|
|
|
|
|
,
The bifurcation in this month's data is the cleanest signal of the year so far: 100% of newly identified queue positions with 2028+ CODs are in SPP, ERCOT, or MISO, while 82% of moratorium-county MW sits in NYISO and CAISO. New origination is voting with its filings. Treasury's Notice 2026-15 lands on top of that pattern, making cell sourcing the threshold compliance event for any project beginning construction this year. We also updated a NY ORES section on our site with the help of the Clean Energy Siting Team at NYSERDA.
MARKET BRIEF:
1. Treasury operationalizes FEOC for BESS. Notice 2026-15 (issued Feb 12) formalizes the Material Assistance Cost Ratio mechanics. IRS safe harbor tables assign 52% of total direct cost to battery cells in grid-scale configurations, meaning a single procurement decision now determines ITC eligibility for projects beginning construction in 2026.
2. Illinois CRGA signed, IPA's first 1,038 MW procurement closes August 26. The split is 450 MW in MISO LRZ 4 and 588 MW in PJM ComEd, on a 3,000 MW cumulative target by 2030. First major Midwest state-mandated BESS pipeline, and the developer field is not yet crowded.
3. Massachusetts EFSB consolidated permit takes effect July 1. Projects without a DPU comprehensive zoning exemption before that date are locked out of the legacy certificate route. They must choose the new 15-month state pathway or move into the local consolidated permit process.
4. Storage M&A is concentrating in late-stage assets. FlexGen acquired Clean Energy Services on April 7, the latest in a wave that put 11 BESS deals on the board in Q1 2026 alone (per FTI Consulting reporting). Capital is paying premiums for executed SGIAs and full site control rather than chasing early-stage pipeline. The "augmentation trade" is now a distinct M&A strategy: acquiring vintage solar assets to retrofit with BESS as a way around frozen interconnection.
5. Tariff stack on Chinese BESS equipment is now roughly 55% before AD/CVD. Section 301 increased to 25% on Jan 1, IEEPA layers 20% on top, China cancelled lithium battery export VAT rebates, and Trump set a separate 15% rate on grid equipment. This is a structural cost reset, not a fluctuation. |
|
|
|
|
|
ISO QUEUE INTELLIGENCE
Headline numbers (positions with COD in 2028 or later, plus positions filed without a COD):
-
55 newly identified queue positions totaling 12,353 MW
-
SPP 8,850 MW (39 positions), ERCOT 2,560 MW (12), MISO 943 MW (4)
-
Zero new positions in PJM, CAISO, NYISO, or ISO-NE
-
Colorado leads with 4,369 MW (23 positions), Texas 2,560 MW, Wyoming 1,479 MW
-
Zero new positions are in moratorium counties
-
Moratorium-county queue (filtered): 59 positions, 11,553 MW (NYISO 4,896 MW, CAISO 4,597 MW, PJM 1,640 MW)
A note on what "new" means: these are positions newly identified in our latest pull. Some may have been filed earlier and only just surfaced in our data. Of the 55 positions, 17 (3,483 MW) carry no posted COD.
The pattern is the story: new origination is going inland, contested MW is staying coastal. Every new position with a 2028+ COD is in SPP, ERCOT, or MISO. The contested backlog continues to age in NY and CA. Zero new positions are moratorium-flagged this pull, which is either a real concentration shift or a cross-reference timing artifact worth watching next month.
One concentration data point worth noting: four PJM positions at the Nelson 345 kV substation in Lee County, IL total 1,640 MW. Lee County is in PJM ComEd, the same zone Illinois IPA is procuring 588 MW from in August. One moratorium county holds nearly 3x the MW the IPA is procuring across all of ComEd.
Named developers concentrated in moratorium counties: Terra-Gen (750 MW, 6 positions), Key Capture Energy (610 MW, 5), Aypa Power (600 MW across 2 NY positions in Wyoming and Orange counties, both Dec 2029 COD), RWE Clean Energy (550 MW, 3), Origis (479 MW, 3). |
|
|
|
MORATORIUM UPDATES
119 active moratoriums across 11 states. New York accounts for 100 of them. The next-largest concentrations: California 4, Iowa 3, Washington 3, Indiana 2, Massachusetts 2. Of the 119 active, 115 are full moratoriums, 3 are outright bans, and 109 limit utility-scale only (10 are ALL_BESS scope).
Three new identified this month, all in New York:
-
Denmark, Lewis County: new 1-year moratorium effective Jan 21, 2026, 600 kWh threshold, utility-scale scope
-
Greig, Lewis County: new 1-year moratorium effective Jan 14, 2026, bundled scope covering commercial solar, BESS, wind, and Compressed Air Energy Storage in a single ordinance
-
Camillus, Onondaga County: new 1-year moratorium effective Mar 10, 2026, ALL_BESS scope (no utility-scale carve-out), sweeping language with no exceptions
Two patterns to flag. Lewis County now has three towns with active moratoriums (Denmark and Greig joined this month). And the Greig and Camillus ordinances both use bundled or sweeping language, matching the same packaging pattern Huntington County IN used earlier this quarter.
Cross-reference to Section 2: none of the three new moratoriums hit current queue positions (Lewis and Onondaga have no tracked queue MW in our database). They are pre-emptive, not reactive. But NY's broader picture continues to constrain 4,896 MW of NYISO queue MW across 35 positions.
A caveat that matters in NY: as covered in our Founder's Note above, ORES does not have jurisdiction over standalone BESS under current law. For NY standalone projects, an active moratorium is a binding constraint with no state-level workaround until pending legislation (S5506/A8378) advances.
The full tracker is updated: 119 active moratoriums across 11 states>> |
|
|
|
OEM WATCH
1. Tesla and LG Energy Solution: $4.3B LFP deal officially confirmed. US government confirmed in mid-March that Tesla is the previously-anonymous counterparty. LGES will produce prismatic LFP cells at its Lansing, MI plant (a former Ultium Cells site) starting around August 2027, dedicated to Megapack 3, on a contract running through July 2030. Largest disclosed US ESS cell supply deal on record. The FEOC reclassification trigger is plant commissioning, not contract signing, so current Megapack inventory may still rely on Chinese cells until 2027. (Based on publicly available information as of April 2026. Developers should conduct independent due diligence and consult tax counsel.)
2. Samsung SDI confirms US ESS production at StarPlus Energy in Indiana. A roughly $1B long-term ESS supply contract with a US energy company, deliveries 2026 through 2029. The plant is the Samsung SDI / Stellantis JV, originally built for EV batteries and partially converted to ESS lines. Both NCA and LFP cells. Second major Korean OEM after LGES with material US ESS production tied to a named buyer with deliveries already underway.
3. US ESS cell manufacturing has gone from essentially zero to 20 GWh in twelve months. A US Energy Storage Coalition report (cited in industry coverage in late March) projects roughly 95 GWh by early 2027 and claims domestic capacity is now sufficient to supply 100% of grid-scale demand. The Coalition is a self-interested source and the 100% claim likely refers to nameplate, not contracted-and-delivered capacity, but the trajectory is real. DOE separately issued a $500M NOFO on March 13 for domestic battery materials processing and manufacturing.
4. Tesla detailed Megapack 3 fire safety improvements at an EEI Loss Control meeting in late March. Expanded full-scale burn tests, gas-release characterization, controlled deflagration via sparkers and over-pressure vents. Tesla also reported completing root-cause analyses for prior incidents and is preparing fleet-wide incidents-per-GWh statistics. This is a posture update from the largest US BESS integrator, not a new incident, and aligns with the new NFPA 855 2026 edition's expanded large-scale fire testing requirements.
|
|
|
|
WHAT I'M WATCHING
1. FERC large load interconnection ruling: April 30 deadline. DOE directed FERC to take final action on the large load ANOPR by month-end. A favorable ruling would let co-located BESS at data center sites access expedited 60-day interconnection studies and could clarify net-basis transmission treatment. Binary outcome that materially expands or constrains the co-location market.
2. Michigan Court of Appeals hears PA 233 challenge: April 16. 70+ townships and 7 counties contest the MPSC's interpretation of "compatible renewable energy ordinance." A ruling that narrows MPSC authority effectively closes the state bypass pathway and reactivates dozens of township moratoria. Ruling expected within 90 days of the hearing.
3. PJM TC2 Phase II study results: June 1. Roughly 32 GW of remaining transition cycle capacity, including significant BESS. Attrition rate determines how much of PJM's 18 GW of queued storage actually advances to interconnection agreements. |
|
|
|
New to The Carina Dispatch? Subscribers also get The Carina Rules, in-depth BESS development guides at carina.energy/carina-rules/ |
|
|
|
|
|
The Carina Dispatch
BESS market intelligence from Carina Energy — moratorium tracking, queue insights, and development analysis delivered twice a month. Explore our moratorium data at carina.energy/bess-moratoriums or read more on The Carina Rules at carina.energy/carina-rules.
Share The Carina Dispatch → |
|
|
|
|
