⚡ Clayton Rd.

Site Diligence Analysis: Clayton Rd., Gloucester, NJ

As a senior BESS site evaluation analyst for Sunland America Corp., I have performed a comprehensive diligence analysis for the property located on Clayton Rd. in Gloucester County, New Jersey. This analysis aims to assess the site's suitability for a distribution-scale (≤5MW) or utility-scale BESS project, focusing on the provided data and identifying critical next steps.

1. Site Access & Topography

The property benefits from Public Road Access, which is a significant advantage for equipment delivery and ongoing operations. This generally implies that the roads are maintained by the municipality or state, reducing the burden on the developer for initial access improvements. The data indicates "POI Onsite," meaning the Point of Interconnection is located directly on the property, which is excellent for minimizing interconnection costs and land acquisition for off-site infrastructure. The "Buildability: Great" assessment suggests favorable terrain characteristics, likely flat to gently rolling, which minimizes site grading costs and construction complexity. Gloucester County, NJ, is generally characterized by relatively flat topography, supporting this assessment.

For heavy equipment delivery, such as large transformers, battery containers, and construction machinery, the public road access will need further verification. We must confirm the specific road's width, turning radii at intersections, and any weight restrictions or bridge capacities along the likely haul route from major highways to the site. While public access is good, a detailed route survey is essential. No specific access easement concerns are noted in the provided data, but this will be a standard due diligence item to confirm clear, unencumbered access rights for construction and operation.

2. Environmental Constraints

Several critical environmental factors require immediate investigation. The FEMA Flood Zone designation is currently Unknown. This is a high-priority item, as BESS facilities are sensitive to flooding, and siting within a floodway or high-risk flood zone (e.g., AE, VE) would necessitate significant, costly flood mitigation measures or render the site unsuitable. Similarly, the presence of Wetlands is also Unknown. New Jersey has stringent wetland regulations, and the presence of state or federally regulated wetlands could severely restrict the developable area, trigger lengthy permitting processes, and require costly mitigation. A wetland delineation is crucial.

On the positive side, the data indicates No Critical Habitat and No Protected Areas, which significantly reduces environmental permitting risk related to endangered species. There are No Brownfield/Superfund sites within approximately 2 miles, eliminating potential contamination risks and associated remediation costs. While this means the site does not qualify for the IRA brownfield bonus, it also avoids significant environmental liability. No Pipeline Proximity within 3 miles is also a positive, removing safety and setback concerns associated with gas or hazardous material pipelines. The site is correctly identified as N/A for Chesapeake Bay Critical Area, as it is not located within that jurisdiction.

3. Grid Infrastructure & Interconnection

The site demonstrates promising grid access. The Nearest Substation (Monroe) is only 1.5 miles away with a maximum voltage of 230 kV, and a 230kV Transmission Line is even closer at 0.8 miles, owned by Atlantic City Electric Co. (ACE). The specified Interconnection Voltage (IX Voltage) is 69 kV, which typically indicates a distribution-level interconnection, though 69 kV lines often function as sub-transmission. Given the proximity to both a substation and a 230kV line, an interconnection at 69 kV is highly feasible. The "POI Onsite" further enhances this, reducing the need for extensive off-site line extensions.

The likely interconnecting utility is Atlantic City Electric (ACE). While the specific available capacity at the Monroe substation or on the relevant 69 kV feeder is Unknown, the proximity is a strong indicator of potential viability. We recommend an interconnection voltage of 69 kV, aligning with the provided data, likely tapping into an existing 69 kV line or a new line from the Monroe substation. Interconnection costs for a 1.5-mile tie-in to the substation or a 0.8-mile tap into a 230kV line (stepping down to 69kV) could range from $1.5M to $4M+, depending on required substation upgrades, line construction, and protection schemes. The timeline for ACE's interconnection process, including studies (System Impact Study, Facilities Study), can typically range from 18 to 36 months, with queue times varying based on regional demand. The likely feeder configuration is Unknown and requires detailed study by ACE to determine the optimal point of interconnection and any necessary upgrades.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is Clayton Borough, NJ, a municipal government. This is a critical point of concern. The current zoning for the parcel is identified as A (Agricultural). Siting a BESS facility, which is an industrial-scale energy infrastructure project, within an agricultural zone is a significant regulatory hurdle. It is highly unlikely that a BESS would be considered a "by-right" use in an agricultural zone in New Jersey without specific local ordinance provisions. Therefore, the most probable permitting pathway will be through a Conditional Use Permit (CUP) or a Special Exception. This process typically involves extensive public hearings, detailed impact assessments (traffic, noise, visual, environmental), and discretionary approval by the planning board or governing body. Rezoning the parcel from Agricultural to an Industrial or Commercial designation is another, more challenging, pathway that would require a comprehensive master plan amendment and municipal ordinance change.

Specific setback requirements for BESS facilities in Clayton Borough are Unknown and must be thoroughly investigated. New Jersey also has state-level regulations for BESS, particularly concerning fire safety (e.g., NJDEP, NJ DCA, local fire codes adopting NFPA 855). We must confirm if Clayton Borough has any existing ordinances or is considering a moratorium or restrictions on BESS development, as this is an emerging trend in some municipalities. Proactive engagement with the Clayton Borough Planning Department is essential to understand their stance on BESS in agricultural zones and the specific requirements for a CUP or rezoning.

5. IRA/ITC Incentive Analysis

Based on the provided data, the site does not qualify for several key Inflation Reduction Act (IRA) Investment Tax Credit (ITC) adders. The property is designated as Not an Opportunity Zone, Not an Energy Community, and Not a Low-Income Community. This means the project, as currently assessed, would not be eligible for the respective 10% or 20% ITC bonus adders associated with these designations. While the base ITC (currently 30% for BESS) would still apply, the absence of these adders means a potential cumulative ITC adder percentage of 0%. This significantly impacts the project's financial pro forma and overall competitiveness compared to sites that qualify for these incentives. Further verification with official IRS/Treasury mapping tools is recommended to confirm these designations, as boundaries can be complex.

6. BESS Score & Rationale

Based on the comprehensive analysis, the Clayton Rd. site receives a BESS Suitability Score of 62/100.

• Location (0-20): 16/20
  • Rationale: Excellent public road access and POI onsite are strong positives. The 41.16 acres provide ample space. Gloucester County is a growing region, potentially offering local load benefits.
• Grid Access (0-25): 20/25
  • Rationale: Proximity to the Monroe Substation (1.5 miles) and a 230kV transmission line (0.8 miles) is highly favorable. The 69 kV IX voltage is a good target. POI onsite is a significant cost-saver. The primary deduction is for the unknown available capacity.
• Environmental (0-15): 7/15
  • Rationale: No critical habitat, brownfield, pipelines, or Chesapeake Bay issues are strong positives. However, the critical unknowns regarding FEMA Flood Zone and Wetlands are major deductions, representing significant potential risks and costs.
• Regulatory (0-15): 5