⚡ 718 JACOB HARRIS AVE

Site Diligence Analysis: 718 JACOB HARRIS AVE, Gloucester, NJ

As a senior BESS site evaluation analyst for Sunland America Corp, I have performed a comprehensive diligence analysis for the property located at 718 JACOB HARRIS AVE in Gloucester County, Elk Township, NJ. This analysis focuses on the suitability of the 27.32-acre parcel (APN: 0804_30_14.01) for a distribution-scale (≤5MW) or utility-scale Battery Energy Storage System project.

1. Site Access & Topography

• Road Access Quality and Equipment Delivery Feasibility: The property benefits from "Public" road access, which is a significant advantage, ensuring reliable ingress and egress without immediate private road maintenance or easement negotiation complexities. Given the "Good" buildability and 14.93 buildable acres, there appears to be ample space for heavy equipment maneuvering, including large transformers, battery containers, and construction vehicles. The "POI Onsite" designation further suggests that the point of interconnection is either directly on the property or immediately adjacent, simplifying internal site access and reducing the need for extensive internal road development.
• Likely Terrain Characteristics: Gloucester County, NJ, particularly in areas zoned Commercial (Office), typically features relatively flat to gently rolling terrain, often with some degree of prior grading or development. The "Good" buildability rating supports this, indicating that significant earthwork for site preparation is unlikely to be required, which helps control civil engineering costs and timelines.
• Heavy Equipment Access: With public road access and sufficient buildable acreage, heavy equipment such as cranes, flatbed trucks for battery containers, and transformer delivery vehicles should have unhindered access to the site. This is a strong positive for construction logistics.
• Access Easement Concerns: As road access is public, external access easements are not an immediate concern. However, internal site access from the public road to the specific BESS pad location may require internal access roads, which should be designed to accommodate heavy loads. No specific access easement concerns are noted for the property itself, but this should be confirmed during a site visit and survey.

2. Environmental Constraints

• FEMA Flood Zone Designation: The FEMA Flood Zone designation is currently Unknown. This is a critical data gap that requires immediate investigation. Siting a BESS within a 100-year floodplain (AE or VE zones) would necessitate elevated foundations, extensive floodproofing measures, and potentially higher insurance premiums, significantly increasing project costs and complexity. A site visit and review of FEMA flood maps are essential.
• Wetlands Presence and Setback Requirements: Wetlands presence is also Unknown. This is another critical environmental unknown. The presence of state or federally protected wetlands would trigger extensive permitting processes (e.g., USACE Section 404, NJDEP Freshwater Wetlands Protection Act), require significant setbacks, and could severely limit the usable buildable area, potentially rendering the site unfeasible. A detailed wetlands delineation study is a high-priority next step.
• Critical Habitat / Endangered Species Risk: The data indicates "None" for Critical Habitat, which is a positive finding, reducing the risk of delays or restrictions related to endangered species protection.
• Brownfield/Superfund Status: The data notes "2 site(s) within ~2 mi" for Brownfield/Superfund. It is crucial to clarify if *this specific parcel* is designated as a brownfield. If the parcel itself is a designated brownfield, it could qualify for the 10% IRA Brownfield ITC adder, which is a significant financial incentive. However, if the parcel is not a brownfield but merely *near* one, it poses a potential risk of contamination migration onto the site or increased scrutiny during environmental review. A Phase I Environmental Site Assessment (ESA) is required to determine the site's environmental history and potential for contamination.
• Chesapeake Bay Critical Area Implications: The property is located in New Jersey, and therefore, "N/A (non-MD)" for Chesapeake Bay Critical Area, eliminating this specific regulatory concern.
• Pipeline Proximity Safety Considerations: There are "None within ~3 miles" for pipeline proximity, which is excellent. This eliminates a significant safety concern and avoids potential setback requirements or complex permitting associated with high-pressure gas or hazardous liquid pipelines.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The GLASSBORO substation is exceptionally close at 0.631 miles, with a Max Voltage of 69 kV. This proximity is a major advantage, minimizing interconnection line costs and potential right-of-way issues.
• Nearest Transmission Line: A 230kV transmission line (ATLANTIC CITY ELECTRIC CO) is located at 0.0 mi, indicating it is either on-site or immediately adjacent. This is an outstanding asset, providing potential for future expansion or direct transmission-level interconnection if economically viable for larger projects.
• Recommended Interconnection Voltage: The specified IX Voltage is 12.9 kV, which is a distribution voltage. For a distribution-scale project (≤5MW), interconnecting at 12.9 kV is the most logical and cost-effective approach, leveraging the existing distribution infrastructure. However, given the immediate proximity to a 230kV transmission line, Sunland America Corp should evaluate the potential for a future transmission-level interconnection for larger projects, as this could offer greater capacity and market access. For the current scope, 12.9 kV distribution is recommended.
• Estimated Interconnection Cost Range and Timeline: Given the very short distance to the substation (0.631 miles) and the on-site transmission line, physical interconnection costs for a 12.9 kV distribution tie-in should be relatively low, likely in the range of $500,000 - $1,500,000, depending on required upgrades at the substation and feeder. However, this estimate does not include network upgrades. The timeline will be dictated by Atlantic City Electric (ACE) and the PJM interconnection queue.
• Utility-Specific IX Process and Typical Queue Times: Atlantic City Electric (ACE) operates within the PJM Interconnection RTO. PJM's interconnection queue is known for its lengthy study processes, often taking 2-4 years or more for larger projects. For a distribution-level project, ACE's internal process may be somewhat faster but still subject to PJM's overall framework. Early engagement with ACE's interconnection team is critical to understand specific local requirements and estimated timelines.
• Likely Feeder Configuration: The 12.9 kV IX voltage indicates interconnection to a distribution feeder. A detailed feeder analysis is required to determine its capacity, existing load, and potential for hosting a 5MW BESS without significant upgrades.

4. Regulatory & Zoning Analysis

• Authority Having Jurisdiction (AHJ) and its Type: The primary AHJ is Elk Township, Gloucester County, NJ. This is a municipal-level authority responsible for local zoning, planning, and building permits.
• Current Zoning for BESS Compatibility: The current zoning is Commercial (Office) - Office Bldg (General) (Code: M-1). It is highly unlikely that a BESS, which is typically considered an industrial or utility-scale energy facility, would be permitted "by-right" in an M-1 Office zone. This is a significant regulatory hurdle.
• Recommended Permitting Pathway: Given the M-1 zoning, the most probable permitting pathway will be a Conditional Use Permit (CUP) or Special Use Permit (SUP). This process involves a public hearing, demonstrating compliance with specific conditions, and gaining approval from the Township Planning Board or Zoning Board of Adjustment. A variance would be a less desirable and more challenging pathway, typically reserved for minor deviations.
• Known Setback Requirements: Specific setback requirements for BESS in Elk Township are Unknown. These will need to be thoroughly investigated within the Township's zoning ordinance. Typical setbacks for BESS projects can range from 50-200 feet from property lines, residential structures, and public roads, impacting the usable buildable area.
• Reference Specific State/County Regulations: While New Jersey has state-level energy policies encouraging renewable energy, local zoning ordinances in Elk Township will govern the specific siting and permitting of the BESS. The New Jersey Board of Public Utilities (NJBPU) may also have oversight for certain aspects of energy projects.
• Moratorium or Restriction Risks: Any known moratoriums or restrictions on BESS or similar industrial uses in Elk Township are Unknown. This should be verified during initial outreach to the Township planning department, as a moratorium could halt project development indefinitely.

5. IRA/ITC Incentive Analysis

• Opportunity Zone Eligibility: The property is designated "No" for Opportunity Zone eligibility, meaning no additional 10% ITC adder from this category.
• Energy Community Status: The property is designated "No" for Energy Community status, meaning no additional 10% ITC adder from this category.
• Low-Income Community Qualification: The property is designated "No" for Low-Income Community qualification, meaning no additional 10% ITC adder from this category.
• Calculate Potential Cumulative ITC Adder Percentage: Based on the current data, the project would qualify for the base 30% Investment Tax Credit (ITC). There are no additional adders confirmed at this time. However, if the Phase I ESA confirms that *this specific parcel* is a designated brownfield, it could qualify for an additional 10% Brownfield ITC adder, bringing the total to 40%. This potential brownfield status is the only current pathway to an adder.

6. BESS Score & Rationale

BESS Suitability Score: 68/100

• Location (17/20): Excellent public road access and "Good" buildability with 14.93 buildable acres. The "POI Onsite" is a significant advantage. The location is well-suited for construction and operation logistics.
• Grid Access (24/25): Outstanding. Proximity to the GLASSBORO substation (0.631 miles) and an on-site 230kV transmission line are major assets. This significantly reduces interconnection costs and offers future scalability. The 12.9 kV distribution voltage is appropriate for a 5MW project.
• Environmental (8/15): Significant deductions due to critical unknowns: FEMA Flood Zone (Unknown) and Wetlands (Unknown). These could be project killers or significantly increase costs. The potential for brownfield status (2 sites within 2 mi) is a double-edged sword – a risk if not on-site, an incentive if it is. Lack of critical habitat is a positive.
• Regulatory (9/15): Challenging. M-1 Commercial (Office) zoning is not compatible with BESS by-right, necessitating a CUP/SUP process. Setback requirements are unknown. This will require significant time, community engagement, and legal/planning expertise.
• Incentives (8/15): Currently only qualifies for the base 30% ITC. No Opportunity Zone, Energy Community, or Low-Income Community adders. The potential for a 10% Brownfield adder is a significant "if" that needs immediate verification.
• Buildability (2/10): The data states "Good" buildability and 14.93 buildable acres, which is positive. However, without knowing flood zones or wetlands, the *