⚡ 106 11TH AVE

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 0123_81_7 (106 11TH AVE, Weymouth Township, NJ)

This report provides a comprehensive due diligence analysis for the subject property in Weymouth Township, NJ, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: Initial desktop review indicates the property is located on 11th Avenue, which appears to be an unpaved, potentially private dirt or gravel road. Access from a major paved thoroughfare, such as the Black Horse Pike (US-322) or Route 50, would involve navigating several miles of secondary and local roads. The quality of these access roads is a significant concern for the delivery of heavy equipment. A full route survey would be required to confirm bridge weight limits, turning radii, and road conditions.

Terrain & Equipment Access: The site is heavily wooded and appears to be relatively flat, which is characteristic of the Southern New Jersey coastal plain. While the flat topography is advantageous for construction, the dense tree cover will necessitate significant clearing and grading, adding to site preparation costs. The primary challenge will be upgrading the final stretch of 11th Avenue to support the weight of a heavy-haul truck carrying a 50-ton transformer or fully-loaded battery containers. The current state of the road is likely insufficient.

Easement Concerns: A critical unknown is the legal status of 11th Avenue. We must verify if it is a public right-of-way or if a private access easement is required from adjoining landowners. Securing a new, permanent, all-weather access easement could be a time-consuming and costly negotiation. The 5.0 buildable acres (out of 5.35 total) suggests a portion of the lot may be encumbered by an existing easement or unbuildable due to frontage/access issues, which requires title review.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone designation is currently unknown and represents a critical data gap. A formal flood zone determination is required immediately. Similarly, the presence of wetlands is unknown but highly probable given the site's undeveloped, wooded nature in this region of New Jersey. A desktop environmental screening followed by a formal wetland delineation will be necessary. Any identified wetlands will trigger significant state (NJDEP) and federal (USACE) setbacks and permitting requirements, potentially rendering the 5.0 buildable acres unusable.

Critical Habitat & Protected Areas: While the data indicates no specific critical habitats, the entire parcel is located within the jurisdiction of the New Jersey Pinelands Commission. The Pinelands National Reserve is a unique, protected ecosystem. Development is strictly controlled by the Pinelands Comprehensive Management Plan (CMP), which supersedes many local regulations. This is the single most significant environmental constraint and represents a potential fatal flaw for the project.

Other Considerations:

• Brownfield/Superfund: The site is not a brownfield, which means we cannot claim the 10% IRA brownfield adder. However, this also signifies a lower risk of legacy contamination and associated cleanup liabilities.
• Pipeline Proximity: No major pipelines are located nearby, eliminating risks related to pipeline safety setbacks and potential co-location conflicts.
• Chesapeake Bay Critical Area: Not applicable as the site is in New Jersey.

3. Grid Infrastructure & Interconnection

Substation & POI: The site's primary strength is its exceptional proximity to the DOROTHY substation, located just 0.135 miles away. This drastically reduces the cost and complexity of the generator lead line. The substation's maximum voltage of 138 kV indicates it is a significant node on the grid, likely with both transmission and distribution infrastructure.

Interconnection Strategy: For a ≤5MW BESS, a transmission-level (138 kV) interconnection is neither practical nor cost-effective. The recommended pathway is to interconnect to a distribution feeder (likely 12.47 kV or 24.9 kV) originating from the Dorothy substation. The interconnecting utility is presumed to be Atlantic City Electric (ACE), an Exelon company, operating within the PJM Interconnection RTO. (Requires Verification).

Cost & Timeline: The short distance to the Point of Interconnection (POI) suggests a relatively low "gen-tie" construction cost, potentially under $750,000. However, the total interconnection cost is highly dependent on the available capacity of the local distribution feeder and the required utility upgrades at the substation, which could still be substantial. The PJM interconnection queue process is notoriously backlogged. Even for a distribution-connected project processed by the utility under FERC guidelines, the timeline from application to commercial operation can realistically exceed 36 months.

Feeder Configuration: The specific feeder must be identified via a pre-application request to ACE. We need to assess its current loading, protection schemes, and whether it has sufficient capacity to accommodate a 5MW injection/withdrawal without causing voltage or thermal violations. This is a primary technical unknown.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The project is subject to a dual-jurisdiction review. The primary AHJs are Weymouth Township for local zoning and site plan approval, and the New Jersey Pinelands Commission for compliance with the Pinelands CMP.

Zoning Compatibility: The zoning designation "PFA-10" almost certainly stands for "Pinelands Forest Area." This is one of the most restrictive zoning districts within the Pinelands. The intent of this zone is conservation and extremely low-density residential use. Utility-scale energy infrastructure, including BESS, is not a permitted use by-right and is highly unlikely to be considered compatible with the CMP's land use goals.

Permitting Pathway: A standard Conditional Use Permit (CUP) or Special Use Permit (SUP) pathway is not viable here. The project would require, at minimum:

1. A formal application to the Pinelands Commission, which would likely be denied as inconsistent with the CMP.
2. A use variance from the Weymouth Township Zoning Board of Adjustment, which carries a very high burden of proof.

5. IRA/ITC Incentive Analysis

The project's eligibility for Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) is a key financial driver.

• Base ITC: 30%
• Opportunity Zone: No (0% adder).
• Energy Community: Yes. The site qualifies under both the "Coal Closure" and "Fossil Fuel Employment" criteria, securing a 10% adder.
• Low-Income Community: No (0% adder).

Cumulative ITC: The project is eligible for a total potential ITC of 40% (30% base + 10% Energy Community). This is a strong incentive that improves project economics, but it cannot overcome fundamental land use and permitting flaws.