⚡ 150 PENNS GROVE AUBURN RD

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 1702_48_7_QFARM (Carneys Point, NJ)

This report provides a comprehensive due diligence analysis for the property located at 150 Penns Grove Auburn Rd, Carneys Point, NJ. The analysis evaluates the site's suitability for a distribution or utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access: The site has direct frontage on Penns Grove Auburn Road, a two-lane county road. Based on aerial imagery, this road appears to be paved and in reasonable condition, likely capable of supporting heavy truck traffic, including flatbeds for battery containers and transformers. However, a formal road study would be required to confirm weight limits and the condition of any bridges or culverts on the delivery route.

Terrain & Equipment Access: The topography in this region of Southern New Jersey is generally flat with minimal elevation change, which is ideal for BESS construction as it significantly reduces civil engineering and site grading costs. The primary concern is the discrepancy between the total parcel size (16.21 acres) and the stated buildable area (7.45 acres). This suggests that over half the property is constrained. Access from the main road to the designated buildable area appears straightforward, but an access easement will need to be formally defined and recorded as part of the site control agreement. The ground conditions must be verified with a geotechnical study to ensure they can support the heavy foundation loads of transformers and battery enclosures.

Easement Concerns: No existing access easements for third parties appear to cross the property based on a preliminary review, but a full title search is required for verification. A new access easement from Penns Grove Auburn Road to the project footprint will need to be secured from the landowner.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap and a potential fatal flaw. Given the site's relative proximity to the Delaware River and associated tributaries, there is a moderate to high risk that portions of the property, particularly the non-buildable areas, could be within a designated flood hazard area (e.g., Zone A or AE). Siting critical infrastructure within a 100-year floodplain is highly discouraged and often prohibited by local ordinances. Immediate verification using FEMA's Map Service Center is required.

Wetlands: The presence of wetlands is Unknown but highly probable. The significant reduction from total to buildable acreage (a 54% loss) strongly indicates the presence of environmental constraints, with wetlands being the most likely cause in this region. Development within wetlands is heavily regulated by the New Jersey Department of Environmental Protection (NJDEP) and the Army Corps of Engineers, requiring extensive permitting and often mandating large, prohibitive setbacks (e.g., 50-150 ft buffers). A formal wetland delineation is a mandatory and urgent next step.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This reduces the risk of lengthy and complex endangered species surveys or consultations with the U.S. Fish and Wildlife Service.

Site Contamination: The site is not a known brownfield or superfund location. While this removes the 10% IRA brownfield bonus, it is a net positive as it eliminates the risk of discovering contamination during construction, which can lead to costly remediation and project delays. A Phase I Environmental Site Assessment (ESA) is still recommended as standard practice.

Pipeline Proximity: No major gas transmission pipelines are located within three miles, mitigating risks associated with pipeline-related setbacks, safety protocols, and potential easement conflicts.

3. Grid Infrastructure & Interconnection

Substation Proximity: The site's proximity to the PENNSGROVE substation (0.337 miles) is its single greatest asset. This extremely short distance dramatically reduces the cost and complexity of the generator lead line. The substation's maximum voltage of 69 kV makes it suitable for a utility-scale BESS project. Available capacity is unknown and must be determined through a formal interconnection application with the utility, which is presumed to be Atlantic City Electric (ACE), an Exelon company.

Transmission Proximity: A 230 kV transmission line is located 0.9 miles away. While a viable option for a very large project, interconnecting at 230 kV would be substantially more expensive and complex, requiring a dedicated switchyard.

Recommended Interconnection: The recommended Point of Interconnection (POI) is at the PENNSGROVE substation. For a distribution-scale project (≤5MW), a 12.47 kV feeder-level interconnection would be pursued. For a larger utility-scale project, a direct 69 kV interconnection into the substation bus would be the most efficient pathway.

Cost & Timeline Estimate: Given the sub-half-mile distance, the interconnection cost could be in the lower range, estimated at $1.5M - $4M. However, this is highly dependent on the required substation upgrades (e.g., new bay, breaker upgrades, bus work) which can only be determined by a utility system impact study. The interconnecting utility is within the PJM Interconnection territory. PJM's interconnection queue is notoriously backlogged; timelines from application to commercial operation can easily exceed 3-4 years.

Feeder Configuration: Requires Verification. A pre-application report with the utility is necessary to identify the specific distribution feeder(s) originating from the PENNSGROVE substation and to get an initial assessment of their hosting capacity.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): Carneys