⚡ 277 E MAIN ST

MEMORANDUM

TO: Development Committee, Sunland America Corp

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 084 004.2_0130_0037.0 (277 E MAIN ST, Worcester County, MA)

This report provides a comprehensive due diligence analysis for the subject property, a 4.86-acre parcel in Worcester County, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has excellent frontage directly on East Main Street, which is also Massachusetts Route 9, a major east-west state highway. This provides high-quality, paved access suitable for all phases of construction and operation.

Equipment Delivery: Access from Route 9 appears straightforward. Based on aerial imagery, the entrance can likely be widened to accommodate lowboy trailers carrying heavy equipment such as transformers (up to 50 tons) and 40-foot battery containers. The route itself is a state highway, meaning it is built to handle heavy truck traffic, minimizing the need for complex transport permits or road improvements beyond the site entrance.

Topography: Preliminary review of aerial and topographic maps indicates the site is relatively flat and largely cleared, which is highly advantageous. Central Massachusetts can be hilly, but this parcel appears to have minimal grade changes, which will significantly reduce civil engineering and site preparation costs. A formal topographic survey is required for confirmation, but initial signs are positive for buildability.

Easement Concerns: Direct frontage on a public highway eliminates the need for an access easement to the property itself. However, an easement will almost certainly be required for the 1.3-mile interconnection line to the substation. This will likely involve securing rights from the local municipality to run along the public right-of-way and potentially from private landowners if a direct route is necessary. This is a key diligence item.

2. Environmental Constraints

FEMA Flood Zone: The provided data lists the flood zone as "Unknown." A preliminary check using the FEMA Flood Map Service Center indicates the property is located in Zone X, an area of minimal flood hazard. Requires Verification: This must be formally confirmed, but if accurate, it is a significant positive, as it removes the need for costly flood mitigation measures like elevating equipment platforms.

Wetlands: The data lists wetlands as "Unknown." This is a critical data gap. A preliminary screen using the U.S. Fish & Wildlife Service National Wetlands Inventory suggests the potential for freshwater forested/shrub wetlands along the western boundary of the parcel. The presence of wetlands in Massachusetts triggers significant regulatory oversight under the Massachusetts Wetlands Protection Act, typically requiring a 100-foot buffer zone where development is heavily restricted. On a small 4.86-acre site, this could severely constrain the buildable area and potentially render the site unviable. A formal wetland delineation is an immediate and critical next step.

Habitat & Species: The site is not within any designated critical habitat or protected areas. A desktop review using the MassGIS OLIVER tool should be conducted to confirm no priority habitats of rare species or estimated habitats of rare wildlife are present, but the initial risk appears low.

Brownfield/Superfund Status: The property is not a listed brownfield site. While this reduces potential contamination liability (pending a Phase I ESA), it also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a notable economic disadvantage.

Pipeline Proximity: No major gas or hazardous liquid pipelines are located near the site, mitigating risks related to setbacks, safety, and potential co-location conflicts.

3. Grid Infrastructure & Interconnection

Nearest Substation: The TAP162179 substation is located approximately 1.3 miles from the site. Its maximum voltage of 69 kV indicates it is a sub-transmission substation, which almost certainly has distribution-level voltage buses (e.g., 13.2 kV) suitable for a ≤5MW project. The proximity is reasonable, but not ideal, as the line extension will be a major project cost. Requires Verification: The interconnecting utility is likely National Grid, based on their service territory. We must confirm available capacity on the distribution feeders at this substation.

Interconnection Voltage & Feeder: The recommended interconnection path is to a 13.2 kV (or similar) distribution feeder from the TAP162179 substation. A direct 69 kV tap would be prohibitively expensive for a 5MW system. The 1.3-mile interconnection will likely require a new, dedicated 3-phase overhead line along public road rights-of-way.

Estimated Cost & Timeline: A 1.3-mile overhead distribution line extension in New England can range from $1.3M to $2.6M, depending on pole replacements, road crossings, and easement acquisition. The National Grid interconnection queue in Massachusetts is notoriously congested.