⚡ AGNESE CT

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for AGNESE CT, Barre, MA (APN: H_499)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project on a 3.08-acre parcel in Barre, Worcester County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria. The primary positive attribute is the exceptional proximity to a 115 kV substation. However, this is significantly counterbalanced by severe challenges related to residential zoning, site access, and a lack of financial incentives under the Inflation Reduction Act (IRA).

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Agnese Court, which appears via satellite imagery to be a small, potentially unpaved or private residential cul-de-sac. This presents a significant risk for project development. Standard public roads are designed to specific load-bearing and width standards, which this access point may not meet. The delivery of heavy equipment, including multi-ton transformers, switchgear, and containerized battery systems, requires wide, stable, and robust access routes. A preliminary assessment suggests Agnese Ct is likely inadequate for construction traffic and heavy-haul vehicles without substantial and costly upgrades.

Terrain & Buildability: The land use is designated as vacant residential land. Based on the topography of Worcester County, the site likely features rolling hills and is probably wooded. This will necessitate clearing, grubbing, and grading, adding to site preparation costs. The exact buildable area is unknown and will be constrained by topography, environmental setbacks, and required zoning setbacks.

Access Easements: A critical unknown is the legal status of Agnese Court. If it is a private road, a formal, permanent access easement from the owner(s) of the road will be required for construction and ongoing operations. Furthermore, if the road itself is insufficient, an alternative access route across adjacent parcels may be needed, which would require negotiating and purchasing additional easements. This process can be time-consuming and expensive, with no guarantee of success.

2. Environmental Constraints

Flood & Wetlands: The FEMA flood zone and wetlands status are currently unknown. This represents a major data gap and a potential fatal flaw. Any designation within a 100-year floodplain (e.g., Zone A or AE) would impose significant design constraints, requiring all equipment to be elevated above the Base Flood Elevation, drastically increasing costs. The likely presence of wetlands in this region of Massachusetts is high; any delineated wetlands would trigger state (MA Wetlands Protection Act) and local (Barre Conservation Commission) jurisdiction, requiring significant setbacks (typically 100 feet or more) that would reduce the buildable area.

Habitat & Protected Species: The data indicates no critical habitats or protected areas on site, which is a positive finding. A desktop review using the USFWS IPaC tool should still be conducted to formally document this.

Contamination & Brownfield Status: The site is not a designated brownfield, meaning it is ineligible for the 10% IRA brownfield tax credit adder. The presence of two superfund/brownfield sites within a two-mile radius is a minor concern that will be noted in a Phase I Environmental Site Assessment (ESA), but the risk of contamination migration to the subject property is likely low.

Other Constraints: The site is not within the Chesapeake Bay Critical Area. No pipelines or gas wells are in the immediate vicinity, eliminating risks associated with those features.

3. Grid Infrastructure & Interconnection

Proximity to Infrastructure: This is the site's strongest attribute. It is located just 0.3 miles from substation TAP140741, a 115 kV facility. Proximity is a key driver of interconnection cost, and this distance is highly favorable.

Interconnection Strategy & Cost: For a distribution-scale project (≤5MW), a direct interconnection to the 115 kV transmission bus would be technically feasible but financially prohibitive. The more viable and cost-effective strategy is to interconnect to a distribution feeder originating from this substation. The interconnecting utility and distribution voltage are unknown but are likely National Grid and 13.8 kV, respectively. Verification is required. Assuming a suitable 3-phase distribution line is adjacent to the site, the interconnection cost could be in the range of $750,000 - $2,000,000. If a new feeder exit from the substation and a 0.3-mile line extension are required, costs could escalate to $2,000,000 - $3,500,000+.

Utility & Queue Timeline: The utility is likely National Grid, and the interconnection process would be managed through the ISO New England (ISO-NE) queue. The ISO-NE process is notoriously complex, expensive, and lengthy. From application submission to Commercial Operation Date (COD), developers should budget for a timeline of 30-48 months, including multiple rounds of system impact studies.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Barre. The property is zoned R-80 (Residential, 80,000 sq. ft. minimum lot size