Probably yes.

The IRS hasn't issued guidance on what "when the original installation of the item is completed" means. However, basic statutory construction says that it does not mean "placed in service" because those two terms appear in 26 USC section 25D.

To me, "placed in service" means everything is done and the panels are producing. Accordingly, "when the original installation of the item is completed" must mean something before "placed in service" and to me, the only reasonable thing is not yet turned on or not yet approved or given permission to operate by the utility. But that's just my guess.