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Dec 4, 2025 CAISO Market Operations CAISO Market Refresh CAISO is the second largest renewable energy market by deployment, just marginally behind TX, however, operating in CAISO isn’t trivial – the market works in a few layers, and all required capacity is procured in the DA market However, two additional balancing markets run throughout the day – the Integrated Forward Market (IFM) and the Fifteen Minute Market (FMM) Source: CAISO OASIS Data Integrated Forward Market (IFM): Bidding starts in the IFM the morning before the day starts and all operators submit bids for DA and AS for each operating hour. However, BESS with Resource Adequacy (RA) contracts are required to make bids for every hour Fifteen Minute Market (FMM): Once the day begins, FMM gets to work. Operators must submit bids 75 minutes prior to each operating hour. This is also referred to as the 75-minute lockout period FMM capacity is cleared in 15-minute increments Real-Time Dispatch (RTD): RTD works in 5-minute intervals and CAISO uses this to address sudden system wide issues like outages, demand spikes, etc. FMM awards can be adjusted in both directions in RT, and this can cause uncertainty about the immediate operating hours. It is important to note that assets with firm AS obligations must have 60-minutes of SoC in the IFM and 30-minutes of SoC in the RTM to deliver and avoid penalties. Key Market Mechanisms & Initiatives Extended Day-Ahead Market (EDAM): This is a major ongoing initiative to expand the real-time WEIM into a day-ahead market. Status: The EDAM is scheduled to launch in May 2026, with PacifiCorp and Portland General Electric as initial participants. Stakeholder workshops are ongoing to finalize tariff clarifications and implementation details. Source: U.S Energy Information Administration Flexible Ramping Product (FRP): This market mechanism is designed to manage the significant net load variability caused by high solar and wind integration. Function: It procures capacity to handle forecasted movement and uncertainty in net load (total load minus solar/wind generation) in the real-time market. Performance & Challenges: The CAISO net load can swing more than 20 GW in a single hour. While beneficial for grid stability, the FRP rarely presents consistent, high-value revenue opportunities for most battery energy storage systems (BESS) as prices are often zero due to sufficient available capacity. The Department of Market Monitoring has previously identified implementation errors in the product's demand curve calculations that resulted in under-procurement of upward capacity during critical ramps. FRP addresses real-time variability across the Western grid, with CAISO facing some of the steepest ramps Source: U.S EIA SP15 hosts nearly 75% of CAISO’s battery storage, reflecting where solar growth and ramping needs are most concentrated. This regional buildout plays a major role in shaping real-time flexibility and FRP activity across the grid. As storage scales further, SP15 increasingly influences CAISO’s price formation and operational dynamics. Source: CPUC Master Resource Database Ancillary service prices in SP15 have declined sharply as battery storage has scaled across CAISO. With increased competition, services like RegUp, Spin, and Non-Spin offer far less revenue than previous years. This shift pushes storage operators to rely more on energy arbitrage and real-time market opportunities. Source: CAISO OASIS Data With ancillary service prices declining, energy arbitrage now makes up the largest share of CAISO BESS revenue. Growing solar-driven volatility has increased DA–RT spreads, making arbitrage more valuable. As a result, storage operators rely more on price forecasting and real-time optimization to capture returns. Source: CAISO Special Data TB4 opportunities come from predictable daily price swings in CAISO, where low midday prices encourage charging and high evening prices reward discharging. This spreads-based strategy is a major revenue driver for batteries under tolling agreements. Capturing these spreads consistently requires strong forecasting, SOC planning, and real-time optimization. Source: CAISO OASIS Data California utilities and CCAs are rapidly increasing their TB4-settled procurement, growing from under 2 GW in 2023 to over 3.5 GW by 2025. TB4 contracts shift real-time operational risk from offtakers to independent power producers (IPPs). This structure gives utilities financial certainty while requiring storage operators to manage price volatility and dispatch performance. The growing adoption of TB4 highlights the market’s move toward financially settled performance-driven contracting for BESS. Source: CPUC Fillings Raafe Khan < Back Back

< 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

Mar 27, 2026 From lab to grid: making LDES bankable The grid already faces multi-hour and multi-day imbalances caused by transmission constraints, renewable intermittency, and extreme weather volatility. The rapid addition of data centers further complicates this situation, adding peak load to an already stressed grid. As the traditional 2-4 hour storage market tightens, and large-AI-based loads demand a higher degree of reliability and redundancy, long-duration energy storage (LDES) is gaining serious attention from developers, Independent Power Producers (IPPs), utilities, and investors. LDES matters now more than ever because: Renewable penetration is accelerating , leading to increased curtailment. Industrial electrification is increasing baseload demand , adding stress to transmission and distribution systems. Peak load is growing , leading to overbuilding of generation. Extreme weather is stressing grids globally , increasing the need for flexibility. Contrary to popular belief, LDES is not a future solution. The technologies exist today, but have yet to be successfully field-tested in long-term projects. When deploying LDES at scale, the deciding factors will be cost, performance, and commercial viability, which will all determine the market’s true winners and losers. The chemistry war: A distraction from the real issue Energy storage professionals have debated which chemistry or brand name is ideal for long-duration applications. This debate, while lively, is besides the point. Industry efforts should focus on technology-agnostic procurement – picking the technology that fits the use case. While most markets still anchor to the 4-hour lithium-ion benchmark, reflecting yesterday’s grid needs, intraday needs exceed 4 hours, and multi-day reliability events are increasing. Lithium currently wins on performance and experience, with ~90% round-trip efficiency, a mature bankability profile, and proven deployment at scale. However, lithium performs best for 4-hour use cases (or less) and 15-20 year technical life expectations. If efficiency, upfront capital outlay, and energy density are critical to the project, lithium-ion typically wins. But when fire safety, total cost of ownership, a fully or primarily domestic supply chain, or >8-hour discharge needs dominate, a non-lithium technology may be superior. “The longer the better” is the right answer for most LDES projects, but each deployment will have varying problems and solutions. Longer doesn’t just mean longer discharge duration, but also a longer calendar life. Duration should be defined by system need, not by lithium’s historical average, and the right chemistry cocktail should be tailored not to industry standard but to individual use cases. Scaling too fast will break things Despite record installation numbers, the long-term degradation performance of utility-scale storage remains uncertain. Most assets are underwritten on lab-based, accelerated testing, so we truly don’t understand how these systems are expected to perform between years 10 and 20 of their operating lives. The utility-scale storage industry is little more than a decade old, and no battery fleet has reached end-of-life. At this stage, decommissioning frameworks remain theoretical rather than concrete. Commissioning engineers and project managers currently rely on performance metrics documented by accelerated lab testing instead of real-world use cases and stressors. Furthermore, few asset owners of deployed projects possess true fleet-level transparency regarding battery health and key dispatch metrics. Taken together, these factors make project failure – or faster-than-promised degradation – highly likely. Depending on the project structure, some teams will catch and fix these issues over time. However, many won’t have a fix available to them due to the rapid evolution of cell form factors and subsystem hardware and software architecture. With storage remaining untested in long-term, real-world projects, industry skepticism remains a hurdle. Overcoming this will require LDES demonstrating real-world degradation performance, ease of integration, enhanced safety, lower lifecycle costs, and reliability comparable to lithium. Long-term financial viability also matters. Buyers need confidence that the supplier will be around for multiple decades to provide technical support, spare parts, and warranty response. We also need to ensure that we close the gap between economic forecasts and operational realities, and how risk is underwritten. Hopefully, with deployment and manufacturing scale, the economics will follow, making LDES the right choice for energy generation projects and facilities. Policy frameworks shape LDES deployment now, but they remain far behind Historically, ancillary service markets have been the early proving ground for energy storage around the world. Because these products reward fast response over short time windows—typically minutes to about an hour—short-duration batteries had a built-in advantage: they could follow rapid control signals and deliver frequent, shallow charge-and-discharge cycles that align well with today’s battery performance. But as growing renewable generation pushes fossil “thermal” plants further down the dispatch order and into a more backup role, the grid increasingly needs LDES to do what fast services can’t: capture excess clean energy that would otherwise be curtailed, provide resilience and flexibility during longer imbalances, and help keep the lowest-cost electricity available when it’s needed. That said, the current ancillary service market designs reward speed, not endurance. If fundamental price signals evolve to incentivize lower-cost, longer-duration assets that perform at a high reliability standard, the market will rise to the challenge. LDES needs clear market incentives. Those signals may show up over time, but capacity markets could help make long-term projects financeable now. The recent federal policy changes promoting domestic manufacturing now reshape the equation. Lithium-ion supply chains remain heavily dependent on both mining and processing outside the U.S.. With new FEOC guidance under the OBBB and tariff policy implementation, any critical mineral material that can be found domestically gains a huge homefield advantage in cost and tax credit eligibility. Many lithium alternatives in LDES, such as zinc and sodium, draw on U.S. deposits. While gaining traction, these technologies remain untested at a mass scale and still lack the affordability and performance of lithium-ion. Policy levers can accelerate innovation and encourage market adoption, and policymakers have many in the works. LDES provides essential infrastructure. As the grid incorporates more renewable energy sources and retires older fossil fuel facilities, only massive deployment and integration of LDES can guarantee grid reliability. The technology exists; companies are building it, and deployments are happening. Yet cost competitiveness, efficiency gaps, and operability at commercial scale remain real barriers. Companies that can combine cost discipline, bankability, and execution excellence will define the next era of grid infrastructure, and we need it sooner rather than later. As featured in ESS News. What's your take? Email us at hello@camelotenergygroup.com for any questions! Raafe Khan < Back Back

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

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

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

< Back 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

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

May 6, 2026 Field Failures Field Failure #1 : Improper Conductor Torque Ensuring safety and reliability in PV electrical systems starts with attention to detail - here’s a stark reminder of what can happen when conductor terminations are not properly torqued The visible damage to this electrical panel serves as a powerful illustration of how incorrect torque can lead to overheating, equipment failure, or even fire hazards Not to mention any catastrophic failure could potentially propagate and impact other physically and or electrically adjacent equipment Always double-check your connections for the correct torque specifications to maintain system integrity and prevent costly downtime and cost overruns. Field Failure #2 : Improper SWPP Measurers Improper stormwater pollution prevention plan (SWPPP) measures can lead to significant erosion and sediment accumulation, as seen in the image. This not only damages our construction sites and surrounding properties but also poses a risk of substantial fines from the Department of Environmental Protection. Let’s commit to effective erosion control and protect our environment. Proper SWPPP measures are crucial for maintaining site integrity and avoiding costly penalties. Field Failure #3 : Proper Direct Burial Conductor Bedding Proper installation practices are essential for the safety and efficiency of PV electrical systems. Improper bedding of direct burial conductors can lead to significant issues, including system failures, safety hazards, and costly repairs. When conductors are improperly bedded, as in this case, where construction debris was left in the trench with the direct burial conductors causing abrasion and ultimately leading to complete conductor failure. Camelot Energy Group plays a critical role in preventing these problems by overseeing the installation process, ensuring that proper QA/QC process is followed, and adherence to industry standards and best practices. William Coon < Back Back

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

Dec 2, 2025 SMART 3.0 - PY 26 Update The Massachusetts Department of Energy Resources (MA DOER) released their final form for the 2026 Program Year. Here’s what you need to know: The DOER began accepting SMART 3.0 applications on October 15, 2025, and since then, 191.90 MW has been submitted, with 301 applications > 25 kW and 86 applications < 25 kW Based on several factors, from the One Big Beautiful Bill Act (OBBBA) of 2025, to equipment supply chain issues, and projected load growth, the DOER revised the following elements of the draft report: PY26 Base Compensation Rates PY26 Energy Storage Multiplier PY26 Annual Capacity Block PY26 Capacity Allocations and Set Asides Capacity Block: PY2026 will have a 600 MW AC of available capacity for STGU subject to the annual cap. This is an increase from the 450 MW AC capacity in the initial draft. Per 225 CMR 28.05 (4), each EDC will be allocated at least 5% of the available capacity block and the remaining capacity will be allocated to the total retail electric load served to Massachusetts customers by each EDC. The distribution capacity for PY2026 was based on March 2026 retail electric load of each EDC. The allocations shall be as follows: Source: Camelot Energy Group 225 CMR 28.05 (5), a minimum amount of capacity is set aside for the following categories: Standalone STGUs > 25 kW and ≤ 250 kW STGUs > 250 and ≤ 500 kW Low Income Property STGUs And Community Shared Solar STGUs These set asides are allocated accordingly: Source: Camelot Energy Group Base Compensation Rates: Base Compensation Rates for STGUs > 25 kW AC were based on the levelized revenue requirements for each project based on the following inputs: Capacity factor Production degradation Installation costs Financing costs Operation and maintenance costs Project management costs Land lease costs Incremental operating and capital expense costs Based on public feedback, and an attempt to balance analysis results with the desire to avoid a significant shift in the MA solar market in the first full year of SMART 3.0 Base Compensation Rates were revised as follows: PY2026 Adders The Compensation Rate Adders for STGUs >25 kW AC were developed by comparing the average levelized cost of energy of all project types >25 kW AC for each respective adder category to a baseline value. Based on the Program Year 2026 analysis, DOER found that there was variation in whether Compensation Rate Adders for Program Year 2026 should be reduced, kept the same, or increased (see “Calculated PY26 Adder Rate” below). As with the Base Compensation Rates, based on the overall Annual SMART Program Assessment, DOER decided to maintain or increase the value of Compensation Rate Adders (see “PY26 Adder Rate” below). That said, the Compensation Rate Adders for PY2026 will be as follows: In conclusion, it is clear that federal policy and broad-based challenges in the energy value chain prompted some changes. We find that rates have mostly increased or stayed the same relative to the initial draft proposal. We see that the DOER is sending a price signal that energy storage and solar are going to be key tools in achieving state mandated energy affordability and climate-based goals. One thing is clear; Massachusetts is setting a strong example of how to fairly incentivize public and private investment in energy infrastructure with the goal of making energy affordable across customer archetypes in the Commonwealth. Raafe Khan < Back Back

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