⚡ 196 NESBITT RD

Site Diligence Analysis: 196 NESBITT RD, Cecil County, MD

To: Sunland America Corp. Development Team
From: Senior BESS Site Evaluation Analyst
Date: October 26, 2023
Subject: Comprehensive Site Diligence Analysis for 196 Nesbitt Rd, Cecil County, MD

1. Site Access & Topography

The property at 196 Nesbitt Rd, Cecil County, MD, totaling 5.59 acres with 5.13 buildable acres, presents a mixed picture regarding access and topography. The specific quality of "Road Access" and "POI Access" is currently Unknown. This is a critical information gap. Nesbitt Road itself needs to be thoroughly evaluated for its width, pavement quality (paved vs. unpaved), and load-bearing capacity to determine if it can support the delivery of heavy equipment such as large transformers, battery containers, and construction machinery. If Nesbitt Road is a typical residential street, significant upgrades, including widening, paving, and potential reinforcement, may be required, incurring substantial costs and potential permitting delays. Direct access to the parcel from Nesbitt Road also needs verification; any existing driveways or access points must be assessed for suitability or if new ones need to be constructed.

Regarding topography, the high percentage of buildable acres (5.13 out of 5.59) suggests the terrain is likely relatively flat or gently sloping, which is favorable for BESS construction, minimizing extensive grading and earthwork costs. However, without specific topographical data or a site visit, this remains an assumption. Heavy equipment access will depend entirely on the road quality and the site's internal grading. Any access easement concerns are Unknown at this stage and would require a title search and survey to identify.

2. Environmental Constraints

Several key environmental factors require immediate investigation. The FEMA Flood Zone designation is Unknown, which is a significant risk. Siting a BESS within a flood zone (e.g., AE, VE) would necessitate elevated equipment pads, specialized flood-resistant designs, and potentially higher insurance premiums, substantially increasing project costs and complexity. Similarly, the presence of Wetlands is Unknown. Wetlands trigger stringent federal (US Army Corps of Engineers) and state (Maryland Department of the Environment) permitting processes, requiring extensive delineation, mitigation plans, and significant setbacks, which could reduce the effective buildable area and extend project timelines considerably.

Positively, the site appears free from several major environmental impediments: there are None identified for Critical Habitat, Protected Areas, Brownfield/Superfund sites within ~2 miles, Pipeline Proximity within ~3 miles, or Gas Wells Nearby within ~2 miles. The absence of Brownfield/Superfund status means there's no immediate contamination risk, though it also means the project would not qualify for the IRA brownfield bonus adder. Crucially, the site is Not within the Chesapeake Bay Critical Area, which is a major advantage as it avoids the highly restrictive development regulations and lengthy review processes associated with that designation in Maryland.

3. Grid Infrastructure & Interconnection

The grid infrastructure at this location is exceptionally strong, presenting a significant advantage. The Nearest Substation, COLORA, is only 0.449 miles away with a Max Voltage of 230 kV. Even more compelling is the Nearest Transmission Line, a 500kV line owned by PECO ENERGY CO., located at a mere 0.2 miles. This proximity to high-voltage infrastructure is ideal for a utility-scale BESS project.

Given the close proximity to both 230kV substation and a 500kV transmission line, the likely interconnection voltage would be at the transmission level, either 230kV or potentially 500kV, depending on the project size and available capacity at the substation/line. While the Interconnecting Utility and IX Voltage are currently Unknown, Cecil County is typically served by Delmarva Power (an Exelon company, similar to PECO) or BGE. We recommend targeting a transmission-level interconnection due to the excellent proximity. Interconnection costs, while still potentially in the range of $1M-$5M+ for transmission-level studies and potential substation/line upgrades, would be significantly lower than sites requiring extensive new line construction. The timeline for transmission-level interconnection studies (System Impact Study, Facilities Study) and construction could range from 2 to 4+ years. The utility-specific interconnection process and typical queue times for Delmarva Power or BGE would need to be investigated immediately. The likely feeder configuration is Unknown, but for a project of this scale and proximity to transmission, a direct transmission tap or substation connection is more probable than a distribution feeder connection.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is Unincorporated Cecil County, MD. This is a critical area of concern. The current Zoning is identified as "Residential - Mobile/Manufactured Home (NAR)." This zoning designation is highly incompatible with a Battery Energy Storage System, which is typically classified as an industrial or heavy commercial use. It is extremely unlikely that a BESS would be permitted "by-right" in this zone.

The recommended permitting pathway will almost certainly involve a challenging and lengthy process. Options include a Conditional Use Permit (CUP), Special Exception, or a full rezoning application. A variance is generally reserved for minor deviations, not a fundamental change in land use. Each of these pathways requires extensive public hearings, demonstrating compliance with specific criteria, and often faces significant community opposition, especially in residential areas. Cecil County's specific zoning ordinances must be reviewed to identify any known