|
|
|
|
|
,
Every one of the 35 new queue positions that we've identified over the last two months landed outside a moratorium county, and SPP took 23 of them. Not what I expected walking into the data, but it looks like origination teams are voting with their applications. This edition covers July and August since last month's Dispatch didn't ship, so the Moratorium, Queue and OEM updates are doing double duty this month. |
|
|
|
MARKET INTELLIGENCE:
NFPA 855 gets its 2026 refresh, and it's a real one. Hazard Mitigation Analysis is now the default for utility-scale BESS, NFPA 68 deflagration venting is out in favor of mandatory NFPA 69 explosion control, and large-scale fire testing joins UL 9540A. If a project in pre-construction was banking on venting, that design needs another look.
Section 301 forced-labor tariffs replaced the Section 122 baseline on July 24. Combined China-origin tariffs on lithium batteries now stack to roughly 41% and Chinese solar panels to roughly 63%. Korean and Japanese OEMs move from a flat 10% baseline to a 12.5% ceiling (net of MFN); EU OEMs stay at a 10% ceiling. Small on paper for non-China origins, but the era of a stable 10% flat baseline is over.
PJM's 2028/2029 capacity auction cleared at the $325/MW-day cap for a third straight cycle. Secured 138,318 MW, still around 6,831 MW short of the reliability target. Without the FERC-imposed collar, constrained zones would have cleared somewhere between $555 and $777. Storage cleared under 1% of PJM capacity last cycle, which is the number worth remembering.
Brookfield is buying Aypa Power from Blackstone for roughly $7B. One of the largest storage-platform deals on record. Aypa's roughly 200-person dev team and North American BESS portfolio move into Brookfield's renewables business.
AES walked away from Jewelflower on August 4. The 40-acre, 312-container project in San Jose's Coyote Valley had permits and a CEQA lawsuit threat waiting for it. Community opposition killed a fully permitted project. That's the story here, not fire code. |
|
|
|
ISO QUEUE UPDATES:
We've identified 6,641 MW across 35 new queue positions since June:
-
ERCOT led on MW: 3,357 MW across 11 positions
-
SPP led on count: 3,134 MW across 23 positions (66% of filings)
-
MISO: 150 MW, 1 position
-
CAISO, PJM, NYISO, ISO-NE: nothing this pull
-
State leaders: Texas 3,357 MW, Kansas 1,269 MW, Oklahoma 778 MW
Zero of the 35 landed in a moratorium county. But 20,927 MW of BESS still sits in queue positions inside moratorium jurisdictions across seven states: NY 6,894 MW, CA 6,267 MW, IL 5,950 MW, MA 1,156 MW, MI 360 MW, IN 200 MW, IA 100 MW. Suffolk County NY carries the most single-county exposure at 1,576 MW across 17 positions. Named developers there include Savion (248 MW), Key Capture Energy (5 positions totaling 419 MW), AES Clean Energy, NextEra Energy Resources, Caithness Energy, and Ramadi LLC.
One filing to flag: Prairie Point LLC submitted back-to-back ERCOT positions 27INR0618 and 27INR0619, both 1,000 MW, both hitting RAMHORNH 5 in Wise County TX, same COD of 12/31/2027. Two gigawatts at a single POI from one developer.
|
|
|
|
MORATORIUM UPDATES:
110 active BESS moratoriums across 9 states, with NY carrying 90 of them (82% of the active US map). WA 6, CA 4, IA 3, IN 2, MA 2, ME 1, TX 1, WI 1. Of the 110, 91 target utility-scale only, 18 cover all BESS, and 1 covers solar-plus-storage.
Four new moratoriums landed since the June edition. All NY, all covering all BESS rather than just utility-scale:
-
Town of Arietta, Hamilton County NY. Effective 6/22/2026, expires 6/22/2027.
-
Town of Wilton, Saratoga County NY. Effective 6/15/2026, expires 6/15/2027. Broadest of the four in wording, freezing applications, permits, site plan approval, and variances.
-
Town of Benson, Hamilton County NY. Effective 6/9/2026, expires 6/9/2027.
-
Town of Spafford, Onondaga County NY. Effective 6/9/2026, expires 6/9/2027.
None of the four overlaps with where developers already have queue capital committed (Suffolk, Ulster, Orange, Dutchess). The pattern to sit with: four in a row are all-BESS scope, not utility-scale-only. That's more restrictive than the 91 utility-scale-only ordinances that make up most of the active map.
Download: The full tracker is updated: 110 active moratoriums across 9 states.
|
|
|
|
OEM & FEOC WATCH:
Wärtsilä is spinning its global Energy Storage business into a 50/50 JV with Germany's RCT Solutions. Reclassified as Discontinued Operations and Assets Held for Sale pending close, with an expected €40 to €50M drag on 2026 operating results before turning positive by end 2027. Wärtsilä sits at #10 on Wood Mackenzie's July global BESS integrator ranking, so anyone holding a Wärtsilä contract has a live counterparty transition to track.
Fluence just published a working template for domestic-content compliance. The July 13 Rexford 2 deal (200 MW / 800 MWh for Avantus in Tulare County, CA) specifies cells from Tennessee, modules from Utah, and partner manufacturing in Texas. Named plants make the domestic-content claim harder to hand-wave, and it's a real path around the July 24 forced-labor tariff layer.
Frontier Power USA converted 920 MWh onto Eos Energy's zinc-based Z3 platform on July 7. Four ERCOT projects totaling ~230 MW / 920 MWh, all sourced from Eos' Turtle Creek PA plant (scaling to 8 GWh by 2027 on a DOE loan guarantee). Frontier is backed by $100M from Cerberus plus ~$150M in Eos equity, which is real capital behind a non-lithium play at ERCOT scale.
Saft completed large-scale fire testing on its I-Flex BESS on June 25. With NFPA 855 (2026 edition) making LSFT the default requirement alongside UL 9540A, Saft is one of the first named OEMs to have that box checked publicly under the new rules.
FEOC classifications above are Carina's assessment based on publicly available information as of publication. Developers should conduct independent due diligence and consult tax counsel. |
|
|
|
WHAT I'M WATCHING:
Before you go, here are a few things worth watching as they unfold:
-
Independence, MO Planning Commission recommendations on the dual data center and BESS moratorium were expected mid-August. Watch for city council action reclassifying data centers and BESS from by-right to special-use permits.
-
The FEOC 55% content floor for 2026 construction starts is the near-term compliance deadline. Watch USTR Section 301 country-list revisions for shifts in what counts.
-
NJ BPU's August 12 investigation of PJM capacity market design could push FERC or PJM stakeholders toward storage-friendly accreditation. Stakeholder process runs through H2 2026 into 2027.
If you see something in this data that's worth discussing or digging deeper into, please feel free to reply to this email. I read every response.
Regards,
Malaquias Encarnacion | Managing Director
Carina Energy | BESS Execution, Engineered
|
|
|
|
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.
|
|
|
|
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 → |
|
|
|
|
