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Dec 4, 2025 CAISO Market Operations CAISO Market Refresh CAISO is the second largest renewable energy market by deployment, just marginally behind TX, however, operating in CAISO isn’t trivial – the market works in a few layers, and all required capacity is procured in the DA market However, two additional balancing markets run throughout the day – the Integrated Forward Market (IFM) and the Fifteen Minute Market (FMM) Source: CAISO OASIS Data Integrated Forward Market (IFM): Bidding starts in the IFM the morning before the day starts and all operators submit bids for DA and AS for each operating hour. However, BESS with Resource Adequacy (RA) contracts are required to make bids for every hour Fifteen Minute Market (FMM): Once the day begins, FMM gets to work. Operators must submit bids 75 minutes prior to each operating hour. This is also referred to as the 75-minute lockout period FMM capacity is cleared in 15-minute increments Real-Time Dispatch (RTD): RTD works in 5-minute intervals and CAISO uses this to address sudden system wide issues like outages, demand spikes, etc. FMM awards can be adjusted in both directions in RT, and this can cause uncertainty about the immediate operating hours. It is important to note that assets with firm AS obligations must have 60-minutes of SoC in the IFM and 30-minutes of SoC in the RTM to deliver and avoid penalties. Key Market Mechanisms & Initiatives Extended Day-Ahead Market (EDAM): This is a major ongoing initiative to expand the real-time WEIM into a day-ahead market. Status: The EDAM is scheduled to launch in May 2026, with PacifiCorp and Portland General Electric as initial participants. Stakeholder workshops are ongoing to finalize tariff clarifications and implementation details. Source: U.S Energy Information Administration Flexible Ramping Product (FRP): This market mechanism is designed to manage the significant net load variability caused by high solar and wind integration. Function: It procures capacity to handle forecasted movement and uncertainty in net load (total load minus solar/wind generation) in the real-time market. Performance & Challenges: The CAISO net load can swing more than 20 GW in a single hour. While beneficial for grid stability, the FRP rarely presents consistent, high-value revenue opportunities for most battery energy storage systems (BESS) as prices are often zero due to sufficient available capacity. The Department of Market Monitoring has previously identified implementation errors in the product's demand curve calculations that resulted in under-procurement of upward capacity during critical ramps. FRP addresses real-time variability across the Western grid, with CAISO facing some of the steepest ramps Source: U.S EIA SP15 hosts nearly 75% of CAISO’s battery storage, reflecting where solar growth and ramping needs are most concentrated. This regional buildout plays a major role in shaping real-time flexibility and FRP activity across the grid. As storage scales further, SP15 increasingly influences CAISO’s price formation and operational dynamics. Source: CPUC Master Resource Database Ancillary service prices in SP15 have declined sharply as battery storage has scaled across CAISO. With increased competition, services like RegUp, Spin, and Non-Spin offer far less revenue than previous years. This shift pushes storage operators to rely more on energy arbitrage and real-time market opportunities. Source: CAISO OASIS Data With ancillary service prices declining, energy arbitrage now makes up the largest share of CAISO BESS revenue. Growing solar-driven volatility has increased DA–RT spreads, making arbitrage more valuable. As a result, storage operators rely more on price forecasting and real-time optimization to capture returns. Source: CAISO Special Data TB4 opportunities come from predictable daily price swings in CAISO, where low midday prices encourage charging and high evening prices reward discharging. This spreads-based strategy is a major revenue driver for batteries under tolling agreements. Capturing these spreads consistently requires strong forecasting, SOC planning, and real-time optimization. Source: CAISO OASIS Data California utilities and CCAs are rapidly increasing their TB4-settled procurement, growing from under 2 GW in 2023 to over 3.5 GW by 2025. TB4 contracts shift real-time operational risk from offtakers to independent power producers (IPPs). This structure gives utilities financial certainty while requiring storage operators to manage price volatility and dispatch performance. The growing adoption of TB4 highlights the market’s move toward financially settled performance-driven contracting for BESS. Source: CPUC Fillings Raafe Khan < 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

Mar 10, 2025 Constructability Part 1 Constructability refers to the overall ease and efficiency with which a project can be built. This directly influences both the speed of construction, and the cost required to complete the project. It encompasses various aspects of design, planning, procurement, and execution to ensure the project can be built effectively, safely, and within budget and timeline constraints. The Importance of Constructability in Solar and Battery Storage Projects When it comes to solar and battery storage projects, constructability should be considered as early as the site acquisition stage. Typically, during this phase, developers identify a potential land parcel and create a preliminary layout to assess site capacity, estimate annual energy production, and gauge interconnection feasibility using the limited information available. While this is a crucial first step, constructability concerns are often overlooked or insufficiently analyzed. This can lead to projects with critical constructability challenges advancing through the development process—resulting in wasted time and money on projects with a low likelihood of successful execution. The Camelot Energy team has extensive experience in development, engineering, procurement, and construction, allowing us to help owners and developers identify and address constructability concerns early in a project’s lifecycle. By doing so, we help mitigate late-stage issues, ensuring smoother project execution. This article is the first in a series on "Constructability," where the Camelot team will highlight common challenges and showcase solutions that enable seamless project development and construction. The Ups and Downs of Topography in Renewable Energy Projects One of the most common constructability issues we encounter during the development and construction phases is inadequate attention to topography . The terrain of a project site significantly impacts design feasibility, energy production estimates, and overall constructability. Why Topography Matters Most preliminary project layouts are created using publicly available data, which typically provides only 5’ or 10’ contour intervals. While this offers a rough idea of site conditions, it lacks the precision needed to fully de-risk a project. This limitation is particularly problematic for sites with complex terrain, dense forestation, or proximity to floodplains. For such projects, hiring a professional survey company to conduct a detailed topographic survey (with 2’ contour intervals or finer) is essential. This data enables developers and engineers to validate site conditions accurately and plan accordingly. Using Topography Data in Project Design and Development Once a detailed topographic survey is completed, the preliminary layout—including solar arrays, battery storage units, access roads, fencing, and equipment pads—should be incorporated into computer-aided design (CAD) software . By integrating this data into the design, engineers can assess site suitability and proactively address constructability challenges. At this stage, a slope analysis should be conducted to identify areas of concern. This analysis requires input from multiple disciplines, including civil, structural, and electrical engineers, construction professionals, and racking vendors . Collaboration ensures that all aspects of the project are evaluated, and risks are mitigated early. Key Topography Considerations for Constructability Civil Design Grading requirements to meet design standards Stormwater management and hydrology considerations Access road construction feasibility Equipment pad locations and elevation planning Structural Design Vendor-specific racking slope tolerances Structural calculations for stability and safety Accommodation of varying site elevations Electrical Design Trenching and underground conductor runs Placement of medium-voltage poles and guy wires for overhead lines Routing and protection of underground cables Construction Considerations Water management strategies during construction Temporary erosion control measures Site layout for construction staging areas Placement of office trailers and parking zones Operations & Maintenance (O&M) Planning Long-term vegetation management strategies Ongoing erosion control measures Why Early Topographic Analysis is Essential Topography sets the foundation for every aspect of a renewable energy project—it is the building block of successful development and project design. Identifying and addressing topographic challenges early minimizes risks, helps maintain budget and schedule discipline, and ensures that project goals are met. By taking a proactive approach, developers can avoid costly redesigns, permitting delays, and unexpected construction obstacles. Looking Ahead This article is just the beginning of our series on constructability. In upcoming articles, we will dive deeper into other critical factors affecting constructability, including geotechnical challenges, interconnection hurdles, and procurement risks. Stay tuned for more constructability insights from the Camelot Energy Group! < Back Back

Oct 31, 2024 U.S. ISO/RTO Regions The energy storage market, driven in large part by the Inflation Reduction Act, is hot and active, with many developers and investors making new investments and growing their storage portfolios. Unfortunately, overall market growth does not mean low risk for developers and the cost of picking the wrong market, revenue stack, contracting structure, or technology could spell disappointment for investors as they watch others pass them by. Sound and informed guidance on energy storage development is absolutely critical to capitalizing on this important growth area. At Camelot, we provide comprehensive market analyses across all U.S. Independent System Operator (ISO) and Regional Transmission Organization (RTO) regions. Our team analyzes each market’s unique characteristics, helping solar and energy storage developers identify the best opportunities for deploying Battery Energy Storage Systems (BESS) and hybrid projects. Here are some key points for each region: ERCOT (Electric Reliability Council of Texas) ERCOT doesn't have a firm real-time ancillary service market, relying sporadically on Supplemental Ancillary Service Market (SASM) auctions to make up for gaps in day-ahead obligations. However, by 2026, ERCOT aims to roll out a real-time co-optimization system for energy and ancillary services. Moreover, as storage saturates the market and as real-time co-optimization between energy and ancillary services gets implemented, ancillary services prices are expected to decline in the near term. Despite the potential saturation of ancillary services in ERCOT, the ongoing deployment of non-dispatchable renewable energy there, and the potential for new load growth, is helping the Lone Star State retain center stage for energy storage developers. However, many developers that come to Camelot for guidance make the mistake of thinking any Texas ESS project is likely to be successful. In reality, identifying the optimal placement and technology mix means all the difference between a profitable ESS project and one that struggles to pencil. Overall, the Houston Hub faces a lower risk of ERCOT related issues, including curtailment, compared to the South hub, which is likely to experience increasing challenges. CAISO (California Independent System Operator) Energy price volatility in CAISO increased significantly in 2022 and is projected to remain elevated in upcoming years, driven by higher gas prices and concerns over system reliability, creates a strong opportunity for BESS. Gas Pricing: Despite less expensive generation from solar and wind, elevated gas prices, impacted by supply constraints and global market dynamics, contribute to higher electricity prices. The availability of cheap electricity from renewables, combined with relatively expensive electricity from gas turbines during periods of low solar and wind resource, create a strong economic opportunity for energy storage. In addition to daily arbitrage, the combination of renewables generating under long-term fixed price contracts and flexible energy storage assets creates a valuable price hedge against fluctuating natural gas prices. System Reliability: CAISO’s grid faces reliability challenges due to increasing reliance on non-dispatchable renewable energy sources like solar, coupled with aging infrastructure, severe weather, and peak demand spikes, especially during summer heatwaves. BESS can mitigate these issues by providing grid stability, fast-acting reserves, and ancillary services to maintain balance. This growing demand for reliability services, along with capacity payments, offers BESS projects multiple revenue streams and a strategic edge in this volatile market. Moreover, California’s aggressive renewable energy targets make it a prime market for BESS projects. Our market overview highlights CAISO’s resource adequacy and ancillary services market changes, helping you understand how to optimize project returns. SPP (Southwest Power Pool) SPP offers significant wind energy potential and continues to expand its transmission network. The surge in renewable energy within SPP is causing a downturn in electricity prices, especially during periods of strong winds, which places intense financial stress on thermal power sources and underscores the importance of adaptable capacity and presents an opportunity for Long Duration Energy Storage (LDES). Our insights into SPP’s market dynamics focus on strategies to capture ancillary service revenues and enhance renewable energy integration through storage solutions. In addition, our team has demonstrated experience in deploying LDES solutions for BTM and FTM projects, putting us in a position to provide strategic insights in this space. PJM (Pennsylvania-New Jersey-Maryland) Interconnection PJM is undergoing rapid data center expansion, especially in Northern Virginia which has put pressure on the grid, causing congestion and high nodal power prices in the Dominion territory. As one of the largest RTOs, PJM presents a strong market with various revenue streams, including capacity and ancillary services. We provide clients with analysis of PJM’s capacity market changes, ensuring projects align with this highly competitive landscape. MISO (Midcontinent Independent System Operator) MISO is currently experiencing a significant transformation in its energy landscape. This shift is characterized by an accelerated adoption of renewable energy sources, alongside a concurrent phase-out of thermal generation plants. Key drivers behind this transition include elevated prices for natural gas and electricity, legislative actions at federal and state levels, demand from energy off-takers, and increasing pressure from stakeholders. MISO's vast geography and increasing renewable penetration create opportunities for BESS projects. Our team helps you understand the benefits of locating projects near congested nodes to optimize project returns. NYISO (New York Independent System Operator) New York is pioneering ambitious climate policies that prioritize storage development. With the recent update to the Energy Storage Roadmap by the New York PSC, storage deployments are expected to increase by 2030 to achieve 6 GW of energy storage. This includes the procurement of 3 GW of bulk storage through an Index Storage Credit (ISC) mechanism, 1.5 GW of retail (Community/C&I) storage, and 200 MW of residential energy storage through the VDER structure, marking a significant shift towards expanding utility-scale storage in the NYISO market to enhance grid reliability and support renewable energy integration. Our NYISO market overview covers key programs, including the Value Stack and Clean Energy Standard, providing guidance to help you understand program specifics and on to provide you with accurate project revenue estimates. We provided some background on the VDER program to help developers and investors better understand this critical framework, which you can view here . ISO-NE (ISO New England) ISO-NE is currently in the early stages of a major shift in market dynamics, transitioning into a period characterized by rapid renewable energy growth, concurrent retirement of thermal generation facilities, and a surge in storage deployment, all fueled by state policy objectives and incentives for clean energy. ISO-NE faces grid reliability challenges and peak demand concerns, making it ideal for storage solutions. We offer insights on ISO-NE’s capacity market changes and BESS opportunities in this renewable-rich region. With Camelot’s help, developers and investors can make confident investment decisions about target markets, project economics, and navigating the latest policy and regulation challenges. We work across all the major markets and developers rely on our market expertise for everything from negotiating tolling agreements to prioritizing their portfolios of merchant market ESS projects. If you're interested in any of the U.S. ISO/RTO market overviews, feel free to reach out to us at info@camelotenergygroup.com . < Back Back

The Clean Energy Helpdesk At Camelot, we believe that local authorities, communities, local governments, and non-profits should have access to the same expert advice that is available to developers and big banks. After all, if we are going to power a just and sustainable society with clean energy, it is going to take support from everyone. As such, we have launched the Clean Energy Helpdesk, wherein members of these groups can ask for pro bono support from Camelot’s team of experts. Requests will be responded to in the order received and Camelot staff will provide up to 8 hours of expert consulting to help address topics such as: Training and technical support on battery energy storage systems for local authorities Technical assistance on energy storage codes and standards Guidance on zoning best practices Q&A with municipal officials about a planned project Business case for community renewable energy If you are a community, local authority, local government entity, or non-profit and need help with questions like these, please fill out the form below. We will be glad to review your questions with you and offer help. Clean energy should be a win-win for everyone, so if you have questions please reach out. How can we help? First name Last name Organization* Email* Phone Tell us what you need help with... Send

< Back Lynn Appollis-Laurent, PE Director, Technical Services Lynn has over two decades of extensive experience in the power, utility, and renewable energy industries. She has occupied several senior roles in transmission power grid operations, EPC, and advisory services in the renewable energy sector. Lynn has successfully directed the development and implementation of utility-scale battery energy storage systems and has provided high level technical and due diligence advisory services for more than 55 unique battery energy storage projects in recent years. In 2024, Lynn joined Camelot, bringing with her a wealth of knowledge and skills to expertly assist clients in developing, constructing, and commissioning solar, energy storage, and other clean energy assets. Lynn holds a Bachelor of Science in Mechanical Engineering from the University of Cape Town, South Africa. lynn.appollislaurent@camelotenergygroup.com

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

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

Dec 30, 2025 PJM Interconnection The Base Residual Auction The 27/28 Reliability Pricing Model (RPM) Base Residual Auction (BRA) cleared ~ 135 GW of Unforced Capacity (UCAP) at an RTO wide cap of $333.44 per MW-day. Only ~ 809 MW of UCAP did not clear due to those resources being priced above the temporary price cap of $333.44 per MW-day. Note, this price cap is expected to go away in the upcoming auction in June/July 2026 For those struggling to convert, this is equivalent to $10 per kW-mo In the absence of the cap, the auction would have effectively cleared at $529.80 per MW-day (Rest of RTO) with a reserve margin of 15.1%, clearing somewhere in the range of $26.3B The RPM cleared 14.8% of Installed Reserve Margin (IRM), 5.2% below the 20% IRM. For context, the IRM is the margin required to maintain a one-day-in-10 years Loss of Load Expectation (LOLE) According to estimates, PJM is short of 6.62 GW of UCAP Source : PJM THE BOTTOM LINE Source : PJM The price came in at the FERC-approved cap, $333.44/MW day (UCAP) for the entire PJM footprint, a slight increase (+1.3%) from the 2026/2027 Base Residual Auction. The cap, agreed to be in place for the Base Residual Auctions for delivery years 2026/2027 and 2027/2028, is calculated using the accredited capacity of the PJM reference resource. The cleared supply in the auction times the clearing price totals $16.4 billion, although not all load pays this clearing price because of the impact of self-supply and bilateral contract arrangements. GENERATION RESOURCE MIX The cleared resource mix in this auction includes: 43% natural gas, 21% nuclear, 20% coal, 5% demand response, 4% hydro, 2% wind, 2% oil and 1% solar • The latest auction results were driven by a 5,250-MW increase in PJM’s demand forecast, almost entirely driven by data centers, and a roughly 370-MW increase in cleared “unforced capacity” compared to the last auction • Reliability risk has shifted from ‘fuel security’ to ‘capacity sufficiency’ • Where prior reliability concerns focused on winter gas performance, this time around, the system is short of accredited capacity itself Even perfect performance wouldn’t fix a structural MW/MWh gap Source : PJM EFFECTIVE LOAD CARRYING CAPABILITY Source : PJM • Even at record capacity prices, PJM is still not able to attract meaningful storage capacity as well as large-scale renewables • This is telling because if high prices are not enough to incentivize investment, the issue is less to do with cost of revenue capture, but more to do with interconnection, accreditation, and rules-based risk CLUES FROM THE QUEUES Source : PJM • Based on the interconnection queue, there is ~2,500 MW of offshore wind, 914 MW of solar, 732 MW of BESS, and 569 MW of natural gas under construction at the time of writing • Withdrawals took center stage in the last 12-18 mos., where we saw ~37,442 MW of solar, 35,659 MW of BESS, 21,669 MW of natural gas, 7,414 MW of hybrids, 5,117 MW of offshore wind, 3,602 MW of onshore wind exit the queue due to a variety of reasons • The greatest number of withdrawals took place in PA, VA, IL, and IN, respectively • By capacity, VA and MD have the most projects currently under construction, whereas from a pipeline perspective, IL, VA, and OH have the most projects currently active in the queue • This underscores the fact that new generation response continues to remain weak in PJM. The BRA is signaling scarcity and it’s not going to get better without serious reforms • The auction increases the probability of an ‘out of market’ action by PJM, indicating market design as a hurdle this weakening investor confidence in RPM LOAD GROWTH PJM has flagged that one of the major drivers of the tight supply-demand balance is the increase in forecasted load, to the tune of + 5,249.9 MW, mostly attributed to large loads Summer: Projected to average 3.1% per year over the next 10-year period and 2.0% over the next 20 years Annualized 10-year growth rates for individual zones range from 0.1% to 6.3%; median of 0.7% Winter: Projected to average 3.8% per year over the next 10-year period, and 2.4% over the next 20 years. Annualized 10-year growth rates for individual zones range from 0.1% to 6.0%; median of 1.6% SOME KEY TAKEAWAYS • There was no price discovery this auction – it hit a wall When every LDA clears at the cap, price loses locational signaling value • Demand Response was the quiet winner. Required Demand Response (DR) availability increased to all hours in the year, and the calculation of the winter peak load was updated to a coincident value. This was a major driver to an increase of the ELCC value for DR from 69% in the 2026/2027 BRA to 92% in the 2027/2028 BRA • If the shortfall continues for two consecutive BRAs, PJM will trigger a Reliability Backstop Auction (RBA) with prior filing with FERC This is almost certain given the large gap between supply and demand • The clearing solution may be required to commit capacity resources out-of-merit order but still in a least cost manner to ensure that all these constraints are respected. In these cases where one or more of the constraints results in out-of-merit commitment in the auction solution, resource clearing prices will be reflective of the price of resources selected out-of-merit order to meet the necessary requirements • PJM submitted $0 offers for specific Reliability Must-Run units and will allocate the revenue as a credit to the associated load • The Chanceford-Doubs 500 kV backbone transmission line was delayed, which significantly impacted MAAC, SWMAAC and DOM CETLs. MARKET EVOLUTION • The Federal Energy Regulatory Commission this year also approved a PJM-proposed expansion of Surplus Interconnection Service to augment the operating efficiency and availability of existing resources, and the Reliability Resource Initiative, which attracted 11,000 MW of nameplate capacity in proposed, shovel-ready, high reliability generation projects. • PJM has also asked FERC for amendments to the rules on Capacity Interconnection Rights (CIRs) that would facilitate an expedited interconnection process to utilize the CIRs of a deactivating resource. • Recognizing that electricity demand is increasing faster than generation is being added, PJM is working on multiple fronts to further streamline the Interconnection Study processes. This includes our collaboration with Google/Tapestry, to leverage artificial intelligence to further streamline the study process and reduce study timelines. Raafe Khan < Back Back

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

Aug 8, 2025 Camelot Unpacks UL 9540 – Part 1 At Camelot, reviewing the UL Listing status of battery energy storage systems (BESS) for the projects we are overseeing as an Owner’s Engineer (OE) or Independent Engineer (IE) is something our team considers a good starting place in the due diligence process. This Listing is so foundational to a successful and code-compliant BESS project that we often take it for granted that everyone understands what this important Standard entails.   Unfortunately, there is a great deal of misunderstanding about the UL 9540 Listing process, even among some engineers who are otherwise pretty familiar with BESS technologies. Missing a step in verifying the proper UL listing of the BESS on a project can have large implications. For instance, an astute authority having jurisdiction (AHJ) that notices your BESS is not properly Listed may find it is not code-compliant, causing significant delays in permitting and significant costs in addressing deficiencies with the BESS manufacturer. Moreover, a UL 9540 Listing represents the successful completion of a battery (we could not resist, of course) of tests related to safety, reliability, and performance.   Understanding Standards Most folks involved in BESS projects think they know what a Standard is, as it seems pretty self-explanatory, right? Perhaps, but once you move beyond the surface level and try to parse the difference between a “Listed”, “Certified”, and “Recognized” product, it can quickly get confusing. So, let’s address a few common misconceptions.   Misconception 1: Projects Have to Comply with Standards The rollout of new standards, like NFPA 855 and UL 9540, have undoubtedly made BESS projects safer. However, complying with these Standards is not required. Organizations like NFPA or UL have no legal authority to provide, or deny, any project a permit. Permits are issued, rather, based on Codes (e.g., Electrical Code, Building Code, Fire Code) and if the Code for your project’s jurisdiction does not incorporate one of these Standards, then the AHJ may not be able to enforce the requirement. This can happen, for instance, when a local Code has not been updated recently enough to incorporate the latest versions of relevant Standards. So, unless the Code references a particular Standard, the project does not have to comply with the Standard, at least from a permitting perspective. Fortunately, many savvy asset owners have developed their own BESS technical criteria. While these criteria are unrelated to permitting, they can be used as a condition of financing. In this way, the investment community can drive better and safer installations by holding developers to the highest current Standards (literally). Misconception 2: Standards Represent the Gold Standard of Safety and Quality Given all the time taken, and the expertise of the dozens of industry experts applied, in crafting Standards it is natural to assume that each one represents the pinnacle of current thinking in design, safety, and quality. Not so. It is best to think of a Standard as the lowest common denominator that a bunch of technical folks with often-competing priorities can agree on. Anyone that has ever got more than one engineer in a room to talk about BESS likely knows that we can be an opinionated bunch, so imagine what a room with fifty engineers is like when coming up with a new technical Standard. The results are incredible acts of service to the industry, but they are only a starting place. Complying with Standards should be a bare minimum, not a stretch goal.   Misconception 3: A BESS can “Pass” or be Listed to UL 9540A Most folks understand a Standard as something that can be “passed” or “failed”. This is an understandable interpretation, as it applies to everything from everyday household appliances to BESS equipment. Unfortunately, UL 9540A is a little different. UL 9540A is actually a testing Standard that describes how a testing laboratory is to initiate and measure the impacts of thermal runaway . In completing the tests, it is literally impossible to not destroy the BESS (/ the BESS is intentionally destroyed). If thermal runaway is not initiated through one initiation method (e.g., heating), then the test continues using other methods until thermal runaway occurs (e.g., nail penetration, overcharging). There are non-lithium-ion BESS that are not subject to thermal runaway but even these do not “pass”. Instead, at each level of testing, a higher level of testing is required unless the test results fall within a particular range . For example, if a cell is tested and does not exhibit thermal runaway, it is not required to test at the module or unit level.   Misconception 4: UL 9540 Replaces Other Battery Standards In fact, UL 9540 is carefully crafted to build on other key standards, not replace them. Though many spec sheets will list UL 9540 alongside UL 1973 or UL 1741, compliance with UL 9540 already includes many of these relevant equipment-specific Standards , such as: UL 1973 for battery cells and modules UL 1741 for inverters (such as in AC block BESS products) UL 9540A for testing thermal runaway propagation risks   Wrapping Up Part 1 Misunderstandings about UL 9540 aren’t just academic - they can cause costly delays, strained relationships with AHJs, and headaches during financing or commissioning. Clearing up the myths is the first step, but knowing exactly what UL 9540 covers, when it’s required, and how to navigate the Listing or Field Listing process is where the real project-saving insight comes in. In Part 2, we’ll take that next step: unpacking the key requirements baked into UL 9540, explaining how they connect to other Codes and Standards, and clarifying the often-misunderstood Field Listing process. If Part 1 was about avoiding the traps, Part 2 is about charting the course to a compliant, bankable BESS installation. < Back Back

Nov 7, 2024 Part 2: VDER Revenue Stack As discussed in Part 1: VDER Revenue Stack for Standalone Storage Projects , while the Value of Distributed Energy Resources (VDER) Calculator is a freely accessible tool for estimating expected VDER revenues, it can fall short in accurately modeling certain revenue streams. Therefore, when evaluating investments in Battery Energy Storage System (BESS) or hybrid (solar + storage) projects, it’s crucial to supplement this initial analysis with a more detailed revenue forecast that considers additional variables encountered in real-world operations. Like other leading market analytics providers, Camelot uses an optimized dispatch model to project future revenues for BESS and hybrid projects participating in merchant energy and ancillary services markets. However, projects with substantial programmatic revenues—such as NY VDER projects—often require a more customized approach to accurately validate revenue streams and financial model inputs. To address this need, Camelot has developed additional tools and capabilities that seamlessly integrate these programmatic revenue streams with relevant merchant market opportunities. You can find more background on the VDER program here to help developers and investors understand this critical framework. For our analysis, we modeled the revenue stack of a hybrid system with a 5 MWDC solar array and a 5 MW, 4-hour BESS under the VDER program across various utilities. We estimated the Locational System Relief Value (LSRV) manually, while our optimized dispatch model calculated LBMP, ICAP Alt 1, ICAP Alt 2, and DRV values. Additionally, we created four scenarios based on the following configurations: Hybrid Systems – PV Charging Only PV Charging Only (Alt 1) PV Charging Only (Alt 2) Hybrid Systems – PV & Grid Charging PV & Grid Charging (Alt 1) PV & Grid Charging (Alt 2) Key Trends and Insights from the PV Charging Only Results Figure 1 Excerpt from Camelot Q4 2024 NY Market Outlook Report Figure 2 Excerpt from Camelot Q4 2024 NY Market Outlook Report Energy Component (LBMP): The combined energy (LBMP) values from both BESS and solar in PV Charging Only projects are not the lowest among VDER components when compared to standalone BESS projects. This is largely because there are no charging costs—BESS charges from PV rather than the grid. Installed Capacity (ICAP) Value: Capacity prices vary significantly by NYISO load zones, making capacity revenue forecasts challenging due to price volatility across zones. These prices may decline as offshore wind is integrated, which contributes both energy and capacity. ICAP Alt 2 yields higher revenue than ICAP Alt 1 across all zones, primarily due to the rate structure of ICAP Alt 2. Similar to ICAP Alt 3 (applicable only to standalone BESS), ICAP Alt 2 prices have historically been higher, especially in Zone J (NYC – ConEd Group A) and Zone K (PSEG LI). Zone J prices average 3.04 times higher than other zones due to anticipated thermal retirements and land constraints that limit new renewable integration. Demand Reduction Value (DRV): Like standalone BESS projects in areas with 2 PM to 7 PM DRV windows, PV Charging Only projects also achieve strong DRV results as these hours often align with system peak windows. In ConEd Group B (Westchester), projects within the 2 PM to 6 PM DRV window produce significantly higher DRV revenues compared to those in the 2 PM to 7 PM window, as the former aligns more closely with potential peak periods. For instance, DRV revenue in ConEd Group B is 6.36 times higher than the utility average within the 2 PM to 7 PM window and 5.82 times higher than the state average. Locational System Relief Value (LSRV): In Central Hudson’s territory, LSRV does not apply. However, the highest LSRV revenues are seen in ConEd (Zones A to C) and PSEG territories, where LSRV revenues are 2.60 times higher than the state average. Environmental Value: The environmental value remains constant across all utilities and is locked in for 25 years. This revenue stream applies only to PV Charging Only cases in VDER, making these configurations more attractive than PV & Grid Charging due to the additional revenue stream. Key Trends and Insights from the PV and Grid Charging Results Figure 3 Excerpt from Camelot Q4 2024 NY Market Outlook Report Figure 4 Excerpt from Camelot Q4 2024 NY Market Outlook Report Energy Component (LBMP): In PV & Grid Charging projects, the combined energy (LBMP) components from both BESS and solar, including charging costs, are the lowest revenue component when compared to PV Charging Only projects in VDER. This is largely because PV Charging Only projects incur no charging costs, as BESS charges directly from PV rather than the grid. Installed Capacity (ICAP) Value : Capacity prices vary significantly by NYISO load zones, making capacity revenue forecasting challenging due to price volatility across zones. These prices could decrease with the addition of offshore wind, which contributes both energy and capacity. Like PV Charging Only projects, PV & Grid Charging projects see higher revenues under ICAP Alt 2 compared to ICAP Alt 1 across all zones, primarily due to the higher rate structure of ICAP Alt 2. Like ICAP Alt 3, which applies only to standalone BESS projects, ICAP Alt 2 prices have historically been highest in Zone J (NYC – ConEd Group A), followed by Zone K (PSEG LI). Zone J averages 3.06 times higher than other zones, driven by anticipated thermal retirements and land constraints that hinder new renewable integration. Demand Reduction Value (DRV): Similar to standalone BESS projects in regions with 2 PM to 7 PM DRV windows, PV & Grid Charging projects also achieve strong DRV results as these times often align with system peak periods. However, as with PV Charging Only projects, PV & Grid Charging projects in ConEd Group B (Westchester) within the 2 PM to 6 PM DRV window yield much higher DRV revenues than those in the 2 PM to 7 PM window, as the former more closely overlaps with system peaks. For example, DRV revenue in ConEd Group B is 5.95 times higher than the utility average within the 2 PM to 7 PM window and 4.87 times higher than the state average. Locational System Relief Value (LSRV): In the Central Hudson territory, LSRV does not apply. Similar to PV Charging Only projects, the highest LSRV revenues are observed in ConEd (Zones A to C) and PSEG, where LSRV revenues are 2.73 times higher than the state average. Environmental Value: The environmental value applies exclusively to PV Charging Only cases within VDER, making PV & Grid Charging cases less favorable in the VDER revenue stack due to the lack of this additional revenue component. Conclusions The VDER revenue stack significantly diminishes for projects located outside of ConEd and PSEG territories. Although CAPEX and OPEX costs for upstate projects may generally be lower, this advantage is offset by the more lucrative revenue streams available in ConEd and PSEG regions, as highlighted in this article. When calculating these revenue streams, it’s essential to account for the various market nuances specific to the VDER revenue stack, as discussed in Part 1: VDER Revenue Stack for Standalone Storage Projects. While the VDER Value Stack Calculator is a useful tool for preliminary analysis, it may not always provide accurate forward revenue estimates. Our team recommends conducting a more detailed analysis to support the development and financing of energy storage and hybrid projects in New York State. In summary, when comparing the VDER value stack for hybrid projects under ICAP Alt 1 and Alt 2, as well as the PV Charging Only and PV & Grid Charging options, we find that PV Charging Only (Alt 2) projects generate higher revenues than PV & Grid Charging projects. This is primarily due to the Environmental value, which is locked in for 25 years at a fixed rate of $31.03/MWh, and the increased revenue potential that ICAP Alt 2 offers over Alt 1. To accurately assess the benefits of PV Charging Only versus PV & Grid Charging, Camelot can assist you in determining the optimal storage system size to co-locate with your solar system, helping you maximize returns for hybrid projects. If you're interested in assessing energy storage and/or hybrid projects in NYISO’s VDER 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