⚡ 8900 N GREENWOOD AVE

Site Diligence Analysis: 8900 N GREENWOOD AVE, Cook County, IL

Date: October 26, 2023
Analyst: Senior BESS Site Evaluation Analyst, Sunland America Corp.

1. Site Access & Topography

• Road Access Quality: The property benefits from "Public" road access, which is a significant advantage for BESS development. This typically implies well-maintained, paved roads capable of supporting commercial traffic.
• Equipment Delivery Feasibility: Given public road access and the "Buildability: OK" designation, it is highly probable that heavy equipment, including large transformers, battery containers, and construction machinery, can be delivered to the site without major logistical hurdles. The "POI Onsite" status further simplifies equipment movement related to interconnection.
• Terrain Characteristics: The property's zoning as "Commercial (Retail) - Grocery, Supermarket" (C-2) in Niles, IL, strongly suggests a relatively flat, previously developed, or easily developable parcel. Commercial areas are typically graded for ease of construction and access. The "Buildability: OK" assessment supports this, indicating no major topographical challenges like steep slopes or significant rock outcrops.
• Access Easement Concerns: No specific data on access easements is provided. While public road access is confirmed, it is crucial to verify if the specific parcel (7.39665 acres per Regrid, within the larger 30.96 acres) has direct frontage or requires an access easement across adjacent portions of the larger property. This requires verification through a title search and survey.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA Flood Zone designation is "Unknown." This is a critical data gap. Siting BESS in a 100-year flood plain (Zone A or AE) would necessitate significant flood mitigation measures, such as elevated platforms or extensive flood barriers, substantially increasing project costs and complexity. A detailed flood study is required.
• Wetlands Presence: Wetlands presence is also "Unknown." This is another critical environmental unknown. The presence of jurisdictional wetlands would trigger federal (USACE) and state permitting, requiring extensive delineation, mitigation, and potential project redesign, leading to significant delays and costs. A Phase I Environmental Site Assessment (ESA) and potential wetland delineation are essential.
• Critical Habitat / Endangered Species Risk: The data indicates "Critical Habitat: None" and "Protected Areas: None." This is a positive finding, as it significantly reduces the risk of delays and design modifications associated with endangered species protection under federal and state regulations.
• Brownfield/Superfund Status: The data states "None within ~2 miles." This is favorable as it avoids the environmental remediation costs and liabilities associated with contaminated sites. However, it also means the project would not qualify for the IRA Brownfield Bonus ITC adder, which requires the project to be located on a brownfield site.
• Chesapeake Bay Critical Area: The data confirms "N/A (non-MD)," meaning this constraint is not applicable to the Illinois site.
• Pipeline Proximity Safety: The data indicates "None within ~3 miles." This is excellent news, as it eliminates the need for extensive safety setbacks, risk assessments, and potential permitting complexities often associated with high-pressure gas or hazardous liquid pipelines. Similarly, "Gas Wells Nearby: None within ~2 miles" further reduces subsurface risks.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The nearest substation distance and maximum voltage are "Unknown." This is a significant gap in grid infrastructure assessment. The distance to the substation directly impacts interconnection costs (line extensions, upgrades) and feasibility. Identifying the specific substation and its available capacity is paramount.
• Nearest Transmission Line: A 345kV transmission line (COMMONWEALTH EDISON CO) is located at 0.9 miles. This proximity to high-voltage transmission is a strategic asset, offering potential future expansion or alternative interconnection pathways, though the current plan is distribution-level.
• Likely Interconnection Voltage: The specified "IX Voltage: 12.9 kV" clearly indicates an intent for distribution-level interconnection. Given the "POI Onsite" status, it suggests direct access to a 12.9 kV feeder.
• Interconnection Cost Range and Timeline: Without substation details and available capacity, estimating costs and timelines is speculative. However, for a 12.9 kV distribution interconnection in ComEd territory (Cook County, IL), costs could range from $500,000 to $2,000,000+ depending on required feeder upgrades, new line extensions (if POI is not directly on a robust feeder), and substation upgrades. Timelines for ComEd distribution interconnection studies and construction can be lengthy, typically 18-36 months, often with significant queue times.
• Utility-Specific IX Process: The interconnecting utility is Commonwealth Edison (ComEd). ComEd has a well-defined but often lengthy interconnection process, involving application, screening, impact studies (System Impact Study, Facilities Study), and construction. Their queues are known to be substantial, especially for larger distribution-scale projects (e.g., 5MW).
• Likely Feeder Configuration: The "POI Onsite" and 12.9 kV IX voltage suggest the property has direct access to an existing ComEd distribution feeder. Further due diligence is required to determine the feeder's health, capacity, and existing load profile.

4. Regulatory & Zoning Analysis

• Authority Having Jurisdiction (AHJ): The primary AHJ is the "Municipality / AHJ: Niles." Cook County will also have some oversight, particularly for stormwater management and potentially building codes.
• Current Zoning for BESS Compatibility: The property is zoned "Commercial (Retail) - Grocery, Supermarket" (C-2). BESS facilities are typically classified as utility, industrial, or heavy commercial uses. It is highly unlikely that a BESS facility would be permitted "by-right" in a C-2 commercial retail zone.
• Permitting Pathway Recommendation: The most probable permitting pathway will be a Conditional Use Permit (CUP) or Special Use Permit (SUP) from the Village of Niles. This process involves public hearings, detailed site plans, and demonstrating compatibility with surrounding land uses and the comprehensive plan. A zoning variance is less likely unless specific hardship can be proven.
• Known Setback Requirements: Specific setback requirements for BESS in Niles are "Unknown" and require immediate verification. Typical BESS setbacks can range from 50-200 feet from residential property lines, and often include requirements from public roads, property lines, and other sensitive receptors.
• State/County Regulations: Illinois has some state-level guidance for energy storage, but local zoning ordinances in Niles will be the primary determinant. Cook County may have specific building code amendments or environmental regulations that apply.
• Moratorium or Restriction Risks: No known moratoriums or restrictions are indicated. However, given the early stage of BESS deployment in many municipalities, there is always a risk that a local jurisdiction might impose a temporary moratorium to develop specific BESS ordinances. This requires direct inquiry with Niles planning department.

5. IRA/ITC Incentive Analysis

• Opportunity Zone Eligibility: The property is designated "No" for Opportunity Zone eligibility. This means the project will not qualify for the additional 10% ITC adder for Opportunity Zones.
• Energy Community Status: The property is designated "Yes — Fossil Fuel Employment (FFE Area)" for Energy Community status. This is a significant positive, qualifying the project for a 10% ITC adder.
• Low-Income Community Qualification: The property is designated "No" for Low-Income Community qualification. This means the project will not qualify for the additional 10% or 20% ITC adders for Low-Income Communities.
• Potential Cumulative ITC Adder Percentage:
  • Base ITC: 30% (assuming prevailing wage and apprenticeship requirements are met)
  • Energy Community Adder: +10%
  • Opportunity Zone Adder: +0%
  • Low-Income Community Adder: +0%
  • Total Potential ITC: 40%
  This 40% ITC is a strong financial incentive, significantly enhancing project economics.

6. BESS Score & Rationale

Overall BESS Suitability Score: 68/100

• Location (15/20): Good public road access and "Buildability: OK" are strong positives. The "POI Onsite" is excellent. However, the discrepancy between "Total Acres: 30.96" and "Parcel Acres (Regrid): 7.39665" needs clarification to ensure sufficient buildable area for the desired project size.
• Grid Access (12/25): While 12.9 kV IX voltage and "POI Onsite" are promising, the "Unknown" nearest substation distance and capacity are critical deficiencies. The 345kV transmission line proximity is a long-term strategic asset but doesn't immediately mitigate the distribution interconnection unknowns. ComEd's known queue times are a concern.
• Environmental (8/15): Absence of critical habitat, pipelines, and brownfield status are positives. However, the "Unknown" status for FEMA Flood Zone and Wetlands represents significant, high-impact risks that could render the site unbuildable or prohibitively expensive.
• Regulatory (10/15): The known AHJ (Niles) is good. Commercial zoning (C-2) is generally more flexible than residential but will almost certainly require a CUP/SUP, adding time and complexity. Unknown setback requirements and potential moratorium risks are concerns.
• Incentives (12/15): The 10% Energy Community adder is a strong positive, leading to a 40% total ITC. The lack of Opportunity Zone or Low-Income Community adders is noted but doesn't detract from the strong Energy Community benefit.
• Buildability (11/10): "Buildability: OK" combined with