⚡ 3126 MILLINGTON RD

Site Access & Topography

The property benefits from Public Road Access, which is a critical positive for BESS development, ensuring unhindered ingress and egress for construction and operational vehicles. The indication of POI Onsite (Point of Interconnection) is also highly advantageous, suggesting that the necessary grid infrastructure is either directly on the property or immediately adjacent, minimizing the need for off-site access easements for transmission lines or distribution feeders. The property spans a substantial 139.16 acres, with 87.77 buildable acres, indicating a large, developable footprint. The "Buildability: Great" assessment strongly suggests favorable terrain characteristics, likely flat to gently rolling, which significantly reduces site preparation costs and complexities associated with grading, cut-and-fill operations, and stormwater management. This excellent buildability, combined with public road access, confirms that heavy equipment, including large transformers, battery containers, and construction machinery, should have feasible access to the site without significant logistical challenges. No specific access easement concerns are noted, but a detailed survey during due diligence will confirm this. The large parcel size also provides ample room for necessary setbacks from property lines and potential future expansion.

Environmental Constraints

Several environmental factors require careful consideration. The FEMA Flood Zone designation is currently Unknown, which represents a significant data gap. This is a critical piece of information, as BESS facilities must be sited outside of 100-year floodplains (Zone AE or A) or require extensive and costly flood mitigation measures (e.g., elevated pads, floodwalls) to meet regulatory and insurance requirements. Similarly, the presence of Wetlands is also Unknown. Wetlands are federally and state-protected areas, and their presence would necessitate avoidance, extensive permitting (e.g., Section 404/401 permits from the Army Corps of Engineers and Maryland Department of the Environment), and potential mitigation, which can significantly increase project costs and timelines. The data indicates No Critical Habitat and No Endangered Species, which is a positive, avoiding complex biological assessments and potential project delays. The absence of Brownfield/Superfund sites within a 2-mile radius eliminates environmental remediation risks and associated costs, though it also means the project would not qualify for the IRA brownfield ITC adder. The property is explicitly noted as Not within the Chesapeake Bay Critical Area, which is a major advantage, as development within this sensitive region is subject to highly stringent environmental regulations, impervious surface limits, and extensive permitting requirements. Finally, the absence of Pipeline Proximity within approximately 3 miles removes significant safety and setback concerns often associated with high-pressure gas or hazardous liquid pipelines.

Grid Infrastructure & Interconnection

The grid infrastructure presents a mix of promising aspects and critical unknowns. The nearest transmission line, a 138kV line owned by Delmarva Power, is located at an excellent 0.5 miles from the property. This proximity is a strong positive, indicating relatively low transmission line extension costs. The stated Interconnection Voltage (IX Voltage) is 69 kV. This suggests that while a 138kV line is nearby, the utility (Delmarva Power) may prefer or require interconnection at the 69kV distribution or sub-transmission level, or there is an unstated 69kV line also in close proximity. For distribution-scale projects (up to 5MW), 69kV is a common interconnection voltage. We would recommend pursuing a 69kV distribution-level interconnection, aligning with the stated IX voltage, which is generally less complex and costly than a full transmission-level interconnection. However, the Nearest Substation distance and maximum voltage are Unknown. This is a critical gap, as the substation's capacity, age, and available feeder positions will dictate the feasibility and cost of interconnection. Without this information, estimating interconnection costs and timelines is speculative. Based on the 0.5-mile proximity to a 138kV line, interconnection costs could range from $1.5M to $4M, depending on whether a new 69kV tap from the 138kV line is required, or if an existing 69kV line/substation is truly nearby and has capacity. The timeline for interconnection with Delmarva Power (an Exelon utility) typically involves a multi-stage queue process (e.g., Feasibility, System Impact, Facilities Studies) which can range from 18 to 36 months, depending on the project's complexity and queue position. The likely feeder configuration would be a dedicated 69kV line from a nearby substation or a new tap from the 138kV line stepping down to 69kV. Further investigation into Delmarva Power's specific interconnection process and typical queue times for Queen Anne's County is essential.

Regulatory & Zoning Analysis

The regulatory and zoning landscape presents the most significant challenge for this site. The Authority Having Jurisdiction (AHJ) is Unincorporated Queen Anne's County, MD. The current zoning is identified as Residential - Rural/Agricultural Residence (Code: CS). This zoning designation is highly problematic for a BESS facility, which is typically classified as a utility, industrial, or heavy commercial use. It is extremely unlikely that a BESS would be permitted "by-right" under this zoning. The most probable permitting pathway would be a Conditional Use Permit (CUP) or Special Exception. This process is discretionary, involves public hearings, and requires demonstrating that the proposed use is compatible with the surrounding area and meets specific conditions outlined in the county's zoning ordinance. A rezoning application is also a possibility but is generally more arduous and carries higher political risk. We must immediately investigate Queen Anne's County's specific ordinances for utility-scale or energy generation facilities within rural/agricultural zones. Known setback requirements for BESS in this jurisdiction are Unknown and must be verified, as these can significantly impact the usable acreage. Maryland state regulations, particularly those under the Public Service Commission (PSC), may apply for projects exceeding certain thresholds, but for distribution-scale (≤5MW), local zoning often takes precedence. There is no information on any current moratorium or restriction risks, but this should be verified during initial county outreach. The zoning incompatibility represents a major hurdle that could lead to significant delays, increased costs, or outright project denial.

IRA/ITC Incentive Analysis

The property's eligibility for additional Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) appears limited based on the provided data. The site is designated as Not an Opportunity Zone, meaning it does not qualify for the 10% ITC adder associated with projects in low-income communities designated as Opportunity Zones. Similarly, the property is Not an Energy Community, precluding eligibility for the 10% ITC adder for projects located in areas with historical fossil fuel employment or brownfield sites. Lastly, the site does Not qualify as a Low-Income Community, which would otherwise provide a 10% or 20% ITC adder depending on the project's ownership structure and capacity. Therefore, based on the current data, the potential cumulative ITC adder percentage is 0%. The project would still be eligible for the base 30% ITC (assuming prevailing wage and apprenticeship requirements are met), but no additional bonuses are identified from these specific categories. Further diligence could explore if any other IRA adders, such as domestic content or energy storage manufacturing, might apply to the BESS equipment itself, but these are not site-specific.

BESS Score & Rationale

BESS Suitability Score: 55/100

• Location (15/20): The site offers excellent buildability ("Great") and public road access, with a large buildable area (87.77 acres out of 139.16 total). This provides ample space for the BESS footprint and necessary setbacks. No critical habitat, pipelines, or Chesapeake Bay Critical Area issues are present.
• Grid Access (18/25): Proximity to a 138kV transmission line at 0.5 miles is outstanding, suggesting relatively low interconnection line extension costs. The stated 69kV IX voltage is suitable for distribution-scale projects. However, the critical lack of information regarding the nearest substation (distance, capacity, voltage) and the specific location/availability of a 69kV line introduces significant uncertainty and risk, preventing a higher score.
• Environmental (8/15): Positives include no critical habitat, no pipelines, no brownfields (thus no remediation risk), and not being in the Chesapeake Bay Critical Area. However, the "Unknown" status for FEMA Flood Zone and Wetlands is a major concern. These are fundamental environmental due diligence items that, if unfavorable, could significantly impact project feasibility, cost, and timeline.
• Regulatory (5/15): This is the weakest category. The "Residential - Rural/Agricultural Residence (CS)" zoning is highly incompatible with BESS development. This will almost certainly require a complex, discretionary permitting pathway (CUP/Special Exception/Rezoning) with high risk of denial, significant delays, and substantial community opposition. The lack of known BESS-specific setback requirements adds to the uncertainty.
• Incentives (5/15): The site does not qualify for any of the major IRA ITC adders (Opportunity Zone, Energy Community, Low-Income Community). While the base 30% ITC is valuable, the absence of adders reduces the overall financial attractiveness compared to other sites.
• Buildability (4/10): While the "Buildability: Great" is a strong positive, the score is slightly tempered by the unknowns regarding floodplains and wetlands, which could introduce unforeseen construction challenges or require costly mitigation if present.

Key Risks & Mitigants

1. Zoning Incompatibility: The "Residential - Rural/Agricultural Residence (CS)" zoning is a fundamental mismatch for a BESS facility.
   • Mitigant: Immediately engage Queen Anne's County Planning & Zoning Department for a pre-application meeting to understand specific BESS permitting pathways (CUP, Special Exception, Rezoning) and their likelihood of success. Simultaneously, initiate a community engagement strategy to gauge local sentiment and address concerns proactively.
2. Environmental Unknowns (FEMA Flood Zone & Wetlands): The lack of data on floodplains and wetlands poses significant financial and permitting risks.
   • Mitigant: Conduct an immediate desktop environmental screen using FEMA Flood Insurance Rate Maps (FIR