⚡ 123 W COHAWKIN RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Mickleton" - 123 W COHAWKIN RD, Gloucester, NJ

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) on the 12.17-acre parcel located at 123 W Cohawkin Rd, East Greenwich Township, NJ. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property has direct frontage on West Cohawkin Road (County Route 667), a two-lane paved road that appears to be in good condition. This road provides adequate access for standard construction vehicles. However, a detailed swept-path analysis is required to confirm that oversized and overweight vehicles, such as those carrying main power transformers (MPTs) and BESS container units, can navigate turns from major highways (like I-295, located nearby) onto the local road network and into the site.

Terrain & Equipment Delivery: As the parcel is currently zoned and used for agriculture, the topography is expected to be predominantly flat with minimal grade changes, which is ideal for BESS construction as it reduces civil engineering and earthwork costs. The 7.73 buildable acres should provide sufficient space for equipment laydown and construction staging. The primary challenge will be constructing a new, robust access road from W Cohawkin Rd into the project area, capable of supporting crane loads and heavy truck traffic.

Easement Concerns: A formal access easement from the public right-of-way across the parcel frontage to the proposed BESS footprint will need to be secured and recorded. We must also verify that no existing utility or access easements encumber the proposed development area. A title search is a critical next step to identify any such restrictions.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical and immediate data gap. Development within a Special Flood Hazard Area (e.g., Zone AE) would introduce significant design challenges, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing costs and potentially rendering the project infeasible. A FEMA FIRMette must be obtained immediately to assess this risk.

Wetlands: The presence of wetlands is also Unknown. Given the agricultural use and proximity to various creeks in Gloucester County, there is a moderate to high probability of wetlands or hydric soils on site. New Jersey Department of Environmental Protection (NJDEP) regulations are stringent, with significant buffer requirements (up to 150 feet for exceptional value wetlands). A desktop National Wetlands Inventory (NWI) screening followed by a formal wetlands delineation by a certified consultant is required to determine the net buildable area and potential project layout constraints.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a formal U.S. Fish and Wildlife Service IPaC (Information for Planning and Consultation) report should be run to screen for federally listed endangered species. A review of the NJDEP's Landscape Project data is also necessary to check for state-level species of concern.

Brownfield/Superfund Status: The presence of a Superfund site within two miles is noted. This does not mean our parcel is contaminated, but it necessitates a Phase I Environmental Site Assessment (ESA) to confirm no Recognized Environmental Conditions (RECs) exist from historical agricultural use (e.g., pesticide/herbicide application) or potential contamination migration. Crucially, the Phase I ESA will also determine if the site could qualify as a "brownfield" under IRA guidelines. If so, this would unlock a valuable 10% ITC bonus. This is a potential advantage but requires careful investigation.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's grid access is its strongest attribute. It is located only 0.65 miles from the Mickleton 230 kV Substation and 0.1 miles from an existing 230 kV transmission line. This proximity is exceptional and dramatically reduces the cost and complexity of a transmission-level interconnection. The Mickleton substation is a major node in the regional grid, suggesting it likely has the capacity to accommodate a significant BESS project.

Recommended Interconnection: For a utility-scale project (>5MW), a 230 kV transmission-level interconnection is the clear recommendation. This allows for participation in wholesale energy markets (PJM) without feeder-level constraints. For a smaller, distribution-scale project (≤5MW), there are likely 3-phase distribution lines along W Cohawkin Rd (Requires Verification). A distribution interconnect would be cheaper and faster but would cap the project size. Given the site's potential, pursuing a larger, transmission-connected project appears more strategic.

Cost & Timeline Estimate:

• Transmission (230 kV): A short tie-line (gen-tie) of less than a mile would still be a major capital expense. Estimated costs could range from $5M - $12M for the line extension, substation bay, and required upgrades. The PJM interconnection queue process is lengthy, typically taking 3-5 years from application to commercial operation.
• Distribution (e.g., 13.2 kV): If a viable feeder exists, costs would be significantly lower, likely in the $750k - $2.5M range, with a timeline of 18-36 months.

Utility & Process: The interconnecting utility is likely Atlantic City Electric or PSE&G (Requires Verification). The process will be governed by the PJM Interconnection Process. We should immediately check the public PJM queue to see if other generation projects are already in study for the Mickleton substation, which would inform us about potential congestion and upgrade costs.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): East Greenwich Township, Gloucester County.

Zoning Compatibility: There is a critical conflict in the provided data. One source lists zoning as "Agricultural/Rural - Farm," while another lists "B2" (General Business). This discrepancy must be resolved immediately by consulting the official East Greenwich Township zoning map and ordinance.

• If Agricultural/Rural, BESS is almost certainly not a by-right use. We would need to pursue a Conditional Use Permit (CUP) or a Use Variance, likely arguing that a BESS qualifies as a "public utility." This path involves public hearings and discretionary approval from the Planning/Zoning Board, introducing significant entitlement risk.
• If B2 (Business), the path might be simpler, but BESS may still require a CUP or Special Exception Permit (SUP). Business zones often have stricter design, screening, and noise standards.

Permitting Pathway & Setbacks: The recommended pathway is to assume a Conditional Use Permit (CUP) will be required. This will necessitate a comprehensive site plan application, community outreach, and expert testimony on safety (e.g., NFPA 855 compliance), noise, and visual impact. We must research the Township's specific ordinances for setback requirements from property lines, residential structures, and public roads. A preliminary review of NJ municipal codes