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< Back Jacques Cantin, PE Senior Project Manager, PE 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

Nov 11, 2025 ERCOT RTC + B ERCOT’s transition from Operating Reserve Demand Curve (ORDC) scarcity pricing to the new RTC+B framework marks a fundamental shift in how batteries and other resources will earn value in Texas’ evolving ancillary services market. ERCOT’s ORDC scarcity pricing is being replaced with a more balanced, data-driven framework. TB-2 valuations have been trending over the last 6-9 months. The composite TB-2 is up by more than 20% (7-year term, Q1 2027 PIS) According to E3, after the passage of the Budget Reconciliation Bill, the phase out of tax credits for solar and wind result in lower deployments and a roughly $15/MWh increase in average annual energy prices from 2026 to 2035. RTC-B is going to be implemented by the end of the year by retiring ORDC scarcity adder. This means that asset owners must prepare for lower ancillary service revenues, higher arbitrage shared, and upside tied to scarcity frequency post implementation This also required four (4) new telemetry points: Frequency Responsive Capacity High Limit (HFRL in MW) High limit of the resources’ capacity that is frequency responsive Frequency Responsive Capacity Low Limit (LFRL in MW) Frequency Responsive Capacity Factor (FRQF) Maximum amount of total base point provided by the frequency responsive capacity of the resource Inactive Power Augmentation Capacity (PAUG in MW) Power augmentation capacity that is not on-line in HSL. This is used in SCED to determine the portion of the non-spin award that will be provided by power augmentation capacity that is not active and deployed as offline non-spin The new telemetry points are intended to inform Security Constraint Economic Dispatch (SCED) the Frequency Responsive Capacity of the resource to ensure that the Regulation and RRS-PFR awards are within the frequency responsive capacity. There are no frequency responsive capacity limitations when providing Non-Spin and ECRS The new demand curve will increase the ancillary service prices under scarcity conditions; however, we note that the scarcity adder will kick in first for RRS and ECRS before RegUp Currently, the onus is on the QSEs to ensure that Regulation and/or RRS-PFR are not coming from the steamer capacity and preserve sufficient headroom on GTs. ERCOT also enforces real-time and post-hoc compliance checks. The improved telemetry will eliminate this burden on QSEs and ERCOT. In practice, the optimization process ensures that resources are not incentivized by prices to deviate from their awards, i.e., a BESS will receive the same operating profit it would have received from the energy market, making it indifferent to the scheduling of its capacity for energy or ancillaries. For ERCOT Contingency Reserve Service (ECRS) it states that batteries can only qualify to provide a quantity that they can sustain for two consecutive hours. Essentially, a two-hour battery can qualify for up to 100% of its rated power as ECRS in any interval. However, a one-hour battery would only be eligible to provide up to 50% of its rated power as ECRS. However, this is changing…ECRS is transitioning from a 2-hour requirement to a 1-hour requirement. RRS and Regulation are being reduced from 1 hour to 30 minutes. Non-spin remains at 4 hours. Since most batteries in ERCOT are at least one hour in duration, the change in duration requirements for RRS and Regulation has minimal bearing on how much capacity is eligible to qualify to provide each of these services. However, the shift to a 1-hour requirement results in a 29% increase in eligible battery capacity for ECRS. This is because RTC+B shifts ECRS to a 1-hour requirement. A 100 MW / 120 MWh battery that was limited to 60 MW under the 2-hour rule can now offer its full 100 MW. It isn’t actually clear how revenues will be impacted as RTC procures ancillaries in real time. However, according to Modo Energy, using Day-Ahead prices as a proxy, batteries would earn about 14% less (or ~ $66 per MW less) under RTC+B on this high-priced day with this operational profile, assuming all RTC+B awards were made exclusively in the Real-Time Market. The reduced revenues reflect limits from SoC checks and the inability to capture extreme Non-Spin pricing. As ERCOT phases out ORDC scarcity pricing and implements RTC+B, asset owners and operators should expect a new balance of risks and opportunities—reduced reliance on scarcity adders, more precise telemetry requirements, evolving duration thresholds, and real-time procurement dynamics that reshape revenue profiles. While uncertainty remains around long-term impacts, it’s clear that operational flexibility, accurate dispatch data, and strategic bidding will play a larger role than ever in capturing value. Raafe Khan, Shawn Shaw < Back Back

Feb 17, 2026 Foreign Entity of Concern (FEOC) DEFINITIONS ▪ Under §48E, BESS is treated as an ‘Energy Storage Technology’ or EST ▪ An EST is defined (by reference to §48 (c) (6) as property that: o Receives, stores, and delivers energy for conversion to electricity o Has a nameplate capacity ≥ 5 kWh o Is not primarily used for transportation o Includes thermal energy storage properties ▪ BESS qualifies for §48E Clean Electricity Investment Tax Credits if: o It is placed in service after December 31, 2024 o Construction begins after statutory termination dates o It does not include material assistance from a Prohibited Foreign Entity (PFE) if construction begins after December 31, 2025 o Determination is based on supplier's tax year at time of cost payments MATERIAL ASSISTANCE COST RATIO For BESS, eligibility depends on definitions under §7701 (a) (52): o Total direct costs include direct material, direct labor costs of Manufactured Products (MPs) and components incorporated into the EST o PFE direct costs are the portion attributable to MPs or Manufactured Product Components (MPCs) that are mined, manufactured, and produced by a PFE o If MACR is below the applicable threshold, the EST includes material assistance from a PFE and is ineligible The threshold percentages are as follows: o 55% in 2026 o 60% in 2027 o 65% in 2028 o 70% in 2029 o 75% in 2030 and beyond TECHNICAL COST COMPONENTS For MACR, only MPs and MPCs are included, some examples are: Battery modules Battery packs Battery cells Inverters Power conversion systems Control systems Thermal management systems ▪ Steel and iron-based structural components are excluded from MACR unless identified as MPs or MPCs ▪ Main power transformers can be ignored ▪ However, it is important to note that asset owners must focus only on a discrete number of MPs and MPCs for MACR calculations Source: Solar Battery Manufacturer TRACKING METHODOLOGIES ▪ Notice 2026-15 establishes three tracking methodologies: o Individual component tracking, where each MP or MPCs tracked to specific BESS units o De-minimis assignment (10% rule), where each MP or MPCs representing < 10% of total direct costs may be assigned across facilities o Averaging for small BESS (<1 MWAC) Must be of same type < 1 MWAC Placed in service same taxable year Taxpayers may average direct costs and PFE production percentage. This is especially relevant for Distributed Generation (DG) BESS portfolios. Source : Solar Battery Manufacturer APPLICABLE SAFE HARBORS ▪ Two interim safe harbors apply as of the date of the notice: o Identified safe harbor - Use 2023-2025 Safe Harbor Tables (Notice 2025-08) to identify and qualify and quantify MPs/MPCs o Cost percentage safe harbor - Use assigned cost percentages instead of actual cost tracking (only if using identification safe harbor) ▪ It is important to note that safe harbor is: o Not allowed for incremental production rule projects o Excluding used property under 80/20 rule from MACR calculations ▪ Per Notice 2025-08, a grid-scale BESS is one with a nameplate capacity greater than 1 MWh, whereas distributed BESS shall have a nameplate capacity less than or equal to 1 MWh QUALIFIED INTERCONNECTION PROPERTY ▪ If BESS includes qualified interconnection property: o Separate MACR must be calculated o If interconnection property fails MACR, BESS ITC can still be claimed but interconnection costs are excluded from qualified investment ▪ Qualified interconnection property could include network upgrade costs paid to the interconnecting utility – the IRS has recommended separate MACR calculations for these network upgrades ▪ It is imperative to work in concert with the utilities to determine cost and sourcing of equipment to accurately quantify and qualify an interconnection specific MACR. THE RISK OF NOT BEING DILIGENT ▪ If MACR is overstated, then: o 20% accuracy penalty applies o 1% understatement threshold instead of 10% o 6-year statute of limitations of MACR- related deficiencies o Supplier misstatements subject to §6695B penalties ▪ That said, there is both economic and reputational risk of not being diligent about strategic sourcing ▪ The onus of traceability is solely on the developer's shoulders and goes beyond traditional checklists and CAPEX focused decision making. TECHNICAL IMPLICATIONS ▪ Supply chain strategy o Track origin of battery cells and modules carefully o Avoid PFE-produced battery cells unless MACR remains above threshold ▪ Portfolio structuring o Consider < 1 MW averaging rule for distributed projects o Use the safe harbor cost tables where advantageous ▪ Contracting o Ensure supplier certifications, but be diligent about reviewing these in detail due to potential penalties at play o Avoid licensing arrangements that could trigger ‘effective control’ by PFEs ▪ Financial modeling o Build MACR analysis into tax equity underwriting o Model threshold compliance by construction year FUTURE GUIDANCE ▪ The IRS is still working on FEOC, so the current notice is one of many expected in the coming months ▪ FEOC also bans tax credits from being claimed on any project or product over a Specified Foreign Entity (SFE) has been effective control by contract o Congress wrote into the statute 13 contract clauses that are leading signs of effective control to ensure non-circumvention o Granting the rights to use Intellectual Property (IP) belonging to an SFE, or modifying an existing contract, on or after July 4, 2025, is automatically considered to give the SFE effective control and as such automatic disqualification from a tax-credit perspective ▪ FEOC explicitly bars any company that is a PFE from claiming federal tax credits ▪ The IRS is seeking comments on the current notice up until March 30, 2026 Raafe Khan < Back Back

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

< Back Aaron King, PE Director of Programs & Policy 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

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

Mar 20, 2025 New Acquisition Opportunity in MISO At Camelot, we always try to keep a finger on the pulse of the solar and energy storage M&A market, as many of our clients turn to us for technical and market due diligence on these sorts of engagements. We just had a noteworthy M&A opportunity come across our desk from our friends at Enerdatics and wanted to share another new opportunity with our network. It’s for a portfolio of ten hybrid (Solar + BESS) projects and one standalone BESS in MISO, a region where many folks have had development and acquisition interests in projects of these kinds. This unique opportunity comprises ten hybrid projects and one standalone BESS totaling 327 MW of solar with co-located BESS + 200 MW of standalone BESS , available for sale in Illinois, Indiana, Wisconsin, and Michigan, USA. Projects are in mid-stage development. Eight of the eleven projects belong to the DPP 2022 cluster and have received their DPP1 Interconnection Cost Estimates from MISO. Initial development, including CIAs, Wetland Delineations, and Phase 1 ESAs, has been completed. The Projects benefit from long option periods of up to 10 years, providing significant flexibility in development. Geographic diversification across four states helps mitigate idiosyncratic market risks of development. Additional details are provided below. The seller is targeting to receive non-binding offers by March 28th, 2025 – please reach out now if you are interested! The seller’s preference is to transfer the ownership of the entire portfolio but is open to considering proposals for a subset of the portfolio in the interest of maximizing the value and number of projects that achieve commercial operation. Camelot Insights Camelot has recently performed diligence on several projects in MISO and we find that revenues can vary widely based on the system sizing and offtake strategy. Similar hybrid projects present a great opportunity and favorable economics in MISO; the ISO took the lead in 2024 with the highest total hybrid capacity in asset level M&A transactions compared to other ISOs/RTOs. In MISO, both Energy and Capacity account for a significant portion of the total revenue stack. Camelot recommends a thorough review of the revenue stack assumptions for the projects in this portfolio. Capacity Market: As MISO transitions to the Direct Loss of Load (DLOL) accreditation method for its capacity market, the accreditation for certain renewable resources is in flux and should be considered. The DLOL accreditation method evaluates the contributions of different resources primarily based on the availability of class-wide resources during a select set of high-risk hours. This method serves as a practical approximation of marginal Effective Load Carrying Capability (ELCC), potentially affecting how renewable and storage assets are valued within the capacity market. Energy Market : The energy market in MISO plays a crucial role in project economics due to its inherent nodal volatility. The variability in Locational Marginal Pricing (LMP) across nodes can present both risks and opportunities. Projects sited near congested nodes may experience significant price swings, which can create arbitrage opportunities for storage assets, allowing them to capitalize on price spreads. Given these factors, strategic site selection and an in-depth nodal analysis are recommended for maximizing returns in the MISO energy market. Costs & Technical Insights : Camelot also has recent data on CAPEX and OPEX applicable to the region and can perform a wholistic economic analysis of the projects to vet the seller’s assumptions. This, together with an evaluation of technology, designs, and key agreements, can help to refine your valuation and de-risk the technical aspects of the transaction. Please Reach Out Overall, this is an attractive opportunity in a very active market. If you are interested, we would be glad to put you in touch with the seller, and if you decide to pursue and need any help on the due diligence side of things, please reach out to Michelle Aguirre or Shawn Shaw, PE . Upcoming Webinar with Enerdatics Finally, stay tuned for an invite to an upcoming webinar which will be co-hosted by Camelot Energy Group and Enerdatics covering key trends in the US M&A market in 2024, including the growth of BESS and hybrid projects, and the uptick in activity in MISO. < Back Back

Sep 11, 2024 Solar Availability Series Part 4 Welcome back for Part 4 of Camelot’s series on solar availability. If you’re just joining us for the series, here are some links to parts 1 , 2 , and 3 . We’ve set the groundwork with a summary of the ongoing validation efforts from IEs, and the resulting changes the industry is making to their assumptions. We’ll revisit their reasoning here. We’ve also described how availabilities are calculated and reported, and touched on ways of maximizing availability by minimizing downtime. If you’ve followed along with the last few parts and you’ve been waiting for our own stance as an Independent Engineer (IE), look no further! Thank you for joining us. Re-Setting the Scene Until somewhat recently, the utility-scale solar 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 projects. Engineering judgement said that a relatively simple solar project would see the equivalent of about 3-5 days of total site outages per year, leading to expected availabilities of about 98.5% to 99.2%. For modeling simplicity, most everyone assumed a relatively consistent availability throughout a project’s lifetime. However, 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 with their average availability levels below what they had hoped. Over the last year we have started to see the beginnings of some robust data-backed approaches to redefining availability assumptions, aided by all the new operating data which is available to us. There have been three IEs who have recently updated their assumptions based on aggregated data from the projects they supported. 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. We’d like to highlight a few key findings from this comparison: Every IE relied on data from monthly operating reports produced by the operators, which are rarely independently calculated or verified. As described in part 2 of this series, there is no single, standard way that availabilities are defined or reported across the industry. The conclusions from these studies should be interpreted carefully, especially because the data QC processes have not been explicitly described. DNV’s analysis used more data and resulted in recommendations which are more clearly tailored to the sites. ICF found that fixed tilt systems showed lower availabilities than tracker systems while DNV found the opposite. 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. 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 practice, however, IEs are often reluctant to deviate from their standard assumptions, as this requires going out on a proverbial limb. While that conservatism is understandable, it may be producing unintended consequences. For instance, if an IE will not give “credit” for more robust technology choices or operating strategies, then owners have little incentive to consider any options but those that can be considered “bankable” at the lowest possible cost. This approach penalizes owners for considering better than baseline equipment, spending more on O&M, or otherwise looking for creative solutions to improve availability. The need for more data was a theme repeated by each company, and this will likely ring true for as long as we do this kind of work. Our availability assumptions will need to be updated regularly, just like we update our approaches to Energy Yield Analyses. Camelot’s Recommendations The Camelot team is compiling the data needed to supplement these studies and validate our conclusions, and we welcome the opportunity to work with industry partners on this effort. In the meantime, we base our own recommendations off the meta-study described above and in Part 1. Without further ado, here is our own take on availability projections: Until we have more information, we should not be differentiating between different mounting types . ICF’s and DNV’s observations contradicted each other. It’s likely other factors influenced the analyses, especially the sample sizes and quality of the input data. The factors which can impact downtime should be studied further, which means collecting more data, ensuring its accuracy, and capturing all potentially-relevant project details. In addition to mounting types, the difference between inverter technologies must be studied further as one of the primary sources of downtime observed at operating sites. For instance, the higher availability noted by DNV on smaller fixed-tilt sites than larger fixed-tilt sites may indicate a reliability advantage for string inverters over relatively small sites with central inverters. This would align with our general experience with operating sites but the data to positively confirm this is not yet available in sufficient quantity. The major sources of downtime should be studied and modeled separately . Using an overall system availability as a metric can muddy the waters significantly, especially when trying to tease out the impact of different design decisions on future performance. When performing energy yield analyses for wind energy projects, some IEs will include assumptions for balance of plant availability, grid availability, and turbine availability separately. Not only can this improve our validations (data allowing), but it will improve the way we assess technology tradeoffs at the design stage. Swapping out a more robust system for a less-robust one should impact only the downtime assumption for that system. Camelot recommends the industry work towards a bottom-up availability model based on historical failure/downtime data at the module, tracker, inverter, MV, HV, and BOS levels. These levels correspond with likely failure points within the system and provide a lowest common denominator that can be adjusted during project design to optimize expected availability. Ensuring this approach has buy-in from IEs will provide a financial incentive to specify better equipment and design better sites. Year-1 availability should be modeled separately from later years due to initial startup issues observed in each validation. Nearly all financial models are already set up to account for annually-varying losses, so adjusting our assumptions based on the clear signals we see from the data appears to be a no brainer. The industry should start modeling a ramp-down in availability later in projects’ life, as DNV may have alluded to, because component failure rates impact availability trends. Without more data, it is difficult to say the magnitude of the decreases because of the other factors at play. However, based on our experience modeling availability at other infrastructure projects, Camelot considers it reasonable to model availability as a ramp-down as a project nears the end of its design life. The “bathtub curve” shown below is an Engineering concept which supports this idea. It shows how infant mortality failures likely contributed to the observed availabilities in the first 6-12 months of operation, and highlights the further need for more operational data as projects age. This is applicable to individual components in many physical systems. Aggregated across an entire system and accounting for typical replacements and maintenance, one might expect to see a flatter availability curve, but with some consideration for early- and late-stage failures. We have seen this already with 10-15 year old PV sites, where owners struggle to obtain compatible replacement equipment that can be “dropped in” to replace original equipment onsite. As technology continues evolving quickly, we can expect new module types, inverter technologies, sensing devices, and code requirements to all play a role in the maintainability of PV sites in the late stages of their useful life. Camelot’s Balanced Approach The summary below provides a graphical representation of each IE’s default availability recommendations over time, and includes Camelot’s own recommended defaults (when no other project-specific information is available). We note the following: Camelot’s approach accounts for the size impacts observed by DNV, which appears to be a strong signal in the data, but does not differentiate between technologies until more information is made available supporting the distinction. Much like DNV, Camelot’s recommended availability starts slightly lower in year 1 before reaching steady operations, as is supported by all studies. We recommend modeling availability declines after year 20 based on several factors, including the bathtub curve concept described above, the typical useful life for major components, and our expectation that the impacts of mid-life failures will likely offset by the efficiencies gained from experience during operations. While we see this assumption as a necessary recognition of late-stage wear-out failures, it’s worth noting that its impacts on a financial model are muted by the time value of money. On average, Camelot’s assumptions are less pessimistic than ICF, and strike a balance between the assumptions reported by Natural Power and DNV. Camelot will consider quantitative adjustment to our base availability assumptions for sponsor efforts that materially result in increased reliability, such as: Demonstrating better than average historical availability for project- specific equipment (e.g., inverters) through operational data (as described in item 3 above) Adding incentives to O&M Agreements for increased availability, beyond simply guaranteed levels Purchasing extra spare parts for more vulnerable system components likely to need frequent replacing Investing in predictive analytics and above-market O&M services to reduce the frequency and severity of unplanned maintenance events While these recommendations may be Camelot’s “default” values, as an IE which cares heavily about the accuracy of our projections, we will always consider factors such as operator experience or the relative track record of the technologies deployed at each site. As the saying goes, “show us the data.” Before we close, it is important to underscore an important point. Recent reporting that indicates PV projects are falling short of expected availability is a call to action for all of us. It is a call to action for more data, better analysis, and a deeper understanding of what causes PV systems to underperform. It is, notably, not a call to action for unnuanced conservatism. Simply whacking a few points off availability is, in our view, insufficient to the task of ensuring a better-performing PV fleet and it creates blind spots. We hope our fellow IEs will join us in not simply erring on the side of conservatism but, rather, will continue to advance our knowledge of these issues and build better, and more nuanced models that reward innovation, investment, and effort. We hope you’ve found this series to be helpful, and we welcome the opportunity to partner with any of our readers who would be able to support with future efforts. Although this is the last of our solar availability series for now, we fully intend to revisit the topic in the future. For our storage-oriented audience, you can expect a similar discussion on availability assumptions for BESS technologies in upcoming articles. About Camelot Energy Group is a technical and strategic advisor to owners and investors in clean energy and energy storage projects, programs, and infrastructure. Guided by our core values of courage, empathy, integrity, and service we seek to support the energy needs of a just, sustainable, and equitable future. Our team has experience in supporting 7+GW of solar PV and 10+ GWh of energy storage and offers expertise in technology, codes and standards, engineering, public programs, project finance, installation methods, quality assurance, safety, contract negotiation, and related topics. Our services are tailored to a providing a different kind of consulting experience that emphasizes the humanity of our clients and team members, resulting in a high quality bespoke service, delivered with focus, attention, and purpose. Key services include: -Technical due diligence of projects and technologies -Owner’s representative and engineer support -Strategic planning -Training and coaching -Codes and standards consulting -Contract negotiation and support. < Back Back

Mar 14, 2025 New Acquisition Opportunity in ISO-NE 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 a portfolio of three hybrid (Solar + BESS) project in ISO-NE, a region where many folks have had development and acquisition interests in the MA SMART + Clean peak programs. A few details to highlight: This portfolio comprises three hybrid projects totaling 15 MW of solar + 6.72 MW of BESS , available for sale in Massachusetts, USA . Each project is for sale at the Notice to Proceed (NTP) stage, with land, permits, and interconnection already secured . The projects are expected to achieve Commercial Operation Date (COD) between Q3 and Q4 of 2026 . They participate in the MA SMART and Clean Peak programs , with potential eligibility under MA SMART 3.0 . The projects qualify for the 30% federal Investment Tax Credit (ITC) and offer strong revenue potential through offtake strategies and ancillary services in ISO-NE . Offers are welcome for the entire portfolio or individual projects , with transaction closing anticipated in Q2 2025 . Camelot has recently performed diligence on, and supported the development of, several projects in MA SMART + Clean Peak Programs and we find that revenues can vary widely based on the revenue stack, BESS system sizing, and offtake strategy. Similar hybrid projects present a great opportunity and favorable economics, especially with the significant adjustments made to the adders proposed in the Massachusetts Department of Energy Resources (MA DOER) straw proposal. This is in addition to the changes made to the Alternative Compliance Payment (ACP) rate, where 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 until 2050. 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 a good opportunity in an active market. If you are new to the MA SMART + Clean Peak Programs, we encourage you to to check out our relevant articles: Massachusetts SMART and Clean Peak Overview MA SMART Part 2: Key Financial Implications for Hybrid Systems 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 . The Enerdatics team will also be at #Infocast2025 next week and will have other exclusive deals and insights to share. Be sure to reach out to Mohit Kaul or Kshitij N R to connect! < Back Back

< 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

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< Back Bill Atkinson, CEM Senior Project Engineer Bill is a Senior Engineer with over 17 years of experience in the renewable energy and energy storage industry. During that time, Bill has worked extensively developing and implementing rigorous quality assurance and inspection processes for clean energy incentive programs and Bill has inspected more than 530MW of PV and energy storage systems. Bill has performed hundreds of design reviews, technology evaluations, major agreement reviews, and site assessments. Bill is a Certified Energy Manager, Certified PV System Inspector, and holds a B.S. in Community and Regional Planning and Sustainable Technology from Appalachian State University. bill.atkinson@camelotenergygroup.com