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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. GET IN TOUCH Contact Us Boston, Massachusetts hello@camelotenergygroup.com First Name Last Name Email Phone Leave us a message... Submit Thanks for submitting!

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

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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

< Back Michelle Aguirre Project Manager Michelle Aguirre is a Project Manager with over 4 years of experience in managing engineering projects. Michelle has expertise in electrical safety, quality assurance, technical report writing, and project management. Michelle has supported with Technical Advisory, Owner’s Engineering, and Supply Chain services on commercial to utility-scale PV and BESS projects with construction monitoring, technology reviews, and managing the quality assurance and traceability of major equipment. Prior to joining Camelot, Michelle was a Product Safety Engineer at TUV SUD. Michelle is a registered Engineer-in-Training in the state of California and holds a B.S. in Environmental Engineering from the University of California-San Diego. She is actively pursuing the NABCEP PV Installation Professional certification. michelle.aguirre@camelotenergygroup.com

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

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

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

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

Oct 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

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