facing multiple critical constructability issues. The first thing that needs to be considered is the location of the site’s main entrance. Even projects that are adjacent to a paved road can present challenges, including: Steep topography requiring grading or retaining walls Stream crossings and culverts needing hydraulic analysis Public utility crossings that may require additional design complexities and coordination Local DOT requirements for driveway permits, signage, or acceleration/deceleration lanes It’s important to remember that large semi-trucks, some carrying oversized loads, will need to safely turn into the project site so if the approach angle or turning radius isn’t addressed early, retrofits or access delays can quickly erode construction schedules and budget. Designing the Site Access Road Once the site entrance is located, the project’s access road needs to be laid out with construction, operations, and safety in mind. A well-designed access road doesn’t just connect points A and B it facilitates: Efficient traffic flow for potentially hundreds of daily deliveries Safe two-way traffic for large trucks Designated turnarounds for dead-ends or tight sites Clear routing to temporary laydown and permanent O&M areas Where possible, the road should follow natural contours to reduce earthwork. Additionally, early geotechnical investigations can prevent surprises during grading, particularly in regions with expansive clays, bedrock, or high groundwater tables. The design should also consider future maintenance equipment and weather impacts. Medium Voltage Routing: Hidden Cost Driver The next consideration that needs to be well thought out is how medium or high voltage will be routed and interconnected. This affects not just cost, but also the construction timeline and long-term reliability. Generally, there are two ways of routing MV cables: overhead or underground. There are pros and cons to both: Overhead lines are typically less expensive per foot and faster to install in soft or forested terrain but may require FAA filings (if near airports), additional tree clearing, and more extensive permitting. Underground lines reduce visual impact and are more protected but come with higher costs, greater trenching needs, and longer lead times on materials like duct banks or vaults. Additional onsite testing may also be required to verify sub surface conditions will be acceptable for trenching. Where feasible, routing the MV lines along the site access road reduces the number of disturbed areas, consolidates construction zones, and limits environmental impacts. This “co-location” strategy also minimizes total site clearing and road crossings, saving time, money, and permitting effort. Siting Equipment Pads with Precision Once the site access and MV routing are aligned, the focus shifts to the strategic siting of equipment pads, usually housing inverters, transformers, switchgear, and potentially Battery Energy Storage Equipment. Pads must be located with multiple variables in mind: DC home run distances : Minimize string length to reduce voltage drop and avoid oversized cabling. Voltage drop : Particularly on larger sites, both DC and AC voltage drop must be calculated during the 30% design stage to optimize cable size and verify the site configuration is cost effective. Drainage : Pads should not be sited in low areas where water naturally collects, leading to pooling, flooding, and potentially failed equipment. Like we discussed in our first constructability article, the site’s topography should be considered to avoid storm water run-off issues. Water and electricity don’t go well together! Access : These pads must remain accessible post-construction for maintenance vehicles and emergency responders. This includes making room for service clearances, crane access (for transformer/BESS replacement), and pull-off areas. Wetland and Hydrology Impacts: Early Action Avoids Late Pain Finally, no layout is complete without overlaying wetland, floodplain, and surface water data. Many projects mistakenly treat this as a permitting detail rather than a constructability issue. Ignoring hydrology can lead to: Equipment and roads placed in flood-prone areas Unforeseen permitting delays (jurisdictional waters, buffer zones, etc.) Costly re-routing of cable trenches or roads Long-term operational headaches related to erosion or access loss Construction delays and potentially expensive construction tactics Projects should engage qualified wetland consultants early and plan for buffers that not only comply with regulations but allow for construction maneuvering and long-term asset protection. Having a Civil Engineering firm put together a Storm Water Prevention Plan in parallel with the preliminary layout should be a standard task of any project’s development. Closing Thoughts and a look ahead While it's common for early-stage project designs to focus on maximizing DC and AC capacity, this singular focus often overlooks critical infrastructure and constructability elements. Without simultaneously considering site access, medium voltage routing, and strategic equipment pad siting, even the most efficient module layout can become unbuildable or result in major cost overruns. These oversights can lead to unexpected grading requirements, excessive cable runs, inefficient traffic flow during construction, and even the need for complete redesigns. Integrating these considerations ensures the design is not only optimized for energy production but also practical, buildable, and financially viable over the project's lifecycle. At Camelot Energy Group, we work with owners and developers to make sure these decisions are integrated into the layout process early, reducing project risk and setting the stage for a streamlined construction phase and long-term performance. In upcoming “Constructability” articles, we will dive deeper into other critical factors, including geotechnical challenges and how to de risk the issues that may be lurking under the surface of your next project! Stay tuned for more constructability insights from the Camelot Energy Group! Mark Warner < Back Back

Aug 23, 2024 Solar Availability Series Part 2 Welcome back for Part 2 of Camelot’s series on solar availability, which is an appropriately hot topic as the industry continues to mature. If you’re just joining us for the series, Part 1 can be found here , and it includes some background on the current state of industry assumptions. Today we’ll cover the not-so-simple task of calculating and reporting downtime, along with some implications. Subsequent parts will describe ways of maximizing availabilities and Camelot’s official stance as an IE. Thank you for joining us! Introduction As expressed in Part 1 , availability is a way of quantifying lost generation potential due to outages; it measures whether a component or system is operating when it ought to be. An availability of 100% at any given time means everything is operating when it should, whereas an availability of 0% means the entire component or system is offline. The plot below illustrates a case where the entire site stopped producing power and was restored the following day. There will be more on this figure later. SCADA Data Collected at a Utility-Scale Solar Project Over Two Summer Days To better summarize the operations at a project based on high-resolution data collected at a site, production and availability data are typically aggregated and reported into monthly operating reports (MORs) which are shared with key stakeholders on a project. Monthly numbers are also aggregated into quarterly and annual reports. Because there is typically some seasonal variation in downtime, most folks will refer to annual availability numbers when benchmarking against expectations, and so when we talk about availability assumptions, we are referring to annual averages . A Deeper Dive Into Metrics The simplest but less useful measure of availability is time-based. It’s calculated as Uptime/(Uptime+Downtime) , so it only considers the time it takes to bring the system back online over the period. However, the most useful measure of availability in most contexts is energy-based . It uses an estimate of the energy lost during the period, and is calculated as Actual Production/(Actual Production+Lost Production) . We care more about lost production than anything; when building out a financial model, we multiply pre-downtime production by the assumed availability to arrive at post-downtime production, so we want to use energy-based availability if possible. This is often why, despite PVSYST’s ability to model downtime, the loss factor is most commonly applied outside of PVSYST; the software interprets the loss as time-based and will apply random downtime throughout the modeled year, resulting in an unintended energy-based loss. Time-based availabilities are not well suited for financial modeling, and we recommend time-based metrics only be used if they are defined and used in O&M contracts, as we’ll touch on below. How are uptime, downtime, actual production, and lost production determined? Uptime and downtime are relatively easily defined on a site-level. SCADA systems will typically flag periods when the site or major components are down, and the duration of these events will sum to be the downtime for the site. In cases when a portion of the site is offline, uptime is often weighted by the portion of the affected site (ideally on a production-potential basis). Actual production comes directly from the power meter, typically at the point of interconnect (POI). Calculating lost production usually involves several steps which are all built into the software used to log and report operational data: Determine “expected production” for each timestep based on the energy model for the site and the existing, measured site conditions (eg irradiance). The model should be validated as an accurate representation of the relationship between measured inputs and production. Referring to the plot above, expected production is the red line, which is based primarily on the plane-of-array irradiance (green line). Calculate the energy lost for each timestep, which is represented by the “Δ” in the plot above. Sum energy lost at each timestep across the entire reporting period. The same calculations hold for any reporting period. To calculate an annual availability number based on monthly data, you can sum the monthly time or production values before doing the same math, or take an energy-weighted average of the monthly availability numbers. What about data gaps or QC? Unfortunately, we see data concerns very often at operating sites, and garbage in equals garbage out. Some meters and sensors will have redundancy onsite in case one fails, but if we run into data concerns due to whatever issues arise, all may not be lost. Even in a system-wide SCADA outage or memory failure, some form of data are always being collected or modeled onsite, and inferences can be made. As a couple examples: If an inverter power meter at a site with 5 central inverters starts to fail, but the inverter should still be online, an operator can verify the inverter’s availability using the POI (revenue) meter. The total power at the POI meter minus the power from the other inverters should roughly equal the power from the fifth inverter (“roughly” because of electrical losses and measurement uncertainties, which can generally be determined from operational data anyways). Even if the entire site goes offline for a period of time and no actual measured data is available, besides the power flowing to the grid at the POI, high-resolution meteorological satellite data can be used. Operators can observe the relationship between the solar resource and production during a fully-operational period to fill in the gaps and define expected production. Admittedly, many O&M providers will not go to the effort to fill in data gaps when they occur, which can lead to missing or inaccurate data. This, in turn, can lead to an inaccurate understanding of overall system performance, which in some cases can even impact a project’s valuation: availability is a key factor when reforecasting a project’s future production, and we have seen cases where missing data makes a significant difference in the uncertainty (leading to lower P99s). This is where Technical Advisors such as Camelot Energy Group can help ensure you are working with the most accurate data you can. Not only can availability be calculated based on a fundamentally different basis (time vs energy), but we need to be careful to scrutinize what is included in the definition as well. Until now, we’ve focused on System Availability, but you might find other metrics floating around and serving other purposes. A few common terms and measures are: System Availability - Captures all quantifiable downtime over the entire site for the entire period, with no carveouts. The following is a list of possible synonyms, noting that the definition of every availability metric should be scrutinized because they can be inconsistent: Plant Availability Project Availability Operational Availability Total Availability Overall System Availability (OSA) An inverter fire which caused system-wide availabilities to drop for a significant period of time Component Availability – Captures only the availability of an individual component over a given time. These commonly include inverter availability or module availability , but can be broken into any components, including trackers. Sometimes referred to as Manufacturer Availability . Contractual Availability – Sometimes also referred to as Guaranteed Availability, this metric is the most commonly-confused one of them all. It should be clearly defined in an O&M agreement, and the downtime it includes can vary. The denominator in the calculation is often more complicated than simple “total time” or “total production” during the period, and both parts of the equation can include carveouts for periods which are often deemed outside of the operator’s control. This is the most commonly-reported time-based availability, but we are seeing an increase in contracts which define Contractual Availability on an energy basis. This incentivizes operators to perform maintenance at more optimal (lower resource) times. Balance of System (BOS) Availability – Includes the availability of all components other than the modules and inverters, such as wiring, mounting structures, and monitoring equipment. Sometimes also termed Balance of Plant (BOP) Availability, but as always, the definitions must be scrutinized. Grid Availability – Captures downtime when the grid is not available to accept power generated by the project. This is the most common carveout for contractual availabilities, as it is almost always outside the control of the operator. We hope this moderately deep dive into solar availabilities helps to put the numbers into perspective and emphasize the importance of understanding what metrics you are looking at when evaluating a project’s uptime. We can always go deeper into the topic, and we’d be happy to support with any questions you may have. The next article in this series will cover a number of ways of maximizing availability and improving your metrics. In the meantime, for questions and more details about Camelot Energy Group and our distinct attitude towards these issues, please reach out at info@camelotenergygroup.com . About Camelot Energy Group is a technical and strategic advisor to owners and investors in clean energy and energy storage projects, programs, and infrastructure. Guided by our core values of courage, empathy, integrity, and service we seek to support the energy needs of a just, sustainable, and equitable future. Our team has experience in supporting 7+GW of solar PV and 10+ GWh of energy storage and offers expertise in technology, codes and standards, engineering, public programs, project finance, installation methods, quality assurance, safety, contract negotiation, and related topics. Our services are tailored to a providing a different kind of consulting experience that emphasizes the humanity of our clients and team members, resulting in a high quality bespoke service, delivered with focus, attention, and purpose. Key services include: -Technical due diligence of projects and technologies -Owner’s representative and engineer support -Strategic planning -Training and coaching -Codes and standards consulting -Contract negotiation and support < Back Back

< Back Taylor Parsons Director, Technical Advisory Taylor is Camelot’s Director of Technical Advisory, and has over 10 years of experience in the energy industry. His primary focuses have been in technical due diligence, energy modeling, and analytics for solar, wind, and energy storage assets. Taylor has led some of the largest due diligence engagements for M&A on projects, platforms, and portfolios. Prior to joining Camelot, Taylor was a Team Lead and Project Manager in DNV's M&A and Energy Assessment Teams. He also supported the National Renewable Energy Laboratory's Systems Engineering team engineering and analysis for wind turbines. He has a Bachelor’s Degree in Mechanical Engineering from the Colorado School of Mines, and is actively pursuing his Executive MBA in Energy (renewables focus) from the University of Oklahoma. taylor.parsons@camelotenergygroup.com

May 27, 2026 ERCOT NPRR 1333: Is Your Inverter-Based Resource Eligible for the $25M Grid-Forming Incentive? ERCOT just posted NPRR 1333, a $25M one-time incentive to retrofit existing inverter-based resources with advanced grid-support capabilities (grid forming, specifically). The mechanics are tight: $1,500 per MW of nameplate, paid 12 months after implementation Linear availability haircut below 90% Applications due March 31, 2027; implementation deadline December 31, 2028 First-come, first-served allocation Funded by Load on an LRS basics Section sunsets June 30, 2030 Three things stand out: The cap binds fast. $25M divided by $1,500/MW ~ 16,700 MW of qualifying capacity against ~50 GW of grandfathered ESRs alone, before wind and solar. First movers win. The price point signals intent. $1,500/MW is modest relative to hardware-heavy retrofits, suggesting the target is units where advanced grid support is largely a controls or firmware update. The protocol language hints at this directly, too The impact analysis is striking for what's absent. Based on the recent disclosure, there is no project cost, no system impact, no staffing impact, and no alternatives evaluated. This is a pure market-incentive lever, not an infrastructure program. Building on NOGRR 272 and PGRR 121 (approved by the PUCT in November 2025), NPRR 1333 closes the gap for the existing IBR fleet. ERCOT's own analysis suggests up to 10% improvement in Generic Transmission Constraints (GTC) in West Texas, McCamey, and the Panhandle under tested scenarios. For ESR owners with marginal-cost retrofit paths, the math is worth running this quarter, not next. Contact Camelot Energy Group today to evaluate your options! Raafe Khan < Back Back

Aug 15, 2024 Solar Availability Series Part 1 Welcome to the first of Camelot’s series on solar availability, which is an appropriately-hot topic as the industry continues to mature. We’ll start with a bit of background on the current state of industry assumptions, and plan to cover other topics such as the not-so-simple task of calculating and reporting downtime, ways of maximizing availabilities, and Camelot’s stance as an IE. Thank you for joining us! Why we Care Accurate long-term energy yield analyses (EYAs) are key to understanding revenues for solar projects, and a fraction of a percentage point in underperformance vs these models can have a notable impact on a large project’s financials. For this reason, many folks in the industry are scrutinizing their EYA practices and performing much-needed validations to identify potential gaps in their modeling, but more often than not they exclude the impacts of downtime from their comparisons. This is for good reason. If pure model performance is most important to us, unexpected downtime events can skew their validation results. However, as the industry matures and more data becomes available to us, we find ourselves in a position where we can and should start scrutinizing our downtime assumptions as much as we do our other assumptions; a fraction of a percentage point in additional downtime has the same impact on a project’s financials as more traditionally-scrutinized underperformance. Let’s talk about the current state of the industry’s expectations and how we might improve them, since every little advancement can have a notable impact. A Bit of Background Availability is a measure of lost generation potential due to outages at a project; it answers the question of “is our system operating when it aught to be?” An availability of 100% at any given time means everything is operating when it should, whereas an availability of 0% means the entire site is offline. At an operating project, availability is aggregated and reported into monthly reports, which are then aggregated into annual availability numbers and compared to expected annual downtime levels. The most impactful sources of downtime come from major component failures such as from inverters, which put entire swaths of a system offline at the same time. We will dive into how availabilities are calculated, reported, and maximized in Part 2 of this series. Current State of Availability Assumptions: You Know What Happens When You Assume Several years ago, the industry didn’t have the kind of established history needed to accurately predict or validate what long-term average availabilities will be at newly-proposed solar projects. Engineers with experience with the sites might assume that entire sites would be offline for the equivalent of about 3-5 days per year, independent of how long they have been operating, leading towards expected availabilities of about 98.5% to 99.2%. For modeling simplicity, most everyone assumed a relatively consistent availability throughout a project’s lifetime. Sometimes engineering judgement turns out near-perfect, and in this case we can’t be all that far off; though as projects became operational, the industry started to question itself. Especially early in new projects’ operational lives, downtime was high and availabilities were lower than expected due to teething issues. Even after the initial startup period, many folks started seeing trends whereby their average availability levels below what they had hoped. Enter the validation: especially over the last year, availability assumptions have taken a seat at the validation table. There have been three IEs who have recently updated their assumptions from looking at real-world measured and reported availabilities at operating projects. ICF led the charge with its performance paper published by kWh Analytics in 2023. DNV and Natural Power followed suit with their own methodology updates in early 2024. Others with access to the data have weighed in as well, from NREL to kWh Analytics. Here, we focus in on the results of the IE validations, each of which took slightly different approaches and used different data sets. The table below summarizes the projects which went into the IEs’ comparisons, and some key comments from their results. Here is a summary of the IE’s post-validation default availability recommendations. As you can see, only DNV makes a distinction between different kinds of projects at this time, though every IE noted that they are open to changing their assumptions based on project-specific data such as operator or technology history. In general, DNV’s analysis used more data and resulted in recommendations which are more clearly tailored to the sites. Interestingly, despite every IE noting lower availabilities early in a project’s life, only DNV adjusted their recommendation to treat the first year differently from other years. No IE has taken a stance on availability changes later in a project’s life yet. Also of note, ICF found that fixed tilt systems showed lower availabilities than tracker systems while DNV found the opposite. From this, it should be clear that we as an industry don’t have all the answers yet, but that there’s hope of converging on more robust, data-backed opinions on future availability projections for solar projects. The industry is ever-evolving, and in some ways this may be a moving target, but we will only get better as more projects come online and we continue to focus on validating our key assumptions with the data. We look forward to expanding on this topic in future articles in the series. In the meantime, for questions and more details about Camelot Energy Group and our own approach to these issues, please reach out at info@camelotenergygroup.com . About Camelot Energy Group is a technical and strategic advisor to owners and investors in clean energy and energy storage projects, programs, and infrastructure. Guided by our core values of courage, empathy, integrity, and service we seek to support the energy needs of a just, sustainable, and equitable future. Our team has experience in supporting 7+GW of solar PV and 10+ GWh of energy storage and offers expertise in technology, codes and standards, engineering, public programs, project finance, installation methods, quality assurance, safety, contract negotiation, and related topics. Our services are tailored to a providing a different kind of consulting experience that emphasizes the humanity of our clients and team members, resulting in a high quality bespoke service, delivered with focus, attention, and purpose. Key services include: -Technical due diligence of projects and technologies -Owner’s representative and engineer support -Strategic planning -Training and coaching -Codes and standards consulting -Contract negotiation and support. < Back Back

Oct 30, 2025 NFPA 855 (2026) Taylor Swift dropped her new album, but the NFPA dropped the 2026 edition of 855: Camelot is reviewing the standards and there will be a dedicated post about this in the coming weeks – stay tuned! Please reach out to us if you require guidance on the ensuring your systems are code compliant and you have the best resources to complete fire safety engineering General Scoping: The latest edition has reorganized things which reduce ambiguity and cross references that existed across chapters in prior editions General requirements have been moved into a single chapter; technology specific chapters with tailored rules which should create fewer conflicts and clearer applications during code reviews Large-Scale Fire Testing (LSFT): The latest edition puts a stronger emphasis on LSFT but creates an anchor to UL 9540A. The most significant single change is the introduction of full-scale burn testing with flammable gas ignition. In the short-term, this puts the 2026 NFPA 855 ahead of UL 9540A, as the 4 th edition does not provide a procedure for this gas ignition process. This is expected to be addressed in the upcoming 5 th edition of UL9540A, to be released in March, but in the meantime, specifics of new LSFT procedures are a bit of a gap in the new edition of NFPA 855. Conceptually, the new LSFT is considered an alternative unit-level test, adding to the typical number of UL 9540A tests that need to be reviewed as part of typical due diligence. Engineers, like Camelot, will now need to review cell, module, unit, and LSFT test reports to validate system design and code compliance but, overall, this added testing is expected to result in improved safety. Source: UL For larger, denser designs, the 2026 edition elevates LSFT to an expected component to demonstrate containment, adjacent to unit impacts and realistic configurations (multiple racks, aisle spacing, ceiling effects, heat flux, etc.) Source: Hithium It is important for engineers to budget for real estate when proposing dense BESS layouts with tight clustering. Camelot expects AHJs will ask for both UL 9540A and system-scale LSFT evidence in permitting packages Explosion control: While previous editions allowed owners to comply via either passive (e.g., deflagration panels) or active (e.g., gas detection and ventilation), the 2026 edition will now require manufacturers to use active ventilation measures complying with NFPA 69. Manufacturers may still use passive measures if desired but these, alone, will no longer be compliant with NFPA 855. The new standard also increases the requirements for documentation around explosion control and the rigor of hazard mitigation analyses (HMA). The new edition also provides more specific requirements for supplying backup power to explosion control systems, allowing them to remain operational when grid power is disconnected. Enhanced documentation requirements: The 2026 cycle clarifies HMA expectations (inputs, scenarios, outcomes) and pushes better correlation between detection technologies and mitigation strategies (e.g., clean agent vs water, deflagration prevention vs passive venting). This is a direct response to inconsistent submittals in prior cycles. Camelot expects AHJ to scrutinize HMAs and modeling assumptions, so it is important to be explicit about gas evolution triggers, alarm setpoints, failure modes, fan curves, agent hold times, ventilation rates, fail-safe logic, etc. Owners will need to be ready to work closely with suppliers to provide AHJs with more test data, modeling results, and similar technical information going forward. NFPA 855 also draws a distinction between Emergency Response Plans (ERPs) and Emergency Operations Plans (EOP). Much of this content was previously merged into a single document but going forward, ERPs will focus on firefighter and emergency personnel information, whilst the EOP will provide key information for the owner/operator. The result should be two more targeted and accessible documents replacing a single broad document, but developers will need to plan on refreshing previous templates and some additional time to coordinate separately on these key documents. Technology coverage has been expanded in the 2026 edition which intends to reduce overapplication of Li-specific requirements to chemistries with different risk profiles, like lead-acid, aqueous Nickel, etc. Operations and Maintenance: Since testing expectations have been made explicit, field-based modifications like augmentation may potentially invalidate test representativeness. It is expected that the AHJs will trigger re-evaluations to ensure everything is up to code The latest edition also states that the project owners schedule annual ERP reviews and training for first responders to maintain compliance. This has been the best practice for some time but jurisdictions adopting NFPA 855 will now have grounds to make this a requirement. It is also worth putting this new edition of NFPA 855 into a broader context, as things are moving fast on the ESS codes and standards front. Camelot is closely tracking several related codes and standards efforts, including: NFPA 800 (Battery Safety Code) is a new standard with far more breadth than previous codes, covering all aspects of battery safety from manufacturing and storage to operations and disposal. It goes beyond stationary ESS, as well. The code is still in its first draft, but the Technical Committee is actively working on updates. UL 9540A 5 th Edition: As noted above, the new edition of this critical testing standard will likely provide updated guidance to better address the LSFT requirements put forth in NFPA 855 (2026) and this should be released in March. Camelot’s CEO, Shawn Shaw, is working on an update to the 2022 Energy Storage Systems and the IBC, IFC, IRC, and NEC published by the International Code Council. Stay tuned for more updates and a final publication date soon. Raafe Khan, Shawn Shaw < Back Back

Feb 13, 2025 NERC’s New Compliance Threshold Big changes are coming for renewable energy projects in North America. Starting in May 2025, NERC will require all inverter-based resources (IBRs) with an aggregate nameplate capacity of 20 MVA or more—connected at 60 kV or higher—to register as a Generator Owner (GO) and/or Generator Operator (GOP). If your solar, wind, battery storage, or fuel cell project falls into this category, compliance is no longer optional—it’s mandatory. 1. Understanding the New Requirements Historically, NERC registration was only required for facilities above 75 MVA and 100 kV, but these new thresholds mean that many mid-sized energy projects will now be subject to NERC oversight for the first time. The goal? Enhancing grid reliability as more inverter-based resources connect to the bulk power system. 2. Key Steps for Compliance If your project meets the new criteria, here’s what you need to do: Assess Your Facilities – Determine if your current or planned projects exceed the 20 MVA and 60 kV thresholds. Begin the NERC Registration Process – Registering with NERC isn’t an overnight task. The process can take 6–12 months, depending on factors like documentation requirements, technical assessments, and coordination with regional reliability entities. Early registration helps avoid bottlenecks and ensures compliance well ahead of the May 2026 enforcement deadline. Develop a Compliance Plan – This includes: Meeting NERC Reliability Standards , such as PRC-024 (Generator Frequency and Voltage Protection) to ensure proper coordination with the grid. Updating operational procedures , like implementing real-time monitoring systems to log and report grid disturbances. Training personnel on cyber and physical security best practices to align with CIP (Critical Infrastructure Protection) requirements. Conducting regular audits to ensure ongoing compliance with evolving regulations. Engage with Experts – Compliance can be complex, and mistakes can be costly. Partnering with experienced professionals ensures a smoother transition. 3. How Camelot Energy Group Can Help At Camelot Energy Group, we can assist you with NERC registration and compliance support for energy storage and renewable energy projects. Whether you’re navigating the registration process for the first time or need a tailored strategy to meet NERC’s evolving reliability standards, our team of experts is here to help. From registration assistance to ongoing compliance support, we provide: End-to-end NERC compliance services tailored to your specific project Technical assessments to determine your compliance obligations Regulatory expertise to help you avoid penalties and operational risks With the May 2026 compliance deadline approaching, early action is critical. Don’t let regulatory hurdles slow down your project—reach out to Camelot Energy Group today to ensure you stay ahead of the curve. Contact us to discuss your NERC compliance strategy! < Back Back

Camelot Energy Group is a technical & strategic advisor to owners and investors in clean energy & energy storage projects, programs & infrastructure. We specialise in Solar, Energy Storage, Consulting, Engineering, Batteries, Due Diligence, Energy Access, Strategy, Owner’s Engineering & Advisory. GET IN TOUCH Contact Us Boston, Massachusetts hello@camelotenergygroup.com First Name Last Name Email Phone Leave us a message... Submit Thanks for submitting!

Camelot Energy Group is a technical & strategic advisor to owners and investors in clean energy & energy storage projects, programs & infrastructure. We specialise in Solar, Energy Storage, Consulting, Engineering, Batteries, Due Diligence, Energy Access, Strategy, Owner’s Engineering & Advisory. OUR SERVICES At Camelot Energy Group, our services are best defined by our clients’ needs and we approach each engagement by listening to our clients and providing a bespoke solution. With that in mind, our services generally align with the following major activities. If your needs don’t perfectly align with one of these, no worries. These are only general guidelines and you can always contact us. Owner’s Engineering Technical Due Diligence Strategic Advisory Public Program Support Owner’s Engineering (OE) Technical Due Diligence Strategic Advisory Services 01. OWNER'S ENGINEERING (OE) Today’s clean energy asset owner face a rapidly evolving technology landscape, complex technical agreements, supply chain constraints, quality control issues, and schedule risks. At Camelot, we aim to address these challenges and help our clients build more clean energy projects, secure in the knowledge that a team of experts is in their corner ensuring their projects get negotiated, designed, built, and operated to the best possible standards. Our OE clients often ask for our help with: Negotiating supply, EPC, O&M, and other major project agreements Performing technical due diligence on technology and design options Design reviews Project management Commissioning and testing support Field inspections Reporting for financiers and investors Troubleshooting performance challenges Asset management support If you would like to talk to us about your OE needs, please contact us. We look forward to meeting you and learning about your project. 02. TECHNICAL DUE DILIGENCE The market for clean energy transactions is active and growing and projects and portfolios are bought and sold almost daily. Making the choice to invest in a portfolio of greenfield or operating assets, development platform, or new technology can present a great opportunity for savvy investors but there are risks as well. As these bids become more competitive, investors need actionable technical feedback on real-world risks so they can make informed decisions. At Camelot, we have a deep understanding of the M&A process and our team has provided actionable due diligence on everything from energy storage development platforms to large utility scale solar plants and portfolios of C&I projects. Our team evaluates key areas of potential acquisitions, including: Major agreements (EPC, O&M, interconnection, offtake, and supply) Financial models Major technologies Key team members and contractors Energy models Project designs and methods Installation quality Factory QA programs Independent Engineer (IE) reports Camelot and our team members have supported the financing of over $8bn in clean energy assets for private equity, debt, and tax equity financiers, from regional banks to some of the largest financiers in the world. If you think you may need help with technical due diligence on a project, platform, or other investment opportunity, please contact us . If you already have financing and want to make sure your project is well-executed, our Owner’s Engineering services are tailored to provide that peace of mind. OE Technical Due Diligence 03. STRATEGIC ADVISORY SERVICES Many of the world’s most successful investors have identified the clean energy space as ripe for investment and are seeking to successfully enter the market or expand their position to take advantage of the global growth trends. The opportunity is vast but the competition is fierce and wasting valuable time and resources on a bad deal can set you back considerably. Whether the need is to bring your team up to speed on the latest solar and energy storage markets, technologies, and trends or to get help identifying and validating potential M&A targets, our team’s broad industry knowledge, deep relationships, and expertise can help save precious time and avoid the pitfalls of a poor investment choice. Our team provides strategic guidance related to: Leadership team briefings on solar and energy storage market and technology trends Extended trainings and boot camps to get your team up to speed quickly Support for impact investing and energy access Target identification and due diligence Technology roadmap reviews On-call expertise If your team needs help evaluating new market opportunities, please contact us . If you are ready to consider investment in projects or portfolios, you may find our technical due diligence services helpful. STRATEGIC ADVISORY SERVICES

Oct 28, 2025 Smart 3.0 Is Here SMART 3.0 is here and here’s what you need to know. 225 CMR 28.00 is the official DOER regulation (effective September 2025) that defines the technical and commercial rules for solar and storage participation under the SMART 3.0 incentive program, with the core goals of reducing greenhouse gas emissions, improving grid reliability, peak shaving, protecting land-use, and alignment with the MA 2050 decarbonization plan. The rules apply to distribution companies, and all owners, authorized agents and primary installers of Solar Tariff Generation Units (STGUs) It is important to note that participation is voluntary but binding – each participant must comply with all 28.00 requirements, or as amended by the DOER. The second enrollment period starts on January 2, 2026. The DOER assigns capacity annually by utility load share: 10% for systems 25-500 kW 10% for low-income property And 15% for community shared solar It is important to note that unused capacity does not roll over Program year 2026 will have 450 MW of available capacity for STGUs subject to the capacity cap Base compensation rates and adders will be baselined annually – it is expected to change by ~$0.01 per kWh. Fundamental calculation remains the same: Base compensation rate for program year 2025 for projects > 1 MW is $0.1729 per kWh The base compensation rate proposed for program year 2026 for projects > 1 MW is $0.1556 per kWh Adder rates are as follows: Energy Storage Adder: AC-coupled: The SMART 3.0 calculator will be made available on the mass.gov webpage. It is free to download and easy to use to determine the appropriate storage adder applicable for the project. An applicant will reserve an adder multiplier rate upon the initial application for the Energy Storage Adder. However, changes to as-built solar photovoltaic (PV) capacity or the Energy Storage System relative to the information contained in the initial application may result in an increase or decrease to the size of the Energy Storage Adder. Additional information on applying for the Energy Storage Adder is provided in the Statement of Qualification Reservation Period Guideline DC-coupled true-up: For DC-coupled STGUs with Energy Storage Systems, there are round-trip efficiency losses resulting in lower generation at the production meter. To compensate STGU owners for the AC equivalent of the renewable energy production of the STGU and to calculate the annual true-up payment of the round-trip efficiency losses, an applicant shall use the following formula: i = the number of intervals in a calendar year E i = 15-minute interval ESS DC net metered energy output η T = fixed transformer efficiency factor η INV = fixed inverter efficiency factor R P = SMART incentive rate for the STGU The Department shall establish a transformer efficiency factor that shall be fixed for all STGUs and an inverter efficiency factor that will be fixed for the specific inverter utilized by the STGU. The current established transformer efficiency factor is 2. To receive the annual true up payment, the Energy Storage System’s performance data and inverter efficiency factor must be reported to the Department. On an annual basis, the Department will calculate the annual true up payment. Once calculated, the Solar Program Administrator will provide the data to the Department for verification prior to submittal to the appropriate Electric Distribution Company for payment to the STGU Owner. Administrative process flow: Projects ≥ 1 MW must attest to or file FERC QF status under PURPA Submit a Statement of Qualification (SOQ) DOER issues preliminary SOQ – 24-month reservation period Upon interconnection authorization, apply for final SOQ with financial proofs and BESS compliance Ground-mount projects must also secure all non-ministerial permits, such as planning board and conversation commission approvals Capacity is allocated on a first-come basis (generally, first 10 business days sequenced by ISA application date Waitlist mechanism defined with 10-day response window General requirements: PV must be ≤ 5 MW AC: 10 MW AC for brownfield or landfills Delivery point must be physically in MA No active SMART 2.0 SOQ All STGUs > 1 MW AC that do not qualify for a locational adder (e.g., brownfield, landfill, dual-use, floating, etc.) must be co-located with an ESS that meet 225 CMR 28.07 (5) (e) 1 Brownfield: up to 10 MW, ISA exceptions are allowed with pre-determination from the MassDEP Canopy: must be raised so that at least 75% of area underneath be usable Dual-use Ag: trackers must be at least 8-ft for fixed tilt or 10-ft tracking; ≤2:1 DC:AC ratio (≤ 7.5 MW DC); and agricultural plan is required Floating: PFAS-free material; ≤ 50% surface coverage; ≤ 40 MW statewide cap Public entity/low-income/community shared solar: ≥ 40% allocation and ≥ 20-40% bill credit discount DOER can grant exceptions on a case-by-case basis for good cause, like transmission constraints or non-viable interconnection ESS must be at least 2 hours in discharge duration, at least 65% RTE at the POI, and must demonstrate > 52 cycles per year with proper metering (15-minute intervals) and reporting (1Y historian) The ESS must also be at least 25% capacity of the PV plant Land-use controls and mitigation fee (§ 28.08-28.09) Replaces “greenfield subtractor” with a project-specific Mitigation Fee for ground-mount > 250 kW on undeveloped land. Fee calculated per acre based on habitat, prime farmland, and carbon-risk layers (Bio Map, MassGIS datasets). 25% is due at the time of SOQ application, balance at Final SOQ; refundable if project is canceled or site reclaimed. SMART 3.0 represents a significant evolution in Massachusetts’ approach to distributed solar and storage, bringing clearer requirements, stronger land-use protections, and incentive structures aligned with long-term decarbonization goals. As developers, owners, and installers prepare for the 2026 program year, understanding the regulatory updates and technical obligations will be critical to securing capacity and maximizing project value. With careful planning and proactive compliance, participants can successfully navigate SMART 3.0 and contribute to a more resilient, clean, and reliable energy future for the Commonwealth. Raafe Khan, Shawn Shaw < Back Back

< Back Bill Atkinson, CEM Senior Project Engineer Bill is a Senior Engineer with over 17 years of experience in the renewable energy and energy storage industry. During that time, Bill has worked extensively developing and implementing rigorous quality assurance and inspection processes for clean energy incentive programs and Bill has inspected more than 530MW of PV and energy storage systems. Bill has performed hundreds of design reviews, technology evaluations, major agreement reviews, and site assessments. Bill is a Certified Energy Manager, Certified PV System Inspector, and holds a B.S. in Community and Regional Planning and Sustainable Technology from Appalachian State University. bill.atkinson@camelotenergygroup.com