⚡ 27870 CRISFIELD MARION RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 2008142807 (Crisfield Marion Rd, Somerset County, MD)

1. Site Access & Topography

The subject property, a 13.57-acre parcel, has excellent physical access, with direct frontage on Crisfield Marion Road (MD State Highway 413). This is a two-lane, paved state-maintained road that appears to be in good condition and suitable for heavy vehicle traffic. The delivery of large equipment, including battery containers, power conversion systems (PCS), and main power transformers via low-boy trailers, is anticipated to be straightforward without requiring significant road improvements.

Based on aerial imagery and the general geography of Somerset County on Maryland's Eastern Shore, the site's topography is presumed to be very flat, with minimal elevation change. This is advantageous for construction, as it will likely minimize civil work and grading costs. However, this low-lying coastal plain characteristic also presents a significant risk related to flooding and high water tables, which is discussed further in the Environmental section. Given the direct road frontage, a dedicated access easement is not expected to be necessary for site entry. However, an easement will be required for the interconnection line, likely running along the MD-413 right-of-way to a nearby distribution pole.

2. Environmental Constraints

The environmental profile of this site presents several critical unknowns that constitute a high-risk factor.

• FEMA Flood Zone: The flood zone designation is currently unknown. Given the site's proximity to the Chesapeake Bay and its low elevation, there is a high probability it lies within a Special Flood Hazard Area (e.g., Zone AE). Development within a flood zone would necessitate costly mitigation, such as elevating all equipment pads and control houses above the Base Flood Elevation (BFE), potentially rendering the project economically unviable. This is a critical data gap requiring immediate investigation.
• Wetlands: The presence of wetlands is also unknown. Coastal Maryland is rich in wetlands, and it is highly probable that jurisdictional wetlands exist on or adjacent to the parcel. A formal wetland delineation will be required. The presence of wetlands and associated state/federal setback requirements could significantly reduce the stated 9.5 buildable acres and constrain the site layout.
• Chesapeake Bay Critical Area: A significant positive finding is that the property is not located within the Chesapeake Bay Critical Area. This avoids a complex and restrictive layer of state and local environmental regulation, which severely limits impervious surfaces and development activity within 1,000 feet of tidal waters. This status requires verification against official county maps but is a major de-risking factor if confirmed.
• Other Constraints: The site shows no proximity to brownfields/superfund sites, which eliminates environmental liability risk but also precludes eligibility for the 10% IRA Brownfield ITC adder. There are no identified critical habitats, protected areas, or pipelines nearby, which are all positive findings.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents a mixed but challenging picture. The nearest substation, CRISFIELD, is located 3.757 miles from the site. This distance is too great for a dedicated medium-voltage line for a distribution-scale (≤5MW) project; the associated cost would be prohibitive, likely exceeding $3-5 million.

Therefore, the only viable Point of Interconnection (POI) is the 3-phase overhead distribution feeder observed running along the site's frontage on Crisfield Marion Road. The interconnecting utility is Requires Verification, but is presumed to be Delmarva Power (an Exelon company), the incumbent utility for this region. The interconnection voltage would be at the distribution level, likely 12.47kV or 25kV.

The viability of this project is entirely dependent on the available capacity of this specific feeder. A formal interconnection pre-application is essential to determine if the line can accommodate a 5MW injection without requiring extensive and costly upgrades, such as re-conductoring back to the substation or significant protection upgrades at the substation itself. Interconnection costs for a favorable scenario (tapping the adjacent line with minor upgrades) could range from $500k to $1.5M. A scenario requiring major upgrades could easily exceed $2.5M. Timelines within PJM territory are lengthy; even a distribution-level project can take 24-36 months to move through the study process to commercial operation.

4. Regulatory & Zoning Analysis

The regulatory pathway is the most significant challenge and represents a potential fatal flaw for this project. The Authority Having Jurisdiction (AHJ) is Somerset County. The property is zoned R-1 (Residential - Single Family). A Battery Energy Storage System is an industrial/utility-scale energy facility and is fundamentally incompatible with residential zoning.

There is no clear "by-right" path forward. The project would require, at a minimum, a Conditional Use Permit (CUP) or Special Exception, and that is only if the Somerset County Unified Development Code includes provisions