Nov 6, 2025 The Future of Grid - Scale Storage Grid forming projects: Should developers want to design grid-forming inverters they will need to engineer their systems differently. This means that auxiliary loads and losses will be higher, and economics will need to be re-casted to account for SoC-loss during standby operation and forming operation In addition, the following challenges must be navigated: Transformer inrush control POW switching or V/f pre-flux ramp for soft energization Over-voltage issues Handling reactive power absorption Resonance and harmonics Damping network oscillations and ensuring stable short-circuit response Frequency and load pick-up challenges Stabilizing V/f during cold load pickup and staged block loading Operational sequencing Q-droop hierarchy, staged energization, etc. validated via EMT and HIL tests Synchronization issues Smooth ramping, droop control, etc. Ramp rate tuning Staged load pickup and reserve margins Raafe Khan and Shawn Shaw < Back Back

Apr 4, 2025 New U.S. Tariff Policy In an Executive Order signed on April 2, 2025, President Trump has instituted a minimum 10% universal tariff on all imports starting April 5. These 10% tariffs will be additional to “Reciprocal Tariffs” between 10% and 50% on products from about 60 countries starting April 9. The Trump Administration has calculated these Reciprocal Tariffs based on the ratio of country-level trade deficits with the US divided by the value of US imports from the target country. This ratio is being described as a measure of perceived unbalanced trade practices against the US and the Reciprocal Tariffs are being set at 50% of this value for most countries. We note that there are a variety of reasons for countries to have trade deficits and the existence of such deficits is not, in its own, an indication of unfair or unfavorable trade policies. It merely conveys that the US buys more of a country’s exports than that country buys of US exports and these deficits are a normal part of global trade between nations. Exceptions ➡️These new tariffs will not apply to goods that have been loaded on a vessel at a port and are deemed to be in transit before the new rates go into effect. ➡️The universal rate will not apply to goods in transit to the US before April 5 and the reciprocal rates will not apply to goods in transit to the US before April 9. ➡️According to the Executive Order, the new tariffs will not apply to certain articles that President Trump has already singled out for current or possible future sector-specific tariffs. Per the National Electrical Contractors Association (NECA), these sectors are steel, aluminum, some downstream products that use steel or aluminum, copper, pharmaceuticals, autos and auto parts, semiconductors, certain critical minerals and energy and energy products. ➡️The tariffs apply only to the non-US content of goods that include US components. However, at least 20% of the value of such goods would have to originate within the US. Implications for the Energy Sector The new tariffs will impact a variety of energy related technologies, from solar modules produced in Vietnam to wind turbines made with foreign components. FERC recently released their Energy Infrastructure Update for January 2025, in which they noted that the vast majority of new generating capacity will be in solar and wind . Other equipment necessary for bringing power plants online, like switchgear, transformers, and substation equipment is largely imported and will see costs increase. The fossil fuel industry is not exempt, either. Thermal generation equipment, like natural gas combined cycle (NGCC) turbines. Supply is already constrained, and capacity is tied up until about 2029-2031 from Tier 1 suppliers, so added costs will add even more strain. The broad application of new tariffs is expected to have an impact across the energy sector, from gas turbines to solar modules, just as energy demand is growing nationwide to fuel the growth of the AI sector. Impacts on the Energy Storage Supply Chain Many of the countries that supply battery energy storage systems (BESS) to the US market are heavily impacted by the new tariffs. As it currently stands, assuming no other changes, by January 2026, BESS from China will be subject to a total tariff of about 82.4%, as shown below. Clearly, juggling all of the relevant tariffs and duties is a significant exercise with many moving parts. *HTSUS = The Harmonized Tariff Schedule of the United States Tariff Rate Base Tariff, applied March 2025 20.0% HTSUS* Tariff (2012) 3.4.0% Section 301 Tariff 7.5% (2025), 25.0% (2026) Reciprocal Tariff 34.0% Total 64.9% (2025), 82.4% (2026) A summary of the major BESS exporting countries to the US and their new tariffs is shown below. Imported BESS from China have a significantly higher expected tariff than most other countries exporting BESS into the US market. The final tariffs on any product, however, will be complicated to determine as the underlying components may, themselves, be subject to additional tariffs (e.g., an Indonesian BESS made with Chinese inputs). This will be most impactful to the lithium iron phosphate (LFP) BESS suppliers in the near term but with no country being exempt from at least some sort of tariff, we can expect a great deal of supply chain adjustment in the months ahead. Country HTSUS Tariff Base Tariff Section 301 Tariff (Before 1/1/26) Section 301 Tariff (After 1/1/26) US Reciprocal Tariff Total New Tarriff Rate in 2025 Total New Tariff Rate in 2026 China 3.4% 20.0% 7.5% 25.0% 34.0% 64.9% 82.4% Indonesia 3.4% 10.0% 0.0% 0.0% 32.0% 45.4% 45.4% South Korea 3.4% 10.0% 0.0% 0.0% 25.0% 38.4% 38.4% Japan 3.4% 10.0% 0.0% 0.0% 24.0% 37.4% 37.4% Impacts on Battery Storage Pricing Based on our tariff tracker, Chinese made DC blocks are now effectively between the $130 - $180 per kWh-dc range (DDP to site), whereas Non-Chinese DC blocks (manufactured in let’s say Indonesia) are between the $115 - $165 per kWh-dc range (DDP to site). Baseline costs are expected to shift in the near term so this gap may narrow or widen further based on macroeconomic conditions. The gap between domestically manufactured non-LFP DC blocks and Chinese made LFP blocks is expected to narrow by early next year to about $50-$60 per kWh-dc. This means, if OEMs in this category reduce their prices by about 25-30%, based on current capacity projects, then, domestically manufactured non-LFP BESS will be a more attractive option for buyers based on total cost of ownership, not inclusive of the domestic content adder under the IRA. It is to be noted that the American Active Anode Material Producers (AAAMP) filed an AD/CVD petition in 2024 seeking a tariff of up to 910%. This has not yet been adjudicated by the Department of Commerce; however, we expect some movement on this later this fiscal year. Chart from Camelot Energy Group – Impact of April 5 Tariff on DC Blocks International Reactions The scale of the current trade actions is highly likely to elicit stiff responses from the international community. As of this morning of 4/4/25, China has announced a 34% tariff on all US imports, alongside increased export controls affecting rare earth minerals and other key materials exported to the US. While the US is a net importer of most clean energy technologies, US exports of biofuels and components for wind and hydropower systems may be impacted. Perhaps even more impactful, however, would be an increase in export controls that reduce the availability of key input materials. Efforts to onshore lithium-ion battery production, for example, will struggle without a ready supply of high grade graphite for making suitable anodes (currently, despite recent AD/CVD claims, there are no domestic suppliers of graphite who can meet the battery industry’s purity requirements). Also, the majority of equipment used in manufacturing solar cells is currently sold by China, with one recent manufacturer Camelot spoke with indicating the only other option was to buy European equipment at “4x the cost and half the output” compared to the Chinese alternatives. If these trade actions are intended to spur a renaissance of domestic manufacturing, the US is highly vulnerable to interrupted supply chains and export controls from abroad that restrict the very tools we need to build and scale a domestic manufacturing industry. The global trade situation and its impacts on the clean energy sector are evolving quickly and this is a developing topic. Stay tuned for periodic updates from the Camelot team in the days ahead. Follow us on LinkedIn for the latest insights. Next Steps for Industry Stakeholders With growing pressure due to pricing, it is time to carefully evaluate projects and supply chain risks. The Camelot team can help asset owners, investors, and other key stakeholders: Perform due diligence on potential new projects, optimizing technology, revenue streams, and asset management strategy Establish, strengthen, and diversify supply chains to ensure you have flexibility to keep your projects on track Evaluate new technologies that may offer new opportunities, as well as new challenges The Camelot team combines technical, economic, procurement, and strategic insights to help our clients navigate the changing market. Reach out to Hello@CamelotEnergyGroup.com today. We look forward to hearing how the new tariffs affect your business- and ensuring you get the help you need. Bespoke technical and strategic advisory for a better world Raafe Khan, Shawn Shaw < 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

< Back Sagar Bharadwaj, PMP Project Manager Sagar Bharadwaj is a Project Manager at Camelot Energy Group with experience in renewable energy, energy storage, and project management. His work spans battery energy storage systems (BESS), long-duration energy storage, hydrogen technologies, technical project management, and engineering coordination, supporting projects from early-stage development through execution. Prior to joining Camelot, Sagar worked across the energy storage and clean energy sectors, supporting the development of lithium-ion and non-lithium battery technologies, hydrogen-powered aviation systems, and utility-scale energy storage projects. He managed the development of a long-duration battery energy storage project at the University of Minnesota, leading technical evaluations, procurement strategy, financial analysis, and project planning. He also supported the development of hydrogen-powered aviation systems at ZeroAvia and contributed to the development of battery technologies at Aerosapien Technologies. Sagar holds a Master of Science in Energy Science, Technology & Policy from Carnegie Mellon University and a Bachelor of Technology in Mechanical Engineering from Vellore Institute of Technology (VIT). He is also a certified Project Management Professional (PMP®). Outside of work, Sagar enjoys producing music, experimenting with new recipes, traveling to national parks, and staying up to date on emerging technologies Sagar.Bharadwaj@camelotenergygroup.com

Aug 30, 2024 Solar Availability Series Part 3 Welcome back for Part 3 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, please checkout Part 1 and Part 2 of this series. We’ve set the groundwork with how availabilities are calculated and reported along with the current state of IE assumptions. Today we’ll touch on ways of maximizing availability (minimizing downtime). This topic could be its own series, so we’ll focus on the bigger picture. If you’re curious about Camelot’s stance on availability assumptions as an IE, be on the lookout for future parts in this series. Thank you for joining us! The most impactful sources of downtime come from major component failures such as from inverters, which put entire blocks of a system offline at the same time, although more minor events can still bring smaller portions of the site down. We’ll focus primarily on the most impactful contributors to downtime here. There are two broad, controllable factors which impact availability: The frequency of downtime events , driven by component failure rates and the need for planned maintenance. The quality of the engineering and proactive maintenance is important for this piece; and The duration of downtime events , driven by staffing, readiness of replacements, and other primarily-O&M considerations. Reducing the Frequency and Duration of Downtime Events During Operations Owners and O&M providers and can have a significant impact on both the frequency and duration of downtime events at an operational project once it’s been built. Here are a few recommendations for ensuring success: Follow a Robust O&M Agreement. The O&M agreement should be closely followed during operations, which unfortunately does not always occur. The agreement should be robust and include elements of the items below. More recommendations for O&M agreements are also included in the next section. Predictive Maintenance: Utilize data analytics to predict potential equipment failures before they occur. By analyzing trends and historical data, O&M teams can identify patterns that signal imminent issues, allowing for timely interventions. Sufficient Preventive Maintenance: Schedule regular maintenance based on equipment manufacturers' guidelines and site-specific conditions. This includes checking electrical connections and inspecting mechanical systems such as trackers. Of note, energy-based availabilities can be optimized by scheduling maintenance events during periods of expectedly-low production. The time-based availability metric might be the same, but the smaller energy loss means a higher energy-based availability. Spare Parts Management: Maintain a well-stocked inventory of critical spare parts on-site or at a nearby location. This ensures that replacements can be done swiftly without waiting for parts to be ordered and delivered. Follow manufacturer recommended list and review periodically as components may become less available over time. Strong Vendor Relationships: Collaborate closely with equipment manufacturers and vendors to gain access to the latest updates, best practices, and support services. This can also help in negotiating favorable terms for spare parts and service agreements. Third-Party Audits: Engage third-parties to review the performance of the O&M program periodically. External audits can provide fresh insights and identify areas for improvement that internal teams might overlook. Training: conduct regular staff training and testing to ensure readiness for major component failures and extreme weather events. An inverter fire which caused system-wide availabilities to drop for a significant period of time Reducing the Frequency and Duration of Downtime Events During Development O&M activities may be the most visible contributor to a Project’s operational success, but they are not everything. An ace car mechanic can still see more issues with an old, poorly-built junker than a novice will see with a durable, high-end car. Camelot encourages developers to have a mindset of ensuring long-term operational success, which leads to fewer issues and less-impactful downtime. For this, we offer a few broad suggestions: Environmental Impacts: Consider site suitability at an early stage. Evaluate potential environmental risks such as wildlife interference, extreme wind speeds, natural disasters, and erosion which could affect the project’s operation and maintenance. Durable Components : Select robust inverters, transformers, racking systems, and other components designed to withstand harsh environmental conditions and have low failure rates. This often means evaluating cost tradeoffs for more expensive components. Exceed Codes and Standards: At a minimum, ensure the project complies with all local, regional, and international standards for safety, performance, and environmental impact. Even more importantly, most EPC agreements only require code compliance, and code is not about longevity of the asset, it is about safety. As such, make sure your EPC Agreement reflects materials, methods, and design standards consistent with the planned (and financed) useful life. Access: Ensure the site has adequate access for maintenance personnel, which can impact the duration of downtime events. Make major equipment accessible near site roadways and ensure roads are wide enough to facilitate easy use of cranes and other heavy kit. Design the site to allow for spacing between components so that specialized equipment isn’t required for access and repair. Remote Monitoring Infrastructure : Deploy advanced SCADA (Supervisory Control and Data Acquisition) systems to monitor the performance of the solar farm in real-time. This allows for quick identification of issues before they lead to significant downtime. Contract with Reliable O&M providers : Developers will elect to engage with O&M providers during the later stages of development, and should do their due diligence on prospective providers to ensure they will have the right capabilities. The O&M contract should be comprehensive and include elements of the list in the prior section. A few of the most impactful items include: Availability Guarantees: The agreement should include specific availability targets. These targets set clear expectations for how often the solar plant should be operational, and should be tied to incentives to increase the chance of compliance and incentivize high availability. Maintenance Schedules and Protocols , including preventative maintenance schedules, corrective maintenance procedures, and component replacement protocols. Regular Reporting Requirements: The agreement should mandate regular performance reports, including availability, downtime events, maintenance activities, and any corrective actions taken. Transparency in reporting helps project owners monitor O&M effectiveness. For more details on ways of ensuring optimal operations at a solar project, Camelot has released a couple of related articles, including Navigating the Testing and Commissioning Process for Solar Projects , and Tips and Tricks for Procuring PV Modules in 2024 and Beyond . For quick examples of some of the more notable mistakes made in construction/operations which directly lead to lower availabilities, you can follow us on our ongoing Field Failure Series (FFS) . The next article in this series will cover Camelot’s balanced approach when advising our clients on availability expectations for our projects. 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 20, 2025 New Acquisition Opportunity in MISO 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 another new opportunity with our network. It’s for a portfolio of ten hybrid (Solar + BESS) projects and one standalone BESS in MISO, a region where many folks have had development and acquisition interests in projects of these kinds. This unique opportunity comprises ten hybrid projects and one standalone BESS totaling 327 MW of solar with co-located BESS + 200 MW of standalone BESS , available for sale in Illinois, Indiana, Wisconsin, and Michigan, USA. Projects are in mid-stage development. Eight of the eleven projects belong to the DPP 2022 cluster and have received their DPP1 Interconnection Cost Estimates from MISO. Initial development, including CIAs, Wetland Delineations, and Phase 1 ESAs, has been completed. The Projects benefit from long option periods of up to 10 years, providing significant flexibility in development. Geographic diversification across four states helps mitigate idiosyncratic market risks of development. Additional details are provided below. The seller is targeting to receive non-binding offers by March 28th, 2025 – please reach out now if you are interested! The seller’s preference is to transfer the ownership of the entire portfolio but is open to considering proposals for a subset of the portfolio in the interest of maximizing the value and number of projects that achieve commercial operation. Camelot Insights Camelot has recently performed diligence on several projects in MISO and we find that revenues can vary widely based on the system sizing and offtake strategy. Similar hybrid projects present a great opportunity and favorable economics in MISO; the ISO took the lead in 2024 with the highest total hybrid capacity in asset level M&A transactions compared to other ISOs/RTOs. In MISO, both Energy and Capacity account for a significant portion of the total revenue stack. Camelot recommends a thorough review of the revenue stack assumptions for the projects in this portfolio. Capacity Market: As MISO transitions to the Direct Loss of Load (DLOL) accreditation method for its capacity market, the accreditation for certain renewable resources is in flux and should be considered. The DLOL accreditation method evaluates the contributions of different resources primarily based on the availability of class-wide resources during a select set of high-risk hours. This method serves as a practical approximation of marginal Effective Load Carrying Capability (ELCC), potentially affecting how renewable and storage assets are valued within the capacity market. Energy Market : The energy market in MISO plays a crucial role in project economics due to its inherent nodal volatility. The variability in Locational Marginal Pricing (LMP) across nodes can present both risks and opportunities. Projects sited near congested nodes may experience significant price swings, which can create arbitrage opportunities for storage assets, allowing them to capitalize on price spreads. Given these factors, strategic site selection and an in-depth nodal analysis are recommended for maximizing returns in the MISO energy market. Costs & Technical Insights : Camelot also has recent data on CAPEX and OPEX applicable to the region and can perform a wholistic economic analysis of the projects to vet the seller’s assumptions. This, together with an evaluation of technology, designs, and key agreements, can help to refine your valuation and de-risk the technical aspects of the transaction. Please Reach Out Overall, this is an attractive opportunity in a very active market. If you are interested, we would be glad to put you in touch with the seller, and if you decide to pursue and need any help on the due diligence side of things, please reach out to Michelle Aguirre or Shawn Shaw, PE . Upcoming Webinar with Enerdatics Finally, stay tuned for an invite to an upcoming webinar which will be co-hosted by Camelot Energy Group and Enerdatics covering key trends in the US M&A market in 2024, including the growth of BESS and hybrid projects, and the uptick in activity in MISO. < Back Back

Aug 8, 2025 Camelot Unpacks UL 9540 – Part 2 In Part 1 of our Camelot Unpacks UL 9540 series, we tackled some of the most common misconceptions about this critical Battery Energy Storage System (BESS) Standard - misconceptions that can easily derail schedules, inflate costs, or cause compliance headaches. Now, it’s time to move from myth-busting to the nuts and bolts. In Part 2, we’ll walk through some key questions regarding the requirements baked into UL 9540, highlight when and why it’s required, and shed light on the often-misunderstood Field Listing process. Whether you’re overseeing a project, supplying equipment, or working on the financing side, this is the knowledge that keeps your BESS project both compliant and bankable. What does UL 9540 include? While no product certification is ever a perfect guarantee of safety, the UL 9540 Standard is fairly broad in its scope as it's intended for an ESS as a whole, with key tests summarized below. These tests are additional to compliance requirements related to materials, construction, software, electrical design, fire safety design, noise levels, and more. These tests are also additional to any component-level tests required. For example, UL 1973 includes about 30 different tests on the battery modules alone, covering a range of potential risks, such as overcharging, over-temperature operation, external fire exposure, and physical impacts. Table 1: UL 9540 Key Tests Test Category Test Name Description   Electrical Safety Grounding & Bonding Ensures low resistance ground path to safely handle potential fault currents   Electrical Safety Electromagnetic Immunity Ensures safety sub-systems are not subject to electromagnetic interference and electrostatic discharge.   Electrical Safety Insulation Resistance Confirms insulation provides suitable impedance to prevent unintended current flow.   Electrical Safety Dielectric Voltage Withstand Confirms the suitability of dielectric materials to prevent current flow without breakdown.   Electrical Safety Impulse Test Assesses resistance to electrical surges. Fire & Thermal Safety Thermal Runaway Propagation Requires testing according to UL 9540A, with results incorporated into the system design. Mechanical Safety Leakage Confirms no leakage occurs when stress-testing liquid coolant systems with elevated pressure levels. Mechanical Safety Strength Confirms that elevated pressure in coolant systems does not cause damage to piping and equipment. Environmental Testing Seismic Confirms no major equipment damage after simulated seismic event. Environmental Testing Salt Fog Confirms resistance to marine environments. Environmental Testing Moisture Resistance Tests to confirm that enclosures properly resist water ingress. Other Operational Tests Normal Operating Verifies that ESS components do not exceed temperature ratings during normal charge/discharge behavior. Key Subordinate Standards Compliance with UL 1973 (Batteries) Ensures battery modules meet safety and performance standards. Key Subordinate Standards Compliance with UL 1741 (Inverters) Tests the safe integration of inverters in the system.   When is UL 9540 Listing Required? Compliance with UL 9540 is required under a number of major Codes, as summarized below. Note that, as of this writing, nearly all locations within the US require compliance with at least one of the Code editions noted below (or a more recent version). There are likely a few local jurisdictions not yet enforcing these Code editions but, essentially, Listing to UL 9540 is a Code requirement nearly anywhere in the US.     Referencing Code First Version Incorporating Listing for BESS Relevant Section(s) NFPA 70: National Electrical Code 2017 706.5 NFPA 1: Fire Code 2018 Chapter 52, which requires compliance with NFPA 855 which, in turn requires UL 9540 Listing in Section 9.2.1 (2023 Edition) IFC: International Fire Code 2018 1207.3.1   Is it Acceptable to Field List a BESS to UL 9540? Certainly, this is quite common and widely accepted. In practice (and in Code) an ESS is "one or more devices, assembled together, capable of storing energy to supply electrical energy at a future time". As you can see, this goes beyond simply the ESS enclosure to include the equipment facilitating connection to the broader electrical system, such as the inverter. Most ESS manufacturers will not have an infinite combination of their product listed with each possible DC converter, inverter, and transformer. As such, Field Listing is widely required to validate the "system" meets relevant Code requirements.   How does Field Listing Work? The term "Field Listing" is a slight misnomer, as the "field" portion is only a small part of the overall review. In fact, completing the Field Listing requires considerable review of documentation and generally requires that all the components of the ESS be Listed to their own respective Standards (see summary above). The Nationally Recognized Testing Laboratory (NRTL) doing the Field Listing will review the documentation and subordinate Listing status of all the major components in order to underpin their final Field Listing. As you can see, a successful Field Listing requires that the ESS uses high quality components that are properly Listed, and the Field Listing is really just validating the site-specific combination of those components (and that those components have been installed/used per their Listing). Once complete, the NRTL will issue a Field Listing that applies only to that specific project or installation. Even if the exact same equipment is used again at another site, a new Field Listing is still required. The pathway from Code requirement to (some of) the underlying Standards is summarized in the figure below. As you can see, a simple UL 9540 Listing has a lot behind it and is a critical element in having a high quality and bankable BESS. Figure 1: Compliance Pathway   Why do the Components Need to be Listed Separately for a Field Listing? Put simply, many of the required tests to List a BESS to UL 9540 are destructive in nature and you would not want them done to your commercial project. For example: UL 9540A testing requires initiating thermal runaway (aka making the system catch fire on purpose) Vibration and Impact Resistance tests may involve damaging your enclosures Overcurrent and overvoltage tests require exposing the BESS to electrical conditions beyond its design As you can imagine, few manufacturers would be willing to honor warranties after you abuse their system in such ways. So, since we can't deliberately set projects on fire in the field, the NRTL will have to rely on the test results used to obtain other component Listings. As shown above, the DC Block is already Listed to UL 9540. In these cases, all of the most strenuous tests have already been completed and found sufficient by a NRTL and the Field Listing can really focus on the combination of components. In some cases, NRTLs may be willing to issue Field Listings based on manufacturer test reports, engineering analyses, and similar documents but this is a very risky prospect and will take considerably longer and increase the cost to the owner. Also, if the NRTL finds they don’t have sufficient basis for granting the Field Listing, they may require additional testing from the manufacturer, leaving your project in a sort of Limbo state for months, if not longer. So, while any combination of ESS components can theoretically be granted a Field Listing, it is far safer to ensure your ESS is a combination of already-Listed components. In particular, using a DC block that is Listed to UL 9540 in its own right is a great way to reduce the risk of significant costs and/or delays in the final Field Listing process. < Back Back

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Camelot Energy Group is a technical & strategic advisor to owners and investors in clean energy & energy storage projects, programs & infrastructure. We specialise in Solar, Energy Storage, Consulting, Engineering, Batteries, Due Diligence, Energy Access, Strategy, Owner’s Engineering & Advisory. FEATURED PROJECTS Sectors We Serve Camelot Energy Group specializes in the clean energy sector, particularly focusing on these key areas: Solar Energy Storage Clean Energy Programs Energy Access Solar Energy Storage Clean Energy Programs Energy Access 01. SOLAR Enough solar energy falls on the surface of the earth in one hour to supply all of the energy needs of the global population for a year. However, when it comes to capturing and using that energy, the devil is, as they say, in the details. At Camelot Energy Group, we specialize in those details and our team members have supported the financing and construction of over 7GW of solar PV projects, including: Managing quality assurance for portfolios of distributed solar projects and performing hundreds of hands-on field inspections Performing Owner’s Engineering on utility scale projects from 500kW to 100’s of MW Providing technical due diligence and independent engineering (IE) services to support financing of portfolios, projects, and development platforms Supporting and evaluating state clean energy programs to support solar PV and related technologies Developed and delivered numerous trainings on relevant codes, standards, and best practices Our team members have supported many different public and private clients building and investing in solar technologies. See our Services page or contact us to learn more. 02. ENERGY STORAGE Scaling adoption of clean energy technologies will require a range of enabling technologies but none is more critical than the ability to safely and cost-effectively store and manage electricity. Energy storage technologies, from lithium-ion batteries to pumped hydro facilities, are key to managing the grid of tomorrow and the team at Camelot Energy Group has unique expertise and insights into the energy storage industry. From island microgrids to large utility-scale grid support applications, our team members have supported the energy storage transition for nearly two decades and bring core expertise in: Ensured asset owners receive the best possible technologies, designs, and installations during typical Owners Engineering engagements Evaluating new technologies and suppliers through our Strategic Advisory services Performing Technical due diligence and independent engineering on energy storage (including those with colocated solar) facilities and portfolios Developing and delivering trainings to support government entities and clean energy programs Provided key insights on developing codes and standards via our recent publications, including our founder’s recent book , published with the International Code Council and International Association of Electrical Inspectors. Our team members have supported dozens of energy storage projects, including over 4GWh projects. Please contact us if you would like to know more. SOLAR ENERGY STORAGE 03. CLEAN ENERGY PROGRAMS Clean energy programs often provide valuable incentives and technical support that have been key to driving adoption of new technologies. Though solar PV is much more cost-effective than it was even a few years ago, these programs continue to play a vital role and Camelot Energy Group is pleased to support these efforts. Our team members have: Helped state incentive programs build and manage quality assurance programs, ensuring that public funds support high quality, safe, and effective installations through program design, technical design reviews, process improvement, and implementation of over 4,000 hands-on field inspections. Evaluated public and utility-run incentive programs to determine cost-effectiveness, participant satisfaction, attributable energy benefits, and support filings with relevant regulatory bodies. Supported utilities during Integrated Resource Plan processes by analyzing technical, economic, and market potential for solar , energy storage, and other clean energy technologies. Our team members have worked with programs at the federal level and in over a dozen states. If you manage clean energy programs and need support running, evaluating, or expanding such a program please contact us. CLEAN ENERGY PROGRAMS 04. ENERGY ACCESS Globally, more than 750 million people (twice the population of the United States) lack access to electricity and some 2.6 billion people lack access to clean cooking fuels. At Camelot, we believe that a transition to a clean energy future must include energy access for all and we are glad to support these efforts through: Ensuring high quality and safety standards are maintained through Owner’s Engineering Helping impact investors support good projects and technologies with Technical Due Diligence and Strategic Advisory services Providing technical support and expertise to Clean Energy Programs The global impact investment market is a growing and powerful tool for implementing positive change in energy access. If you need help on this important topic, we would like to hear from you. Please contact us. ENERGY ACCESS

< Back Shawn Shaw, PE Founder, CEO Shawn Shaw is the founder and CEO of Camelot Energy Group and has over 21 years of experience in the renewable energy and energy storage industry. During that time, Shawn has supported public programs in more than 10 states and acted as technical advisor to many of the largest banks and financiers in the world, providing technical due diligence, owner’s engineering, and independent engineering on well over 8 GW of solar PV and 5 GWh of energy storage projects in the US, Latin America, and Europe, ranging from design and construction of offgrid island power systems to acting as Independent Engineer for financing multiple 400MWh energy storage projects in complex US markets. Shawn has experience working with a wide variety of equipment suppliers, project developers, banks, financiers, government entities, and incentive program administrators. Shawn is a registered electrical engineer (Power Systems) in New York State and holds a B.S. in Applied Physics from Rensselaer Polytechnic Institute. Recently authored Energy Storage Systems: Based on the IBC, IFC, IRC, and NEC in collaboration with the International Code Council. shawn.shaw@camelotenergygroup.com

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

Oct 10, 2024 Part 1: VDER Revenue Stack Many developers and financiers rely on the Value of Distributed Energy Resources (VDER) Calculator, a freely accessible spreadsheet calculator tool ( here ) to calculate expected VDER revenues for potential projects. While this tool is freely available and relatively easy to use, we find that it can be insufficient for accurately modeling some potential revenue streams. Some potential shortcomings of an approach relying solely on the VDER calculator could include: The VDER calculator uses only a linear degradation model and a fixed round-trip efficiency value for the life of the project. In reality, degradation follows a curve and RTE also degrades over time. The VDER calculator uses historical call periods for Locational System Relief Value (LSRV), when in actual operation, an operator would act to maximize LSRV revenues by discharging coincident with Demand Reduction Value (DRV) periods. This can result in the VDER calculator under-representing LSRV revenues. Actual Location Based Marginal Pricing (LBMP) revenues are calculated at the nodal level, while the VDER calculator uses zonal-level data, which is not sufficiently granular to accurately capture true prices. ConEd revenues are calculated by Group (A-D) and these groups are not present in the VDER calculator. So, while the VDER calculator is a helpful tool for preliminary analysis, when making an investment in utility-scale BESS, it is important to supplement this initial analysis with a more detailed revenue forecast that accounts for the many additional variables present in actual operations. Like other leading BESS market analytics experts, Camelot uses an optimized dispatch model to calculate future revenues for BESS projects participating in merchant energy and ancillary services markets. However, projects with significant programmatic revenues, like NY VDER projects, often require a more tailored approach to validate revenue streams and financial model inputs, so Camelot has built out additional tools and capabilities to incorporate these revenue streams seamlessly with applicable merchant market opportunities. We provided some background on the VDER program to help developers and investors better understand this critical framework, which you can view here . Below, we have modeled the revenue stack for a 5 MW, 4-hour Battery Energy Storage System (BESS) under the VDER program for various utilities. We estimated LSRV and Installed Capacity (ICAP) revenues manually, while using an optimized dispatch model to estimate LBMP and DRV values. Figure 1 Excerpt from Camelot Q4 2024 NY Market Outlook Report Reasons for manually modeling LSRV and ICAP Alternative 3 (Alt 3) LSRV: Since the VDER Calculator does not distinguish between ConEd Groups (A-D), it can incorrectly place LSRV revenue periods outside the DRV windows for ConEd C and D Groups. In reality, these LSRV calls would correctly align with the DRV windows in each ConEd Group, therefore we have manually adjusted the LSRV periods in ConEd C and D Groups to correct for this. For example, in ConEd Group C , 2023 historical data would suggest that the LSRV period occurs from 2pm-3pm, whereas the DRV period is from 4pm-8pm. In this case, an optimized dispatch might prioritize the DRV period, resulting in no LSRV revenues. Camelot, therefore, adjusts the LSRV revenues to reflect the more likely operating scenario wherein a BESS would gain both LSRV and DRV revenues. Regions with longer DRV windows, such as RG&E, show the greatest loss in LSRV revenues due to capacity degradation in the BESS, as the systems age and become less able to fully discharge over 5+ hour DRV windows. Regions with shorter typical DRV windows or windows capturing most of their revenue within an hour or two , such as ConEd A, were less affected by BESS capacity degradation. Figure 2 Excerpt from Camelot Q4 2024 NY Market Outlook Report ICAP Alt 3: Under the VDER program, ICAP Alt 3 is the sole option for BESS projects and is considered the most lucrative ICAP variant, though this varies by region. Monthly compensation is awarded based on injections during the annual peak hour multiplied by the ICAP Alt 3 rate ($/kW), which fluctuates monthly. Additionally, all ICAP alternatives already account for an ELCC (Effective Load Carrying Capability) adjustment, eliminating the need for further capacity accreditation adjustments. Moreover, since capacity prices fluctuates on a monthly and annual basis, we modeled ICAP manually using the 2024 VDER Calculator and applied an escalation rate based on our market outlook. Key trends and insights from the above figure results The energy component is the smallest contributor to the value stack, largely due to higher charging costs in ConEd and PSEG areas, which face elevated electricity prices caused by high demand, congestion, and transmission losses. Thought energy is discharged at a higher price, too, the difference (high minus low) in price can often be modest. Capacity prices vary significantly by NYISO load zones, making it challenging to predict capacity revenues due to the volatility of auction prices across zones. Prices could decline with the addition of offshore wind, which contributes to both energy and capacity. Historically, capacity prices have been high across Zone J (ConEd NYC) and Zone K (PSEG LI), with Zone J (ConEd NYC) averaging 2.5 times higher than other zones due to expected thermal retirements and the difficulty of integrating new renewables due to land constraints. Projects located in regions with 2 PM to 7 PM DRV windows show the best results, as these times overlap with potential system peak windows. For example, DRV revenues in ConEd and PSEG regions are much higher than in other areas, with ConEd DRV revenues 7.02 times higher than the state average and PSEG DRV revenues 2.22 times higher than the state average. In the Central Hudson utility territory, LSRV does not apply. The highest LSRV revenues are observed in ConEd and PSEG, particularly in ConEd Zone A, where LSRV revenue is 3.17 times higher than the state average. PSEG’s LSRV revenues are, on average, 1.13 times higher than the state average. Conclusions In summary, the VDER revenue stack diminishes considerably when projects are located outside of ConEd and PSEG territories. Though CAPEX and OPEX costs for upstate projects may be generally lower, this is more than offset by the more lucrative revenue streams noted in this article. In calculating these revenue streams, it is important to consider the many market nuances applicable to the VDER revenue stack. The freely available VDER Value Stack Calculator, while a good initial analysis tool, may not be sufficient in all cases to estimate accurate forward revenues and our team recommends a more detailed analysis be done to support development and financing of energy storage projects in New York State. Stay tuned for Part 2, where we will discuss and compare the VDER value stack for hybrid projects under ICAP Alt 1 and Alt 2, as well as the PV Charging Only and the PV & Grid Charging considerations. 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