⚡ TIMBER TRL

Sunland America Corp. - BESS Site Diligence Analysis

Property Address: TIMBER TRL, Columbia County, PA

Analyst: Senior BESS Site Evaluation Analyst

Date: October 26, 2023

Site Access & Topography

The property benefits from Public Road Access, which is a significant advantage for equipment delivery and ongoing operations. The indication of "POI Onsite" (Point of Interconnection Onsite) further streamlines access logistics, minimizing the need for extensive new access road construction within the property boundaries. Given the substantial total acreage of 416.54 acres and the "Buildability: OK" assessment, the terrain is likely manageable, suggesting either relatively flat ground or areas with gentle slopes that can accommodate large-scale construction.

The feasibility for heavy equipment delivery, including transformers, battery containers, and other large components, appears high due to the public road access and the "Buildability: OK" status. This implies that standard heavy-haul routes should be able to reach the site without undue difficulty. However, a detailed geotechnical survey will be required to confirm soil bearing capacity for heavy equipment pads and foundations. No explicit access easement concerns are noted in the provided data, but this will need to be verified during the title review phase to ensure unencumbered access from the public road to the proposed BESS footprint. The large parcel size offers considerable flexibility in siting the BESS to minimize earthwork and optimize internal access roads.

Environmental Constraints

Several critical environmental data points are currently Unknown, posing significant risks that require immediate investigation. The FEMA Flood Zone designation is a primary concern; if the site falls within a 100-year (AE or VE) flood zone, it could necessitate elevated equipment pads, extensive floodproofing measures, or even render portions of the site unusable, significantly increasing costs and complexity. Similarly, the presence of Wetlands is an unknown. If wetlands are identified, federal (USACE) and state (PADEP) permitting would be required, potentially leading to lengthy delays, costly mitigation, and significant setback requirements that could reduce the developable area.

Positively, the analysis indicates No Critical Habitat / Endangered Species, No Brownfield/Superfund sites within 2 miles, and No Pipeline Proximity within 3 miles, which are all favorable for environmental permitting and safety. The absence of brownfield status means no IRA brownfield bonus, but it also eliminates the associated remediation risks. The property is not within the Chesapeake Bay Critical Area, which simplifies regulatory compliance. However, the unknowns regarding flood zones and wetlands are substantial enough to warrant a cautious approach until a Phase I Environmental Site Assessment (ESA) and a wetland delineation are completed.

Grid Infrastructure & Interconnection

The grid infrastructure at this site is exceptionally strong. The Nearest Substation (COLUMBIA) is only 0.5 miles away with a maximum voltage of 230 kV. Furthermore, a 230kV Transmission Line owned by PPL Electric Utilities Corp. is also located just 0.5 miles away. This outstanding proximity to high-voltage infrastructure is a major advantage, significantly reducing interconnection costs and construction timelines associated with new transmission or distribution line extensions.

The stated Interconnection Voltage (IX Voltage) is 69 kV with PPL Electric Utilities. This suggests an interconnection at the sub-transmission or high-voltage distribution level, which is suitable for both distribution-scale (≤5MW) and smaller utility-scale projects. Given the proximity to a 230kV substation, it's likely there's a 69kV bus or line emanating from the substation, or a direct tap onto a 69kV line. We recommend pursuing the 69 kV interconnection given the stated IX voltage, as it aligns with typical BESS project sizes and avoids the higher complexity and cost of direct 230 kV transmission interconnection unless the project scales significantly.

Based on the extremely short distance, the estimated interconnection cost range should be on the lower end for a project of this scale, likely in the $1M - $3M range, primarily for a new switchyard, protection equipment, and a short gen-tie line. The timeline, however, will be heavily influenced by PPL Electric Utilities' specific interconnection queue process and typical study durations, which are generally known to be lengthy (e.g., 18-36 months for full study completion). The likely feeder configuration is Requires Verification, but given the proximity to a major substation, it could be a robust radial or part of a looped system, offering good reliability.

Regulatory & Zoning Analysis

This section presents the most significant challenge for the project. The Authority Having Jurisdiction (AHJ) is listed as "Found (unnamed)" but is within Columbia County, PA. It is critical to immediately identify the specific municipality (township or borough) that holds zoning authority over the property, as local zoning ordinances will dictate project feasibility.

The current zoning is identified as Residential (Code: Rural/Agricultural Residence) and Zoning (Regrid): A (likely Agricultural). This is a major red flag. Utility-scale BESS projects are typically classified as industrial, utility, or heavy commercial uses and are rarely permitted by-right in residential or agricultural zones. The most likely permitting pathway will be a Conditional Use Permit (CUP) or Special Exception, which requires extensive public hearings, demonstrating compliance with specific criteria, and often faces significant local opposition. A rezoning application, which is a lengthy, expensive, and high-risk process, may even be required if a CUP/SUP is not an option.

Known setback requirements for BESS in this jurisdiction are Requires Verification. Pennsylvania state regulations (e.g., Act 129 for energy efficiency) do not typically dictate local BESS siting, leaving it to municipal discretion. Given the residential/agricultural zoning, we anticipate stringent setback requirements from property lines, residences, and public roads, which could limit the developable area. There is a significant risk of local moratoriums or restrictions on BESS development, especially in rural areas where residents may be unfamiliar with the technology or concerned about visual impact, noise, or safety. This zoning incompatibility is a primary go/no-go decision point.

IRA/ITC Incentive Analysis

The property's eligibility for Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) is favorable.

• Opportunity Zone Eligibility: The property is designated as No for Opportunity Zone eligibility, meaning no additional ITC adder from this category.
• Energy Community Status: The property is located in an Energy Community (Coal Closure). This is a significant advantage, qualifying the project for a 10% ITC adder. This adder is crucial for enhancing project economics.
• Low-Income Community Qualification: The property is designated as No for Low-Income Community qualification, meaning no additional ITC adder from this category.

Assuming the project meets prevailing wage and apprenticeship requirements (which is standard practice for Sunland America Corp.), the base ITC is 30%. With the Energy Community adder, the potential cumulative ITC adder percentage is 10%, resulting in a total ITC of 40% (30% base + 10% Energy Community). This substantial tax credit significantly improves project financial viability and competitiveness.

BESS Score & Rationale

Overall BESS Suitability Score: 71/100

• Location (0-20): 18/20
  • Rationale: Excellent acreage (416.54 acres) provides ample space and flexibility. Public road access and "POI Onsite" are ideal for construction and operations. "Buildability: OK" suggests favorable terrain. Only minor deduction for potential internal access road development.
• Grid Access (0-25): 24/25
  • Rationale: Outstanding proximity to a 230kV substation (0.5 mi) and 230kV transmission line (0.5 mi). The 69kV IX voltage is a suitable target for distribution-scale projects. This minimizes gen-tie costs and construction time. Minor deduction for unknown available capacity and PPL's typical interconnection queue times.
• Environmental (0-15): 7/15
  • Rationale: Positive aspects include no critical habitat, pipelines, brownfield, or Chesapeake Bay issues. However, the critical unknowns regarding FEMA Flood Zone and Wetlands introduce significant risk and uncertainty, heavily impacting this score. These could be deal-breakers if adverse.