⚡ 6153 MILL RD

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Mill Road"

Property: 6153 MILL RD, Egg Harbor Township, Atlantic County, NJ (APN: 0108_5202_19)

Executive Summary: This 5.47-acre parcel presents a high-risk, high-reward opportunity. The site boasts exceptional grid infrastructure proximity and qualifies for a lucrative 10% IRA Energy Community tax credit adder. However, these significant advantages are directly countered by a prohibitive residential zoning designation (RG-1), which poses a formidable, potentially fatal, permitting challenge. Environmental unknowns, specifically wetlands and flood risk, also require immediate investigation. The project's viability hinges entirely on our ability to secure a use variance from Egg Harbor Township. My final recommendation is a MAYBE, contingent on positive initial feedback from the local jurisdiction.

1. Site Access & Topography

The property has direct frontage on Mill Road (County Rd 662), a two-lane paved road that appears to be in good condition. This level of access is sufficient for standard construction vehicles and personnel. However, a detailed transportation route survey is required to confirm the feasibility of delivering oversized and overweight equipment, such as 53-foot battery containers and multi-ton transformers. The survey must verify bridge clearances, weight limits, and turn radii from the nearest major highway (e.g., Atlantic City Expressway) to the site entrance.

Based on its location in the Atlantic Coastal Plain of Southern New Jersey, the site's topography is expected to be very flat with sandy, well-drained soils. This is a significant advantage, as it will likely minimize civil engineering and grading costs. An access road will need to be constructed from Mill Road onto the site, which should be straightforward given the flat terrain. The provided 4.8 buildable acres suggests a portion of the site is constrained, though the reason is currently unknown.

A critical unknown is the presence of any access, utility, or conservation easements. A preliminary title report must be ordered immediately to identify any recorded encumbrances that could restrict the placement of BESS equipment or access roads.

2. Environmental Constraints

Environmental factors present the most significant physical risk to this site's developability. The following points are critical:

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a major data gap. A review of FEMA's Flood Insurance Rate Maps (FIRMs) is a top priority. If the site is located within a Special Flood Hazard Area (SFHA, e.g., Zone AE), all equipment pads would need to be elevated above the Base Flood Elevation, dramatically increasing civil costs. If it is in a floodway, development would be prohibited.
• Wetlands: The presence of wetlands is Unknown. Given the site's coastal plain geography, there is a high probability of jurisdictional wetlands being present. A formal wetlands delineation by a certified consultant is mandatory. New Jersey Department of Environmental Protection (NJDEP) regulations are stringent, and required buffers around any identified wetlands could severely reduce or eliminate the 4.8 buildable acres.
• Critical Habitat / Species: The initial screening shows no critical habitat on site. This is positive, but a Phase I Environmental Site Assessment (ESA) should include a desktop review of NJDEP Landscape Project data to confirm the absence of state-listed threatened or endangered species habitats.
• Brownfield/Superfund: The site is clear of any nearby brownfield or superfund sites. While this mitigates environmental liability risk, it also means the project is not eligible for the