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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

< Back Bill Coon Head of Construction Bill is Camelot’s Head of Construction and oversees all aspects of solar and storage construction and installation quality. This work includes construction monitoring, field supervision, and QA inspection of clean energy construction projects. Bill has over 20 years in the construction field and prior to joining Camelot oversaw QA and safety for a solar construction company and spent time as a construction project manager, solar inspector, and engineer. Bill has a Bachelor’s Degree in Mechanical Engineering from Syracuse University. Bill also holds Installer, Inspector, Commissioning, and Maintenance certifications from the North American Board of Certified Energy Professionals (NABCEP) and is a licensed electrician. bill.coon@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

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. Bespoke technical and strategic advisory for a better world About Us Our mission is to power a just, equitable, and sustainable society with clean energy . Our team of industry experts supports asset owners, investors, public agencies, and others through owner’s engineering, technical due diligence, and strategic advisory services. LEARN MORE WHO WE ARE OUR SERVICES LATEST ARTICLES CAMELOT PHOTO GALLERY

< 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

< Back Aaron King, PE Senior Project Engineer Aaron is a Senior Project Engineer at Camelot Energy Group and has over 10 years of experience in the solar and storage industry. Aaron works across Camelot’s Technical Advisory and Owner’s Engineering departments supporting clients on a wide variety of services. He has acted as a project manager and technical lead on different projects and portfolios at all different stages of development from M&A due diligence, design and permitting, construction monitoring, site inspections, testing & commission, and asset management. Aaron started his career designing commercial rooftop systems and solar canopies. Aaron has also worked as a technical PV consultant and owner's engineer with a range of different clients including utilities, property management companies, EPCs, municipalities, state governments, and large universities. Aaron is a licensed Professional Electrical Engineer (Power) in the state of Massachusetts and holds a M.S. in Energy Systems Engineering from Northeastern University and a B.S. in Mechanical Engineering from Johns Hopkins University. aaron.king@camelotenergygroup.com

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

OUR MISSION To power a just and sustainable society with clean energy Getting to this point will require substantial investment in solar, energy storage, and other clean energy technologies, with such investment coming not only from banks and investment funds but communities, corporations, and governments. Building the energy systems of tomorrow offers a chance to rethink energy systems, infrastructure, ownership, and equity. Enabling the investment required to scale clean energy is about people. Investors in the clean energy future have very human questions, concerns, and anxiety as they step into unknown technologies, financing mechanisms, commercial agreements, and other challenges. These people, whether experienced investors or community leaders new to energy topics, deserve respect, expertise, empathy, and service as they bravely step into the future. At Camelot Energy Group , to these brave owners, investors, and visionaries putting their resources into the clean energy future, we say: “We’ve got your backs”. Camelot was founded to accelerate investment in the clean energy infrastructure of the future but also to embrace the human aspects of this transition. By taking the time to listen to our clients, staff, and partners and give each the focus and attention they deserve, we set ourselves apart from other consultancies that focus on sales, overly standardized services, and lackluster support provided by overworked and distracted teams. We believe that by treating our team and clients with respect, dignity, and empathy we provide the best possible advisory services and solve real-world challenges. OUR CORE VALUES Integrity, empathy, courage, and service > Back

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

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

< Back Raafe Khan Head of Energy Storage Raafe is Camelot's Head of Energy Storage at Camelot Energy Group. He brings a great depth of knowledge across the energy storage project lifecycle having held tactical and leadership positions at TATA Power (public utility), Mortenson Construction (EPC), Sunnova Energy Corporation (finance + asset management), Pine Gate Renewables (project development), and Visteon Corporation (product development). His interdisciplinary approach has resulted in over 5 GW of operating projects (wind + solar + storage) and over 25 GWh (storage) across the United States. He is a recipient of several national and international awards, including being a Forbes Under 30 honoree in the field of energy. An ardent advocate for energy access and equity, he is an accredited lecturer for the Battery MBA program and devotes his time to educating stakeholders in the energy storage space about technical and commercial challenges from the cell to a fully functional container system. Raafe has a Bachelor's in Electrical & Electronics Engineering degree from Manipal University and a Master's in Energy Science, Technology & Public Policy from Carnegie Mellon University. raafe.khan@camelotenergygroup.com