Jan 14, 2025 New Acquisition Opportunity in ERCOT At Camelot, we always try to keep a finger on the pulse of the solar and energy storage M&A market, as many of our clients turn to us for technical and market due diligence on these sorts of engagements. We just had a noteworthy M&A opportunity come across our desk from our friends at Enerdatics and wanted to share this opportunity with our network. It’s for one hybrid (Solar + BESS) project in ERCOT – a region where many folks have had development and acquisition interests. A few details to highlight: Project located in Reeves County (West Hub) Point of Interconnect PV Capacity is 16.1 MWdc and BESS Capacity is 28.2 MWh (Assumed to be a 2-hour battery with an overbuild). It’s designed to participate in ERCOT as a Settlement-Only Distribution Generator (SODG) with Clip Charge and Energy Arbitrage. Solar PV will employ bifacial modules with single-axis tracker and the BESS equipment will use Li-ion technology. Interconnection is planned with Texas New Mexico Powe Company (TNMP), with a 12.47 kV voltage specification, connected to a substation, which is 0.3 miles from project to Point of interconnect. Key milestones such as the completion of Initial Assessment (IA) studies and Phase I ESA have been achieved for both sites. Due to its location, there are no county requirements for environmental permitting. Given the project size, state permitting requirements are also favorable. Lease agreements for 30+ years have been secured Approx. 70 Acres secured, possibly allowing future additional buildout Anticipated COD in Q4 2025. Camelot has recently performed diligence on, and supported the development of, several projects in ERCOT (“TX 10’s”) and we find that revenues can vary widely based on the specific node, though volatility in the region is moderate and favorable to BESS project economics. The DC-coupled configuration is somewhat unique to the market, allowing clipping capture from the solar side, but making market participation more difficult; In ERCOT, regardless of the coupling configuration, the solar and the BESS systems apply for interconnection separately. Camelot also has recent data on CAPEX and OPEX applicable to the region, and can perform a wholistic economic analysis of the projects to verify the seller’s assumptions. Overall, depending on the quality of the development of course, this could be good opportunities in an active market. If you are new to the ERCOT market and/or BESS considerations, feel free to check out our relevant articles: www.linkedin.com Ahead of the Curve: How to Choose Forward Curves for BESS Projects Tips For Selecting Optimal Forward Curves for Energy Storage Projects with Mina M. Hanna Last week we introduced why accurate forward curves are critical. www.linkedin.com ERCOT Auxiliary Services for Energy Storage Systems Overview ERCOT purchases ancillary services in the day-ahead market to balance the forthcoming day's electricity supply and demand on the grid and address real-time operational challenges. These services, which can be offered by either generators or consumers, allow for rapid adjustments to the electricity s www.linkedin.com Understanding BESS Augmentation in the Renewable Energy Landscape Modern Battery Energy Storage Systems (BESS) lose available energy capacity as they age and are used to store and discharge energy. As such, many asset owners must carefully consider their approach to maintaining energy capacity throughout the useful life of the BESS. If you are interested, we would be glad to put you in touch with our friends at Enerdatics who are tracking the deal and, of course, if you decide to pursue and need any help on the due diligence side of things, please reach out to Taylor Parsons or Shawn Shaw, PE. < Back Back

Site Under Construction Our new website is on it's way © Camelot Energy Group 2022 | All Rights Reserved | { Website design by Lore Design Co } Get In Touch First Name Last Name Email Message Sign Me Up Thanks for submitting!

Apr 20, 2026 The Container Problem in LFP Long-Duration Storage Will the LDES story for LFP be hamstrung by larger cells trying to sit in 20-foot containers? As we started to chart how cell form factors are evolving, there is an unmistakable artifact: the incremental change in usable system energy is not as much as it used to be, if these cells are to be housed in prototypical 20-foot ISO shipping containers For a typical 0.04 C use-case, we see that from 280 Ah to 314 Ah, the change in system energy is almost 45.80%; however, when we go from 1,175 Ah to 1,300 Ah, the change in system energy is only 10.40%. As OEMs push the limits from 314 Ah to 500 Ah+ form factors, they must also contend with real-estate constraints, especially because of how power and energy are coupled in Lithium-based systems. This tight coupling means cell geometry affects both thermal management footprint and C-rate flexibility. The energy density ceiling imposed by the container is increasingly the binding constraint, not the cell chemistry. We can see from the image below that, at 0.04 C, we're seeing only 287.50 kW per container at 1,300 Ah, assuming we can fit that in a 20-foot container for a typical 1,500 V architecture -looking ahead to 2,000 V architectures, the challenges compound further: higher bus voltages introduce insulation, switching, and safety certification hurdles that could slow adoption for LDES applications specifically. What's your take? Email us at hello@camelotenergygroup.com for any questions! Raafe Khan < Back Back

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

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

< Back Andrew Leslie Senior Project Engineer Andrew Leslie is a career Field Service Representative with over thirty years of customer service experience in the Power Utilities and Automotive sectors. As a member, lead-hand, or site supervisor of an installation and commissioning team, he was called upon regularly to provide support for the team’s EHS (Environment, Health & Safety) concerns. Project planning, coordination and execution are also areas of his expertise, along with civil construction of substations, duct banks and buried conduits required in Utility Hydro and EV Infrastructure projects. These projects typically included electrical and mechanical installation of switchgear, robots, and components, robotic programming, PLC coordination, and site support. As a Construction Supervisor, Lead-hand, and Team Member at Black and MacDonald, he primarily coordinated and executed Substation Maintenance and Construction projects for Toronto Hydro in the Downtown and Horseshoe substations, on Medium Voltage (5, 15, and 27.6 KV) installation and maintenance projects. His training in the Canadian Armed Forces has given him the ability to adapt to new challenges effectively and his experience as a Field Service Representative in the Power/Utilities and Automotive industries, Substation Construction and Maintenance, EV Infrastructure, BESS O&M, and HV Maintenance backs up his commitment to providing clients end-to-end Stellar Customer Service. andrew.leslie@camelotenergygroup.com

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

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

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

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

< 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

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