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Jan 30, 2024 On VDER New York has long been an active market for distributed energy resources (DERs) and community-scale clean energy projects. Camelot has supported numerous community solar projects, as well as a variety of energy storage projects and despite strong policy support for clean energy, the New York market remains one of the most complex for developers and investors. The VDER program was established to simplify and streamline the economics of smaller projects but we still find that many developers struggle with some of the nuances. In our due diligence reviews of VDER projects, we typically find a few common points of discussion: How to project some revenue streams forward past the end of VDER value streams like LSRV and DRV Forecast and assumptions for ICAP revenues Coincidence of energy arbitrage and DRV time periods Approach to modeling charging costs When modeling the revenues for purely merchant projects, Camelot uses a sophisticated toolset including an optimized dispatch model but projects with significant programmatic revenues, such as NY VDER projects, often require a more customized approach to validating revenue streams and financial model inputs. Below, we provide some background on the VDER program to help developers and investors better understand this important program. Background on VDER The “Value of Distributed Energy Resources” (VDER) program, implemented by the New York Independent System Operator (NYISO), is a novel pricing mechanism designed to value and compensate distributed energy resources (DERs), including solar, wind, and energy storage systems. This program marks a shift from the traditional net metering system, specifically for certain DERs in NYISO. Unlike its predecessor, VDER is a more intricate system that considers various factors such as the location of the resource, the timing of energy production and storage, as well as the impact on the grid and the environment. This comprehensive approach aims to provide a more precise and potentially more advantageous form of compensation for owners of DERs. The introduction of VDER is a key element in New York's broader strategy to revamp its energy system. It supports the state's efforts to increase the use of renewable energy and reduce greenhouse gas emissions, thereby aligning with state-level policies such as the Reforming the Energy Vision (REV) initiative. This initiative reflects New York's commitment to modernizing its energy infrastructure, promoting sustainable practices, and moving towards a more environmentally conscious energy landscape. Projects under the VDER program can be as large as 5 MW-AC in capacity. The value of these projects is determined by several factors, including their geographical location and the time of day or year they operate. This valuation is determined through the VDER's Value Stack, which is composed of several key components for energy storage projects: Energy Value (LBMP): This component is primarily based on the zonal day-ahead hourly location-based marginal pricing (LBMP) set by NYISO. The LBMP is influenced by several factors: Market Dynamics: The LBMP is affected by the number of generators bidding into the market. This includes the cost of fuels such as natural gas and oil, which play a significant role in setting the price. Renewable Energy Integration: The integration of renewable energy sources like solar and wind power into the grid also affects the LBMP. Typically, a higher presence of these renewable sources tends to drive down energy costs. Demand Fluctuations: Another significant factor is the fluctuation in energy demand, which varies hourly across different zones in NYISO. This demand is particularly sensitive to weather conditions, as the usage of air conditioning and electric heating systems can dramatically increase energy demand. Impact of External Factors: External factors also play a role in shaping LBMP. For instance, in 2019 and 2020, there was a notable decrease in the pricing for capacity and energy. This trend was attributed to an abundance of generating facilities, lower natural gas prices, relatively mild peak demand periods, and a reduction in energy consumption due to the COVID-19 pandemic. Within the VDER framework, a critical element impacting the Energy Value is the Charging Costs, which differ across utility territories and significantly influence net energy revenues. In regions like the ConEd Territory, encompassing New York City and Westchester, these Charging Costs are particularly variable and can change monthly. As a result, net energy revenues in these areas are often higher, but these fluctuations also present a substantial risk by potentially reducing net revenues. To optimize the financial performance of a Battery Energy Storage System (BESS) in these areas, it is essential to identify and utilize periods when charging costs are at their lowest. By charging the BESS during these optimal times, project operators can minimize charging costs and thereby maximize net energy revenues. This strategy is particularly relevant in territories like ConEd, where the impact of these charging costs is more pronounced. Capacity Value (ICAP): Known as Installed Capacity, which is an essential factor in evaluating how effectively a project mitigates energy usage in New York during the most energy-demanding days of the year. This value is closely linked to the NYISO wholesale capacity markets. The rates for ICAP are subject to fluctuations based on several factors: Increase in ICAP Rates: These rates can rise in scenarios where power plants retire or when the State experiences a high annual peak load, indicating increased demand for energy. Decrease in ICAP Rates: Conversely, ICAP rates may decline if there's an excess in power generation, such as when new power plants come online, or if the annual peak load is lower than expected, indicating a surplus in energy availability. ICAP Alt 3 rates change monthly and vary based on NYISO Load Zones. For standalone energy storage projects, the only applicable ICAP payout option is known as Alternative 3 (Alt 3). Under Alt 3, project compensation is calculated and awarded each month throughout the year. This is based on the energy injections from the peak hour of the previous summer, which are then multiplied by the monthly ICAP Alt 3 rate, expressed in dollars per kilowatt ($/kW). This approach ensures that the compensation is reflective of the actual contribution of the project to reducing peak demand, thus aligning with the core objective of ICAP in the VDER framework. Demand Reduction Value (DRV): This aspect of the Value Stack quantifies the impact of DERs on reducing the need for future grid upgrades by utilities. This value is essentially determined by assessing how much a DER project can lessen the necessity for utilities to enhance their distribution networks to handle new peak load demands. The DRV value and is locked in for 10 years and Based on Several Factors: These rates are derived from the utilities' estimated costs associated with upgrading their distribution networks to accommodate increasing peak loads. Decrease in DRV Rates: Peaks can be lowered by factors such as enhanced energy efficiency measures and declining populations. These developments could lead to a reduction in DRV rates. Increase in DRV Rates: Conversely, factors that contribute to higher peak loads, such as population growth and increased electric consumption during peak times (e.g., due to the adoption of heat pumps and electric vehicles), can lead to an increase in DRV rates. Compensation and Performance: The compensation for the DRV value is closely tied to the performance of the BESS during a predefined DRV Window. The DRV value, expressed in $/kW-yr, is calculated with the assumption that the BESS is capable of discharging at its full capacity during all the hours within the DRV Window. Variation by Utility and Region: It's important to note that both the DRV Window and the associated value can vary depending on the specific utility and the region in question. This variation reflects the differing needs and characteristics of each utility's grid and the regional differences in peak load patterns. Therefore, in the VDER framework, the DRV is a dynamic component that reflects the evolving landscape of electricity demand and supply, as well as the regional characteristics of utility grids. It plays a vital role in incentivizing DER projects that can effectively reduce the need for costly grid upgrades. Locational System Relief Value (LSRV): This value recognizes the additional benefits DERs can provide to the grid in specific utility-designated locations. Here are the key aspects of the LSRV: Project Location Requirements: To qualify for LSRV, a project must be situated in a utility-specified substation or location. Some projects might also be eligible for a Location Adder, which provides additional incentives for being in specific areas deemed crucial for grid support. Availability in Designated Locations: LSRV is accessible only in certain areas designated by utilities where DERs can offer extra benefits to the electrical grid. These areas are typically identified based on their potential for grid relief or congestion reduction. Capacity Limitations: Each designated location for LSRV has a finite amount of capacity available, measured in megawatts (MW). This means that there's a limit to the amount of DER capacity that can qualify for LSRV benefits in any given area. Minimum Call Events: Each utility is required to have a minimum of 10 call events per year. These events are opportunities for DERs to demonstrate their capacity to provide grid relief. Advance Notice: A notice of 21 hours prior will be given for these call events, and they are scheduled to occur during the DRV window. Duration of Calls: The duration of these calls will range from 1 to 4 hours. Compensation Structure: Compensation for participating in these call events is based on the lowest hourly kilowatt (kW) injection during a call window. This method ensures that DERs are rewarded based on their actual contribution to grid relief during these critical periods. The LSRV is thus an integral part of the VDER framework, incentivizing projects that are strategically located to provide maximum benefits to the grid. Through this component, the VDER program aims to encourage the deployment of DERs in areas where they can significantly contribute to grid stability and efficiency. Conclusions To conclude, each of these components plays a role in determining the overall worth of an energy storage project within NYISO’s VDER framework, reflecting its multifaceted approach to valuing DERs. If you're interested in evaluating energy storage projects in NYISO’s VDER Program, don't hesitate to reach out and say hello at info@camelotenergygroup.com . < 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

Sep 11, 2024 Solar Availability Series Part 4 Welcome back for Part 4 of Camelot’s series on solar availability. If you’re just joining us for the series, here are some links to parts 1 , 2 , and 3 . We’ve set the groundwork with a summary of the ongoing validation efforts from IEs, and the resulting changes the industry is making to their assumptions. We’ll revisit their reasoning here. We’ve also described how availabilities are calculated and reported, and touched on ways of maximizing availability by minimizing downtime. If you’ve followed along with the last few parts and you’ve been waiting for our own stance as an Independent Engineer (IE), look no further! Thank you for joining us. Re-Setting the Scene Until somewhat recently, the utility-scale solar 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 projects. Engineering judgement said that a relatively simple solar project would see the equivalent of about 3-5 days of total site outages per year, leading to expected availabilities of about 98.5% to 99.2%. For modeling simplicity, most everyone assumed a relatively consistent availability throughout a project’s lifetime. However, 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 with their average availability levels below what they had hoped. Over the last year we have started to see the beginnings of some robust data-backed approaches to redefining availability assumptions, aided by all the new operating data which is available to us. There have been three IEs who have recently updated their assumptions based on aggregated data from the projects they supported. 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. We’d like to highlight a few key findings from this comparison: Every IE relied on data from monthly operating reports produced by the operators, which are rarely independently calculated or verified. As described in part 2 of this series, there is no single, standard way that availabilities are defined or reported across the industry. The conclusions from these studies should be interpreted carefully, especially because the data QC processes have not been explicitly described. DNV’s analysis used more data and resulted in recommendations which are more clearly tailored to the sites. ICF found that fixed tilt systems showed lower availabilities than tracker systems while DNV found the opposite. 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. 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 practice, however, IEs are often reluctant to deviate from their standard assumptions, as this requires going out on a proverbial limb. While that conservatism is understandable, it may be producing unintended consequences. For instance, if an IE will not give “credit” for more robust technology choices or operating strategies, then owners have little incentive to consider any options but those that can be considered “bankable” at the lowest possible cost. This approach penalizes owners for considering better than baseline equipment, spending more on O&M, or otherwise looking for creative solutions to improve availability. The need for more data was a theme repeated by each company, and this will likely ring true for as long as we do this kind of work. Our availability assumptions will need to be updated regularly, just like we update our approaches to Energy Yield Analyses. Camelot’s Recommendations The Camelot team is compiling the data needed to supplement these studies and validate our conclusions, and we welcome the opportunity to work with industry partners on this effort. In the meantime, we base our own recommendations off the meta-study described above and in Part 1. Without further ado, here is our own take on availability projections: Until we have more information, we should not be differentiating between different mounting types . ICF’s and DNV’s observations contradicted each other. It’s likely other factors influenced the analyses, especially the sample sizes and quality of the input data. The factors which can impact downtime should be studied further, which means collecting more data, ensuring its accuracy, and capturing all potentially-relevant project details. In addition to mounting types, the difference between inverter technologies must be studied further as one of the primary sources of downtime observed at operating sites. For instance, the higher availability noted by DNV on smaller fixed-tilt sites than larger fixed-tilt sites may indicate a reliability advantage for string inverters over relatively small sites with central inverters. This would align with our general experience with operating sites but the data to positively confirm this is not yet available in sufficient quantity. The major sources of downtime should be studied and modeled separately . Using an overall system availability as a metric can muddy the waters significantly, especially when trying to tease out the impact of different design decisions on future performance. When performing energy yield analyses for wind energy projects, some IEs will include assumptions for balance of plant availability, grid availability, and turbine availability separately. Not only can this improve our validations (data allowing), but it will improve the way we assess technology tradeoffs at the design stage. Swapping out a more robust system for a less-robust one should impact only the downtime assumption for that system. Camelot recommends the industry work towards a bottom-up availability model based on historical failure/downtime data at the module, tracker, inverter, MV, HV, and BOS levels. These levels correspond with likely failure points within the system and provide a lowest common denominator that can be adjusted during project design to optimize expected availability. Ensuring this approach has buy-in from IEs will provide a financial incentive to specify better equipment and design better sites. Year-1 availability should be modeled separately from later years due to initial startup issues observed in each validation. Nearly all financial models are already set up to account for annually-varying losses, so adjusting our assumptions based on the clear signals we see from the data appears to be a no brainer. The industry should start modeling a ramp-down in availability later in projects’ life, as DNV may have alluded to, because component failure rates impact availability trends. Without more data, it is difficult to say the magnitude of the decreases because of the other factors at play. However, based on our experience modeling availability at other infrastructure projects, Camelot considers it reasonable to model availability as a ramp-down as a project nears the end of its design life. The “bathtub curve” shown below is an Engineering concept which supports this idea. It shows how infant mortality failures likely contributed to the observed availabilities in the first 6-12 months of operation, and highlights the further need for more operational data as projects age. This is applicable to individual components in many physical systems. Aggregated across an entire system and accounting for typical replacements and maintenance, one might expect to see a flatter availability curve, but with some consideration for early- and late-stage failures. We have seen this already with 10-15 year old PV sites, where owners struggle to obtain compatible replacement equipment that can be “dropped in” to replace original equipment onsite. As technology continues evolving quickly, we can expect new module types, inverter technologies, sensing devices, and code requirements to all play a role in the maintainability of PV sites in the late stages of their useful life. Camelot’s Balanced Approach The summary below provides a graphical representation of each IE’s default availability recommendations over time, and includes Camelot’s own recommended defaults (when no other project-specific information is available). We note the following: Camelot’s approach accounts for the size impacts observed by DNV, which appears to be a strong signal in the data, but does not differentiate between technologies until more information is made available supporting the distinction. Much like DNV, Camelot’s recommended availability starts slightly lower in year 1 before reaching steady operations, as is supported by all studies. We recommend modeling availability declines after year 20 based on several factors, including the bathtub curve concept described above, the typical useful life for major components, and our expectation that the impacts of mid-life failures will likely offset by the efficiencies gained from experience during operations. While we see this assumption as a necessary recognition of late-stage wear-out failures, it’s worth noting that its impacts on a financial model are muted by the time value of money. On average, Camelot’s assumptions are less pessimistic than ICF, and strike a balance between the assumptions reported by Natural Power and DNV. Camelot will consider quantitative adjustment to our base availability assumptions for sponsor efforts that materially result in increased reliability, such as: Demonstrating better than average historical availability for project- specific equipment (e.g., inverters) through operational data (as described in item 3 above) Adding incentives to O&M Agreements for increased availability, beyond simply guaranteed levels Purchasing extra spare parts for more vulnerable system components likely to need frequent replacing Investing in predictive analytics and above-market O&M services to reduce the frequency and severity of unplanned maintenance events While these recommendations may be Camelot’s “default” values, as an IE which cares heavily about the accuracy of our projections, we will always consider factors such as operator experience or the relative track record of the technologies deployed at each site. As the saying goes, “show us the data.” Before we close, it is important to underscore an important point. Recent reporting that indicates PV projects are falling short of expected availability is a call to action for all of us. It is a call to action for more data, better analysis, and a deeper understanding of what causes PV systems to underperform. It is, notably, not a call to action for unnuanced conservatism. Simply whacking a few points off availability is, in our view, insufficient to the task of ensuring a better-performing PV fleet and it creates blind spots. We hope our fellow IEs will join us in not simply erring on the side of conservatism but, rather, will continue to advance our knowledge of these issues and build better, and more nuanced models that reward innovation, investment, and effort. We hope you’ve found this series to be helpful, and we welcome the opportunity to partner with any of our readers who would be able to support with future efforts. Although this is the last of our solar availability series for now, we fully intend to revisit the topic in the future. For our storage-oriented audience, you can expect a similar discussion on availability assumptions for BESS technologies in upcoming articles. 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

Mar 14, 2025 New Acquisition Opportunity in ISO-NE At Camelot, we always try to keep a finger on the pulse of the solar and energy storage M&A market, as many of our clients turn to us for technical and market due diligence on these sorts of engagements. We just had a noteworthy M&A opportunity come across our desk from our friends at Enerdatics and wanted to share this opportunity with our network. It’s for a portfolio of three hybrid (Solar + BESS) project in ISO-NE, a region where many folks have had development and acquisition interests in the MA SMART + Clean peak programs. A few details to highlight: This portfolio comprises three hybrid projects totaling 15 MW of solar + 6.72 MW of BESS , available for sale in Massachusetts, USA . Each project is for sale at the Notice to Proceed (NTP) stage, with land, permits, and interconnection already secured . The projects are expected to achieve Commercial Operation Date (COD) between Q3 and Q4 of 2026 . They participate in the MA SMART and Clean Peak programs , with potential eligibility under MA SMART 3.0 . The projects qualify for the 30% federal Investment Tax Credit (ITC) and offer strong revenue potential through offtake strategies and ancillary services in ISO-NE . Offers are welcome for the entire portfolio or individual projects , with transaction closing anticipated in Q2 2025 . Camelot has recently performed diligence on, and supported the development of, several projects in MA SMART + Clean Peak Programs and we find that revenues can vary widely based on the revenue stack, BESS system sizing, and offtake strategy. Similar hybrid projects present a great opportunity and favorable economics, especially with the significant adjustments made to the adders proposed in the Massachusetts Department of Energy Resources (MA DOER) straw proposal. This is in addition to the changes made to the Alternative Compliance Payment (ACP) rate, where starting in 2026, the rate will increase to $65/MWh and stay at this level until 2032. After 2032, the ACP will return to $45/MWh, where it will remain until 2050. Camelot also has recent data on CAPEX and OPEX applicable to the region and can perform a wholistic economic analysis of the projects to verify the seller’s assumptions. Overall, depending on the quality of the development of course, this could be a good opportunity in an active market. If you are new to the MA SMART + Clean Peak Programs, we encourage you to to check out our relevant articles: Massachusetts SMART and Clean Peak Overview MA SMART Part 2: Key Financial Implications for Hybrid Systems If you are interested, we would be glad to put you in touch with our friends at Enerdatics who are tracking the deal and, of course, if you decide to pursue and need any help on the due diligence side of things, please reach out to Taylor Parsons or Shawn Shaw, PE . The Enerdatics team will also be at #Infocast2025 next week and will have other exclusive deals and insights to share. Be sure to reach out to Mohit Kaul or Kshitij N R to connect! < 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

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

Nov 11, 2025 ERCOT RTC + B ERCOT’s transition from Operating Reserve Demand Curve (ORDC) scarcity pricing to the new RTC+B framework marks a fundamental shift in how batteries and other resources will earn value in Texas’ evolving ancillary services market. ERCOT’s ORDC scarcity pricing is being replaced with a more balanced, data-driven framework. TB-2 valuations have been trending over the last 6-9 months. The composite TB-2 is up by more than 20% (7-year term, Q1 2027 PIS) According to E3, after the passage of the Budget Reconciliation Bill, the phase out of tax credits for solar and wind result in lower deployments and a roughly $15/MWh increase in average annual energy prices from 2026 to 2035. RTC-B is going to be implemented by the end of the year by retiring ORDC scarcity adder. This means that asset owners must prepare for lower ancillary service revenues, higher arbitrage shared, and upside tied to scarcity frequency post implementation This also required four (4) new telemetry points: Frequency Responsive Capacity High Limit (HFRL in MW) High limit of the resources’ capacity that is frequency responsive Frequency Responsive Capacity Low Limit (LFRL in MW) Frequency Responsive Capacity Factor (FRQF) Maximum amount of total base point provided by the frequency responsive capacity of the resource Inactive Power Augmentation Capacity (PAUG in MW) Power augmentation capacity that is not on-line in HSL. This is used in SCED to determine the portion of the non-spin award that will be provided by power augmentation capacity that is not active and deployed as offline non-spin The new telemetry points are intended to inform Security Constraint Economic Dispatch (SCED) the Frequency Responsive Capacity of the resource to ensure that the Regulation and RRS-PFR awards are within the frequency responsive capacity. There are no frequency responsive capacity limitations when providing Non-Spin and ECRS The new demand curve will increase the ancillary service prices under scarcity conditions; however, we note that the scarcity adder will kick in first for RRS and ECRS before RegUp Currently, the onus is on the QSEs to ensure that Regulation and/or RRS-PFR are not coming from the steamer capacity and preserve sufficient headroom on GTs. ERCOT also enforces real-time and post-hoc compliance checks. The improved telemetry will eliminate this burden on QSEs and ERCOT. In practice, the optimization process ensures that resources are not incentivized by prices to deviate from their awards, i.e., a BESS will receive the same operating profit it would have received from the energy market, making it indifferent to the scheduling of its capacity for energy or ancillaries. For ERCOT Contingency Reserve Service (ECRS) it states that batteries can only qualify to provide a quantity that they can sustain for two consecutive hours. Essentially, a two-hour battery can qualify for up to 100% of its rated power as ECRS in any interval. However, a one-hour battery would only be eligible to provide up to 50% of its rated power as ECRS. However, this is changing…ECRS is transitioning from a 2-hour requirement to a 1-hour requirement. RRS and Regulation are being reduced from 1 hour to 30 minutes. Non-spin remains at 4 hours. Since most batteries in ERCOT are at least one hour in duration, the change in duration requirements for RRS and Regulation has minimal bearing on how much capacity is eligible to qualify to provide each of these services. However, the shift to a 1-hour requirement results in a 29% increase in eligible battery capacity for ECRS. This is because RTC+B shifts ECRS to a 1-hour requirement. A 100 MW / 120 MWh battery that was limited to 60 MW under the 2-hour rule can now offer its full 100 MW. It isn’t actually clear how revenues will be impacted as RTC procures ancillaries in real time. However, according to Modo Energy, using Day-Ahead prices as a proxy, batteries would earn about 14% less (or ~ $66 per MW less) under RTC+B on this high-priced day with this operational profile, assuming all RTC+B awards were made exclusively in the Real-Time Market. The reduced revenues reflect limits from SoC checks and the inability to capture extreme Non-Spin pricing. As ERCOT phases out ORDC scarcity pricing and implements RTC+B, asset owners and operators should expect a new balance of risks and opportunities—reduced reliance on scarcity adders, more precise telemetry requirements, evolving duration thresholds, and real-time procurement dynamics that reshape revenue profiles. While uncertainty remains around long-term impacts, it’s clear that operational flexibility, accurate dispatch data, and strategic bidding will play a larger role than ever in capturing value. Raafe Khan, Shawn Shaw < Back Back

< Back Mark Warner Project Manager Mark Warner, a Project Manager at Camelot Energy Group, has over 5 years of experience in the renewable energy development and EPC contractor space. Mark has extensive background in project development, siting, energy analysis, design, construction planning, and permitting for commercial and utility-scale solar projects. Mark holds a Bachelor of Science Degree in Mechanical Engineering Technology from the University of Maine. mark.warner@camelotenergygroup.com

Feb 12, 2025 MA SMART Part 2 Massachusetts continues to establish itself as a leader in state-level clean energy programs, and Camelot is staying closely aligned on the latest developments in the region. Developers and other players take note: Through the Solar Massachusetts Renewable Target (SMART) Program and the Clean Peak Energy Standard, the state has introduced dynamic frameworks designed to accelerate renewable energy adoption while addressing grid reliability and peak demand challenges. Here, in part 1 of our two-part series on the Massachusetts programs, we’ll set the scene with what you need to know about the programs, and will dive more deeply into the key financial implications in part 2. Massachusetts SMART Program Overview The Solar Massachusetts Renewable Target (SMART) Program is a pioneering initiative aimed at promoting solar energy adoption across the state. Managed by the Massachusetts Department of Energy Resources (DOER), the program provides long-term incentives for solar photovoltaic (PV) projects, encouraging residential, commercial and small utility scale installations up to 5MW AC. Here’s an in-depth look at its objectives, structure, and benefits. The SMART program is a feed-in-tariff program that assigns a unique energy rate to different qualifying solar projects based on system size, system type, system location, offtaker type, and associated energy storage system size. The SMART program has a total capacity of 3,200 MW AC, which is distributed among Massachusetts' three investor-owned electric distribution companies: National Grid , Eversource Energy , and Unitil . The capacity assigned to each utility is proportional to the number of customers in their service area. Generally, sites serviced by municipally-owned electric utilities are not eligible for the SMART program. Each utility’s allocated capacity is further divided into two categories: one for systems larger than 25kW AC and one for systems smaller than 25kW AC. These categories are then subdivided into 16 "capacity blocks." As SMART applications are approved, these blocks gradually fill up. Once a block is fully subscribed, it is considered at capacity, and the program advances to the next block. The incentive rate for the new block is lower than that of the previous one, declining by 4% each block. Figure 1: Summary of Capacity Blocks as of 1/9/2025. SMART Capacity Block updates are posted at www.masmartsolar.com for each utility company To determine the exact SMART tariff rate that a project is granted, the DOER determines a base compensation rate based on the system size and the current utility capacity block. Then adders are applied based on system location, off-taker type, energy storage and racking (see Figure 1). Similar to the declining capacity blocks, the adders have declining “tranches”, and as each tranche is filled at the state level, the incentive rate declines by 4%. However, the adder rates for the Agricultural, Brownfield, Canopy, Floating and Landfill Adders will be locked in at their Tranche 1 rates for the duration of the SMART program and the adder rate for the Building Mounted Adder will be locked in at the Tranche 2 rate for the duration of the SMART program as modified by order 20-145-B released by the Department of Public Utilities on 12/30/2021. Figure 2: Previous Adder Values Massachusetts DOER SMART Program – Initial Release 2018 *Significant adjustments to this table are proposed in the Straw proposal: Figure 3: Straw proposal for new adders Massachusetts DOER SMART Updates – Straw Proposal 2024 SMART and Energy Storage Under the current SMART regulations, all projects over 500kW must be coupled with an Energy Storage System (ESS).* SMART projects coupled with ESS are provided with an “energy storage adder” that ranges between 0.025 – 0.077 $/kWh. The exact adder value is dependent on the max power output of the ESS and the duration, with the maximum adder being granted to projects with 100% of the max power of the PV system and 6 hours duration and the minimum adder being granted to projects with max 25% of max PV power and 2 hour duration. The incentive of the Energy Storage adder is applied to all power generated by the system, independent of the use case of the ESS. There is a requirement that each year the ESS must be cycled a minimum of 52 times to maintain eligibility for this adder.** * The new straw proposal published 7/29/24 specifies only projects over 1MW AC will require ESS ** The new straw proposal published 7/29/24 increases this requirement to 156 cycles per year and adds the requirement that the ESS is online and able to discharge 85% of the time during summer and winter months. Figure 4: Energy Storage Adder Matrix Massachusetts Clean Peak Energy Program Overview The Massachusetts Clean Peak Energy Standard (CPS) is a first-of-its-kind program designed to encourage the use of clean energy during peak electricity demand periods. Managed by the Massachusetts DOER, the program incentivizes renewable energy systems and energy storage solutions that contribute to grid stability and reduce reliance on fossil fuel-based power during high-demand hours. How the Program Works Clean Peak Energy Certificates (CPECs): Eligible resources earn Clean Peak Energy Certificates (CPECs) by generating or dispatching energy during defined Seasonal Peak Periods and the Actual Monthly System Peak, as specified by the Massachusetts Department of Energy Resources (MA DOER). CPECs can be traded in the market to electricity suppliers required to meet clean peak compliance obligations. Various applicable multipliers align CPEC generation with time periods and resource attributes that have the highest impact. For instance, higher multipliers are assigned for summer and winter months (4x) compared to other season months (1x). The Actual Monthly System Peak is weighted disproportionately to incentivize project owners to optimize performance during the peak hour of a given month, which determines the infrastructure sizing requirements. Hybrid Solar + ESS projects that are enrolled in the SMART program can also participate in the Clean Peak program and generate CPECs. However, these projects are awarded a 0.3 multiplier for all CPECs generated, effectively derating the value of their incentive by 70%. Eligible Resources: Wind turbines with storage. Solar PV systems paired with energy storage. Standalone storage systems charged with renewable energy. Demand response resources that reduce load during peak periods. Figure 5 – Energy Storage Charging Windows for Solar-Based Charging Hours Defined Peak Periods: Peak hours are established seasonally to reflect times of highest grid demand. These periods typically occur during late afternoon to early evening hour Figure 6 – Clean Peak Season (CPS) Windows Market-Driven Prices: The value of CPECs fluctuates based on market supply and demand, providing financial incentives for participating resources. Things To Note CPEC Revenues CPEC revenues are designed to incentivize clean energy generation during peak demand periods and can apply to projects that include solar paired with energy storage systems (solar + storage), as these systems are particularly effective at delivering energy during peak periods. Standalone solar projects can still qualify for CPEC revenues, but their ability to maximize these revenues is typically limited compared to solar-plus-storage systems, which offers greater flexibility in aligning energy delivery with peak periods because storage enhances the ability to participate in the Clean Peak Standard (CPS) program. By storing solar energy and dispatching it during peak demand hours, hybrid systems can generate additional CPEC revenues, making them a financially attractive option. ACP Rate Changes The DOER has implemented significant updates to the Alternative Compliance Payment (ACP) rate as part of its emergency rulemaking. The ACP rate will remain at $45/MWh through Compliance Year 2025. However, starting in 2026, the rate will increase to $65/MWh and stay at this level until 2032. After 2032, the ACP will return to $45/MWh, where it will remain through 2050. This marks a major departure from the original regulations, which planned for a declining ACP rate, dropping to $4.96 by the end of the policy period. While the higher ACP rate is expected to boost market prices, there is still a risk of steep price drops if surpluses exceed the banking limits of load-serving entities. Figure 7 – CPS Alternative Compliance Payment (ACP) Rates Near-Term Resource Multiplier (NTRM) DOER has also introduced a new NTRM under the CPS. The NTRM will provide a 2x multiplier on CPECs for up to 50 MW of qualified energy storage systems for a duration of 10 years. To qualify, the QESS must be a standalone, front-of-the-meter system interconnected to the distribution system, with a commercial operation date between January 1, 2019, and January 1, 2027. Additionally, it must not have received a Statement of Qualification before January 1, 2025, or the Distribution Credit Multiplier. Ownership is restricted to prevent any single entity from controlling more than 50% (25 MW) of the program’s capacity. DOER released the NTRM application on January 7, 2025[SS3] . Applications submitted by January 21, 2025, will be prioritized based on interconnection service agreement dates. Any applications received after this deadline will be reviewed on a first-come, first-served basis. These updates aim to encourage the development of energy storage systems while addressing previous concerns about market pricing and resource deployment under the CPS. Conclusions Looking forward, Massachusetts aims to expand and refine the SMART & Clean Peak Program to adapt to emerging technologies and evolving market conditions. By integrating solar energy with battery storage and enhancing equitable access, the program continues to serve as a model for other states aiming to transition to a clean energy future. For those considering solar or hybrid projects in the state, the program offers a valuable opportunity to contribute to sustainability while enjoying financial benefits. Stay tuned for Part 2, where we will discuss the revenue stack for hybrid projects, containing a combination of the SMART Program & Clean Peak Program. If you're interested in assessing solar, energy storage, and/or hybrid projects in ISO-NE’s MA SMART Program, feel free to reach out to us 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 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

< 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

< Back Jacques Cantin Senior Project Manager Jacques Cantin is a Senior Project Manager at Camelot Energy Group with over 13 years of experience delivering renewable energy and energy storage projects. Based in Montreal, he has led utility-scale battery energy storage system (BESS) and wind projects across Canada and the United States, overseeing project development, systems integration, design, construction, and commissioning. Prior to joining Camelot, Jacques managed storage and renewable projects for a battery storage technology provider and a renewable energy developer and founded a technology start-up focused on wind turbine blade de-icing solutions. At Camelot, he manages advisory engagements for developers, asset owners, and investors, providing technical due diligence, market and economic analysis, and owner’s engineering support for solar, storage, and other clean energy assets. Jacques holds a Bachelor of Applied Science in Mechanical Engineering from Université Laval and an Executive MBA from Queen’s University. Jacques.Cantin@camelotenergygroup.com