⚡ PRAGUE AVE

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 0111_462_3 (Prague Ave), Galloway, NJ

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 38.39-acre parcel located on Prague Ave in Galloway Township, Atlantic County, New Jersey. The analysis identifies several critical flaws that present substantial, likely insurmountable, risks to project development.

1. Site Access & Topography

Overall Assessment: Critically Flawed. The site is identified as landlocked, which represents a fatal flaw without a clear, cost-effective, and timely remedy.

• Road Access & Equipment Delivery: There is no existing road frontage or legal access to the parcel. All access for surveying, geotechnical analysis, construction, and ongoing operations & maintenance would require securing permanent, multi-parcel access easements from adjacent landowners. The feasibility of delivering heavy equipment, including concrete trucks, cranes, multi-ton battery containers, and the main power transformer, is currently zero. The negotiation for such easements is a high-risk, high-cost, and lengthy process with no guarantee of success.
• Terrain Characteristics: While specific topographic data is not provided, the site's location in the Southern New Jersey coastal plain suggests the terrain is likely flat with minimal grade changes. However, this potential advantage is completely negated by the lack of access. The significant discrepancy between the total parcel size (38.39 acres) and the reported buildable area (8.3 acres) strongly implies the presence of topographic or environmental constraints, most likely extensive wetlands.
• Easement Concerns: The property requires private easements for both physical site access and for the electrical interconnection Point of Interconnection (POI). This doubles the complexity of negotiations, as the optimal path for a road may differ from the optimal path for a gen-tie line. This process would require extensive title work, surveys, legal fees, and compensation to multiple landowners, adding significant soft costs and timeline delays to the project pro-forma.

2. Environmental Constraints

Overall Assessment: High Risk. The site presents significant, unquantified environmental risks that could render the limited buildable area unusable or economically unviable.

• FEMA Flood Zone: The flood zone designation is Requires Verification. Given the site's location in Atlantic County, proximity to the coast and associated bays is a concern. Development within a Special Flood Hazard Area (e.g., Zone AE) would trigger significant design constraints, including elevating all critical equipment, which substantially increases civil engineering and construction costs.
• Wetlands: The presence and extent of wetlands are Requires Verification. However, the reduction of a 38.39-acre parcel to only 8.3 buildable acres is a strong indicator of extensive wetlands governed by the New Jersey Department of Environmental Protection (NJDEP), which has some of the most stringent wetlands regulations in the country. A formal wetlands delineation would be required, and any development would be subject to significant buffer requirements (potentially up to 150 feet), further constraining the site layout.
• Critical Habitat / Endangered Species: The initial screening indicates no critical habitat on site. This is a positive but must be verified through a review of the NJDEP Landscape Project maps for state-listed threatened and endangered species.
• Brownfield/Superfund Status: The site is not a brownfield. This is a double-edged sword: it avoids potential environmental liability and cleanup costs, but it also means the project is not eligible for the 10% IRA brownfield tax credit adder.
• Pipeline Proximity: No pipelines are located within three miles, which is a significant safety and design advantage, eliminating concerns about pipeline-related setbacks and potential impact studies.

3. Grid Infrastructure & Interconnection

Overall Assessment: Deceptively Promising. While grid infrastructure appears ideally located, access to it is severely compromised.

• Nearest Substation: The GALLOWAY substation is only 0.319 miles from the parcel boundary. This proximity is excellent and typically indicates a strong potential for a low-cost interconnection. (Note: The provided "Max Voltage: 0 kV" is a data error; this is likely a standard distribution substation operating at voltages like 69kV/12kV). The close proximity minimizes line loss and construction costs for the gen-tie itself.
• Interconnection Voltage & Feeder: The proposed 12.9 kV interconnection voltage is a standard distribution-level voltage for Atlantic City Electric (ACE), making it ideal for a ≤5MW BESS project. The project would likely interconnect to a radial distribution feeder originating from the Galloway substation. A formal pre-application data request to ACE is necessary to obtain feeder maps and hosting capacity analysis.
• Interconnection Cost & Timeline: The short distance suggests a potentially low cost for the physical line extension (estimated $300k - $750k). However, this estimate is highly misleading. The fact that POI access requires private easements means the all-in cost and timeline are entirely dependent on landowner negotiations. Acquiring these easements could add hundreds of thousands of dollars and 12-24 months to the project, if successful at all. ACE's interconnection queue, operating within PJM, can also be lengthy, often taking 18-36 months to move from application to construction.

4. Regulatory & Zoning Analysis

Overall Assessment: Critically Flawed. The site's zoning designation represents a primary, and likely fatal, regulatory barrier.

• Authority Having Jurisdiction (AHJ): Galloway Township.
• Zoning Compatibility: The parcel is zoned R-5 (Residential). BESS facilities are industrial in nature and are fundamentally incompatible with a residential zoning district. This is not a viable "by-right" use.
• Permitting Pathway: Development would require, at minimum, a Use Variance from the Galloway Township Zoning Board of Adjustment. This is the most difficult and highest-risk entitlement to secure in