⚡ 2268 ROCKVILLE RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 47-1-0-50-0 (Rockville, VA)

This report provides a comprehensive due diligence analysis for the 121.04-acre property located at 2268 Rockville Rd, Goochland County, VA. The analysis evaluates the site's suitability for a Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Rockville Rd (VA-622), a two-lane paved county road. Based on aerial imagery, the road appears to be in fair condition and is a designated truck route, suggesting it can likely accommodate heavy haul trucks required for BESS component delivery. However, a detailed route survey is necessary to confirm the absence of weight-restricted bridges, tight turning radii, or low-hanging utility lines between the site and major highways like I-64.

Terrain & Equipment Access: The topography in this region of the Virginia Piedmont is characterized by gently rolling hills. A preliminary review suggests moderate elevation changes across the large parcel, but ample areas appear to have slopes suitable for BESS development (typically <5%). Heavy equipment, including cranes for setting transformers and battery containers, should be able to access the site directly from Rockville Rd. A formal topographical survey is required to identify the most cost-effective location for the pad site to minimize earthwork.

Easement Concerns: While the property has direct road frontage, the ideal buildable area may be set back from the road to meet noise and visual buffer requirements. A title search is mandatory to confirm that no restrictive covenants or third-party access easements encumber the property. Furthermore, an access easement will need to be secured from the property owner for the 0.5-mile route to the target 230kV transmission line for the interconnection gen-tie line. This is a critical point of negotiation.

2. Environmental Constraints

Flood Zone & Wetlands: Requires Verification. The FEMA flood zone and wetlands status are currently unknown. This represents a significant data gap and a primary development risk. A desktop screening using the FEMA Flood Map Service Center and National Wetlands Inventory (NWI) must be conducted immediately. If the site contains areas within a 100-year floodplain (Zone A/AE) or designated wetlands, those areas and their associated buffers will be undevelopable, reducing the buildable acreage and potentially complicating site layout. A formal wetland delineation will be required to confirm NWI data.

Habitat & Protected Species: The data indicates no critical habitats or protected areas on or immediately adjacent to the site, which is a significant positive. A Phase I Environmental Site Assessment (ESA) will still be required to formally document this and screen for any unmapped sensitive species.

Site Contamination: The absence of nearby brownfield or superfund sites is positive from a liability and cleanup cost perspective. However, this also means the project is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage.

Chesapeake Bay Act: While not in Maryland's Critical Area, Goochland County is subject to Virginia's Chesapeake Bay Preservation Act. This will impose stringent stormwater management requirements (SWPPP) and may require setbacks from any on-site perennial streams or water bodies designated as Resource Protection Areas (RPAs), further constraining the buildable envelope.

Pipeline Proximity: The lack of any gas pipelines within a three-mile radius is a major safety and design advantage, eliminating risks and setback requirements associated with pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission Lines: The nearest substation, Short Pump, is 4.3 miles away. At this distance, a new distribution feeder for a ≤5MW project would be prohibitively expensive (likely $1M+ per mile). The most viable Point of Interconnection (POI) is the Virginia Electric & Power Co (Dominion Energy) 230kV transmission line located just 0.5 miles from the property boundary.

Recommended Interconnection: The only economically feasible path is a transmission-level interconnection at 230kV. This fundamentally changes the project scope from our typical distribution-scale focus to a much larger utility-scale project (likely 20MW+ to justify the costs). This site is not suitable for a ≤5MW project.

Cost & Timeline: A 230kV interconnection is a high-cost, long-lead-time endeavor. It will require constructing a new three-breaker ring bus or switchyard, which can cost between $5 million and $15 million. The interconnection process will be through the PJM RTO queue, which is currently experiencing significant backlogs. The timeline from application to commercial operation is realistically 3 to 5 years.

Utility & Process: The interconnecting utility is Dominion Energy, and the RTO is PJM. The PJM Generation Interconnection process is complex and requires significant engineering deposits and studies (Feasibility, System Impact, Facilities). This is a much more capital-intensive process than a distribution-level interconnection.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is Goochland County. The property is zoned A-2 (Agricultural, General). BESS is not a "by-right" use in this district.

Permitting Pathway: The project will require a discretionary Conditional Use Permit (CUP) from the Goochland County Board of Supervisors. The CUP process involves public notification, a staff report, a hearing before the Planning Commission, and a final hearing before the Board of Supervisors. This pathway carries significant entitlement risk, as approval is not guaranteed and can be influenced by public opposition.

Setbacks & Regulations: Requires Verification. Specific BESS setbacks are not explicitly defined in the Goochland ordinance and would likely be determined during the CUP process. We should anticipate substantial setbacks from property lines (100-200 ft) and nearby residences (500-1,000 ft), as well as requirements for visual screening, noise mitigation, and a decommissioning plan.

Moratorium Risk: As a rural county experiencing development pressure from the Richmond suburbs, Goochland could be sensitive to large-scale energy projects. There is a moderate risk of community opposition or the future imposition of a moratorium on such facilities.

5. IRA/ITC Incentive Analysis

This site performs very poorly on ITC adder eligibility, which severely impacts project economics.

• Opportunity Zone: No. (0% adder)
• Energy Community: No.