⚡ PULASKI HWY

Site Diligence Analysis: PULASKI HWY, Cecil County, MD

Analyst: Senior BESS Site Evaluation Analyst, Sunland America Corp.

Date: October 26, 2023

1. Site Access & Topography

• Road Access Quality: The property is located on PULASKI HWY (US Route 40), a significant arterial highway. This generally indicates excellent primary road access for both personnel and heavy equipment. However, the internal site access from Pulaski Hwy to the actual buildable area is currently "Unknown." This is a critical gap. We need to verify if there's an existing curb cut or if a new access point would need to be engineered and permitted, which can add significant cost and time.
• Terrain Characteristics: The property is 28.85 acres, but only 5.22 acres are designated as "Buildable Acres." This disparity (approximately 18% buildable) strongly suggests significant terrain challenges, wetlands, steep slopes, or other unbuildable features across the majority of the parcel. While the specific topography is "Unknown," the low buildable acreage implies that extensive grading, earthwork, or specialized foundation work might be required for the BESS footprint, increasing civil costs. The "EMU" zoning code (likely Environmental Management Unit) further supports the likelihood of sensitive environmental features or challenging terrain.
• Heavy Equipment Delivery: Access from Pulaski Hwy is favorable for the delivery of oversized equipment such as transformers, battery containers, and construction machinery. However, the internal site access and the ability to maneuver heavy loads to the specific 5.22 buildable acres will depend heavily on the internal topography and the need for new access road construction. This requires a detailed site survey and geotechnical assessment.
• Access Easement Concerns: No specific access easements are noted in the provided data. However, for a large parcel with limited buildable area, it is crucial to investigate potential existing easements (e.g., utility, drainage, ingress/egress for adjacent parcels) that could further restrict the usable footprint or require negotiation. This is a standard due diligence item.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA Flood Zone designation is "Unknown." This is a critical risk. BESS installations must be sited outside of 100-year floodplains (Zone AE/VE) or require significant, costly flood mitigation measures. A detailed flood zone map analysis is an immediate next step.
• Wetlands Presence: Wetlands presence is "Unknown." Given that only 5.22 out of 28.85 acres are buildable, there is a high probability of significant wetlands on the property. Wetlands require strict setbacks and permitting (e.g., Section 404/401 permits from USACE and MDE in Maryland), which can be time-consuming, expensive, and may even render portions of the buildable area unusable. A Phase I Environmental Site Assessment (ESA) and potential wetland delineation are essential.
• Critical Habitat / Endangered Species: The data indicates "None" for Critical Habitat within the vicinity. This is a positive finding, reducing permitting complexity and potential project delays associated with endangered species act compliance.
• Brownfield/Superfund Status: The property is "None within ~2 miles" of a Brownfield/Superfund site. This is a positive in terms of avoiding environmental remediation costs and liabilities. However, it also means the project will not qualify for the IRA Brownfield ITC bonus adder, which is a missed incentive opportunity.
• Chesapeake Bay Critical Area: The property is designated as "No" within the Chesapeake Bay Critical Area. This is a significant advantage, as it avoids the stringent development regulations, impervious surface limits, and enhanced stormwater management requirements typically imposed within this sensitive environmental zone in Maryland.
• Pipeline Proximity: There are "None within ~3 miles" of the property. This is a positive safety finding, eliminating the need for extensive pipeline safety studies, setback requirements, and potential consultation with pipeline operators, which can be complex and add risk.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The nearest substation distance and maximum voltage are "Unknown." This is a major data gap and a critical impediment to evaluating distribution-level interconnection. Without this information, it is impossible to assess the feasibility, cost, or capacity for a typical distribution-scale BESS project (≤5MW).
• Nearest Transmission Line: A 500kV transmission line (PECO ENERGY CO) is located at 2.6 miles. This is a very high voltage line, indicating significant regional grid capacity.
• Recommended Interconnection Voltage: For a distribution-scale project (≤5MW), the primary target should be distribution-level interconnection at a nearby substation (e.g., 12kV, 34.5kV). However, without substation data, this is speculative. Interconnecting to a 500kV transmission line at 2.6 miles for a distribution-scale project would be exceptionally complex and expensive, requiring a new transmission-level substation, significant line extensions, and potentially a lengthy PJM interconnection queue process. Given Sunland America's focus on distribution-scale projects, transmission interconnection is likely economically unfeasible unless the project scope significantly increases.
• Estimated Interconnection Cost Range and Timeline: Without substation data, a distribution interconnection cost estimate is impossible. For a transmission interconnection at 500kV, 2.6 miles, costs would likely be in the tens of millions of dollars, with timelines extending 3-5+ years due to the need for a new substation and extensive grid studies. This is prohibitive for a typical distribution-scale project.
• Utility-Specific IX Process and Typical Queue Times: The "Interconnecting Utility" is "Unknown." Cecil County is primarily served by Delmarva Power (an Exelon company, like PECO). Delmarva Power's interconnection process follows PJM rules for projects above 2MW and state-specific rules for smaller projects. PJM queue times are notoriously long (2-4+ years for studies alone). This needs immediate clarification.
• Likely Feeder Configuration: "Unknown" without substation data. Understanding the feeder configuration (e.g., radial, looped, network) is crucial for assessing reliability, available capacity, and potential for grid services.

4. Regulatory & Zoning Analysis

• Authority Having Jurisdiction (AHJ): The AHJ is "Unincorporated (county jurisdiction)," specifically Cecil County, MD.
• Current Zoning for BESS Compatibility: The current zoning is "Vacant Land - Residential-Vacant Land (Code: EMU)." This is a significant red flag. Residential zoning is generally incompatible with utility-scale BESS projects. The "EMU" code (Environmental Management Unit) often implies a focus on environmental protection, which may further restrict industrial or energy infrastructure development. BESS facilities are typically classified as industrial, utility, or special use, and are rarely permitted by-right in residential zones.
• Recommended Permitting Pathway: Given the residential zoning, a "by-right" permitting pathway is highly improbable. The most likely pathways would be:
  • Special Exception or Conditional Use Permit (CUP): This would require demonstrating that the BESS project meets specific criteria and conditions to be compatible with the surrounding residential character, often involving public hearings and discretionary approval.
  • Variance: If the project cannot meet specific zoning requirements (e.g., setbacks), a variance might be sought, but these are difficult to obtain and typically require demonstrating undue hardship.
  • Rezoning: The most comprehensive but also most challenging pathway would be to petition Cecil County for a rezoning of the parcel to an industrial or utility classification. This is a lengthy, expensive, and politically sensitive process with no guarantee of success.
  The current zoning presents a major hurdle and significantly increases project risk and development timeline.
• Known Setback Requirements for BESS: "Unknown" for BESS in this jurisdiction. Cecil County will have specific setback requirements from property lines, residential structures, and public roads. Maryland state fire code (NFPA 855) also dictates specific separation distances for BESS units. These need immediate investigation.
• State/County Regulations: Maryland has state-level regulations for energy storage, including COMAR 20.62 (Energy Storage Systems) and fire safety codes (e.g., NFPA 855 adoption). Cecil County's Zoning Ordinance will govern land use, setbacks, and permitting processes.
• Moratorium or Restriction Risks: "Unknown." However, given the residential zoning and the increasing public scrutiny of BESS projects, there is a non-zero risk of local opposition leading to temporary moratoriums or restrictive ordinances, especially if the project requires a CUP or rezoning.

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% Investment Tax Credit (ITC) adder for projects located in Opportunity Zones.
• Energy Community Status: The property is designated "No" for Energy Community status. This means the project will not qualify for the additional 10% ITC adder for projects located in Energy Communities (e.g., brownfield sites, coal closure areas, or areas with significant fossil fuel employment).
• 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 adder available for projects in qualifying low-income communities or benefiting low-income households.
• Calculate Potential Cumulative ITC Adder Percentage: Based on the provided data, the cumulative ITC adder percentage for this site is 0%. Assuming the project meets prevailing wage and apprenticeship requirements, it would only qualify for the base 30% ITC. The absence of any adders significantly reduces the project's financial attractiveness and competitiveness compared to sites that qualify for these bonuses.

6. BESS Score & Rationale

BESS Suitability Score: 35/100

• Location (0-20): 10/20
  • Rationale: Good primary road access (Pulaski Hwy) is a positive. However, the very low buildable acreage (5.22 out of 28.85 acres) suggests significant site constraints (topography, environmental) that will increase civil costs and limit layout flexibility. Proximity to residential zoning is a major negative for social license.
• Grid Access (0-2