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Thirty-two ISO queue positions in moratorium counties hit COD in the next 24 months, 6,335 MW total. That's the cohort with binary outcomes coming. Watch which developers move first. This is The Carina Dispatch, May 2026 edition.
Below: five sections of tactical intelligence drawn from the month's market data, ISO queue activity, moratorium tracker, and OEM supply-chain scans. |
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MARKET INTELLIGENCE:
1. Industry analysis now puts roughly 83% of the 219 GW US storage pipeline at risk of losing tax credits without documented FEOC compliance. Here's a refresher: The Material Assistance Cost Ratio (effective July 4, 2025) requires 55% non-PFE equipment costs for 2026 construction starts, putting $80 to $120 million in tax equity at risk on a typical 200 MW / 800 MWh project.
2. PJM reopened its interconnection queue April 27 and received 811 projects totaling 220 GW, including 67 GW of storage. Illinois separately enacted a 3 GW utility-scale storage mandate by 2030, the most aggressive Midwest mandate to date. PJM had received zero new intake since 2022.
3. MISO 2026/27 capacity auction cleared at $116 to $126/MW-day, down 42% from $217 the prior year. A 4-hour battery in MISO North/Central now earns $44/kW-year in capacity, with summer hours accounting for 85% of annualized BESS capacity revenue versus 38% in 2024/25. Duration beyond 4 hours adds no incremental capacity value.
4. Fairfax County, VA's BESS zoning amendment took effect March 18, 2026, classifying large-scale BESS (greater than 600 kWh) as "light utility facilities" requiring special exception approval. Requirements include a 100-foot minimum setback from all lot lines (200-foot from residential or abutting residential districts), NFPA 855 and UL 9540A compliance, fire marshal pre-approval of an emergency operations plan before building permit issuance, and a decommissioning bond recalculated every five years. The framework is a likely template for other Northern Virginia jurisdictions.
5. Fluence Energy signed master supply agreements with two major hyperscalers. First confirmed direct OEM-to-hyperscaler BESS supply commitments, moving the data-center-co-located thesis from press releases to firm purchase orders. |
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ISO QUEUE INTELLIGENCE
6 new ISO queue positions were identified in this month's pull, 987 MW total (4 Active / 645 MW, 2 Withdrawn / 342 MW). ISO split: MISO 2 positions / 400 MW, SPP 4 / 587 MW. Zero new PJM, CAISO, ERCOT, NYISO, or ISO-NE positions, despite PJM's April 27 intake (the 67 GW figure in the previous section is "application" volume, not validated queue).
96 active ISO queue positions sit in moratorium counties, 19,538 MW total. 32 of those positions, 6,335 MW, have CODs in 2026 or 2027. This does not account for projects sitting in distribution-level queues.
The near-term cohort concentrates in NYISO (Long Island and Hudson Valley) and CAISO (San Diego, Ventura, Orange). Named developers with multiple 2026-2027 maturities in moratorium counties include Hanwha Corporation (three NY positions of 200 MW each, all COD 12/1/2027, across Steuben, Dutchess, and Chemung), Caithness Energy (three Suffolk positions), Key Capture Energy (two Suffolk positions), Arevon (Orange and San Diego), Grid Connected Infrastructure (Monroe and Chautauqua), and NextEra Energy Resources (Suffolk). The closest-in maturities: Avantus 500 MW in Ventura with COD 3/31/2026, Arevon 300 MW in San Diego with COD 3/1/2026, AES Clean Energy 70 MW in San Diego with COD 3/6/2026.
Each of these projects will either clear local issues, pivot to a state-pathway filing (New York ORES Section 94-c covers projects >25 MW; California's AB 205 covers projects ≥200 MWh), wait out the moratorium timer, or withdraw. |
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MORATORIUM UPDATES
125 active moratoriums tracked across 11 states. New York remains 83% of the active total at 104 records.
Three new New York town-level moratoriums added in April:
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Town of Northampton (Fulton County), effective 3/30/2026 for one year, scope covers all BESS.
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Town of Schroeppel (Oswego County), effective 4/14/2026, scope limited to solar-plus-storage (source data shows expiration matching the effective date, likely an entry error pending confirmation).
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Town of Carlisle (Schoharie County), effective 4/21/2026 for six months, scope covers utility-scale projects.
None overlap with currently tracked queue positions.
A fourth record was added this month: Town of Oakham (Worcester County, MA), a full BAN on standalone BESS (AG-approved January 2023). This is a 2022 ordinance newly captured in tracking, not fresh action.
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OEM & FEOC WATCH
1. Canadian Solar e-STORAGE: 500 MW / 2,493 MWh US BESS supply for data center load. Agreement with an unnamed major US utility, approximately 500 SolBank 3.0 containers, shipments March to July 2027. One of the largest single BESS contracts in the US pipeline. FEOC posture for SolBank 3.0 is not assured at the product level; buyers should require documented cell sourcing and conduct independent due diligence. (Carina's FEOC classifications are assessments based on publicly available information as of May 17, 2026, not legal determinations. Consult tax counsel.)
2. Tesla–LGES Lansing LFP supply confirmed; Megapack 3 production ramping at Brookshire, TX. The US government publicly confirmed Tesla as the buyer in the $4.3 billion LG Energy Solution LFP supply deal. LGES will produce prismatic LFP cells at its Lansing, Michigan facility starting 2027 for Megapack 3 production at the Brookshire factory, which is ramping toward late-2026 startup with a 50 GWh annual target. Tesla's product-level FEOC classification remains assessed pending operational US cell flow; the compliant supply runway begins in 2027, not before.
3. ISO 3941:2026 introduces a dedicated "Class L" fire classification for lithium-ion batteries, explicitly covering grid-scale BESS. Combined with NFPA 855:2026 and frameworks like Fairfax County's, the codified safety stack now drives expectations for validated propagation testing, gas-behavior analysis, and engineered thermal management. EVE Energy and Hithium both completed full-scale fire certifications during April. |
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WHAT WE'RE WATCHING
FERC large-load interconnection rulemaking (Docket RM26-4-000), final order expected end of June 2026. The order will shape co-location rules for data center plus BESS, cost allocation for large-load interconnection, and federal-versus-state jurisdictional boundaries.
China's export VAT refund on batteries drops to 0% in December 2026. Adds roughly 6% cumulative cost on top of the 15-17% increases already in motion. Projects with 2027 construction starts that haven't yet contracted equipment face a hard procurement cliff.
Moss Landing Phase 2 demolition begins mid-2026 under EPA oversight, with Vistra bearing full cleanup costs. Singleton Schreiber represents approximately 1,000 plaintiffs in pending litigation. Discovery findings will shape AHJ interpretation of NFPA 855:2026 and BESS insurance underwriting industry-wide.
Get these updates on LinkedIn
Carina Dispatch is the monthly read. Our LinkedIn page is where our team posts updates as they happen, including the developments that don't make it into the newsletter. If you want a closer view of the BESS market between issues, follow Carina Energy on LinkedIn. |
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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.
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