⚡ REID SMITH COVE RD

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 61_A_10_0 (REID SMITH COVE RD, Webster, MA)

This report provides a comprehensive due diligence analysis for the 3.46-acre property located on Reid Smith Cove Rd in Webster, Worcester County, MA. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria. The overall recommendation is a NO GO due to multiple significant, likely insurmountable, challenges related to grid access, zoning, and environmental risks.

1. Site Access & Topography

Road Access: The property is located on Reid Smith Cove Road, which appears to be a minor, local residential road. Requires Verification: A desktop review using aerial imagery suggests this may be a narrow, private, or unpaved road. Its condition and load-bearing capacity are unknown and represent a significant risk for heavy equipment transport.

Terrain & Equipment Feasibility: The "Cove" and "Lake" descriptors in the road name and zoning code strongly suggest the site is adjacent to a body of water (Webster Lake). This implies potentially significant topographic relief, with slopes leading down to the water. Such terrain can create major civil engineering challenges and dramatically increase site preparation costs for creating level pads required for battery containers, inverters, and transformers. The ability for a lowboy trailer carrying a 40-foot, 80,000 lb battery container and a mobile crane to navigate the local roads and access the site is highly questionable and must be confirmed with a physical site visit and route survey.

Easement Concerns: Given the likely private nature of Reid Smith Cove Road, a formal, permanent access easement from the road owner(s) would be required. Negotiating such an easement for an industrial-type use in a residential area is often difficult and costly.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone status is currently unknown. This is a critical data gap. Given the site's likely proximity to a lake, there is a high probability that portions of the property lie within a Special Flood Hazard Area (SFHA), such as Zone AE. Development within an SFHA would require elevating all equipment above the Base Flood Elevation (BFE), adding substantial cost and complexity. Any development within a floodway would be prohibited. This must be the first environmental item investigated.

Wetlands: The presence of wetlands is unknown but highly probable due to the lakeside location. A desktop review using the National Wetlands Inventory (NWI) is an immediate next step. Any state or federally jurisdictional wetlands would trigger significant setbacks (typically 50-100 feet) enforced by the Webster Conservation Commission under the Massachusetts Wetlands Protection Act. These setbacks on a small 3.46-acre parcel could render the remaining upland area insufficient for a BESS project.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive. However, this should be verified through the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no sensitive species are mapped in the vicinity.

Site Contamination: The absence of nearby brownfield or superfund sites is positive from a liability perspective but disadvantageous from an incentives standpoint. The project is ineligible for the 10% IRA Brownfield Adder, making its economics less competitive.

Other Constraints: The lack of pipelines or gas wells within several miles is a significant safety and layout advantage, eliminating a common siting constraint.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation, EAST WEBSTER, is 1.8 miles away. For a distribution-scale project, this distance is economically challenging, if not fatal. The Point of Interconnection (POI) would not be the substation itself, but rather a 3-phase distribution feeder originating from it. The critical unknown is the location of the nearest 3-phase, 13.2 kV (or similar voltage) line. A 1.8-mile line extension is a multi-million-dollar undertaking that a ≤5MW BESS project cannot support.

Interconnection Voltage & Cost: The project will interconnect at distribution voltage. The 69 kV bus at the substation is sub-transmission and not a viable target for a small project. The primary cost driver will be the distribution line extension. A rough, order-of-magnitude estimate for a 1.8-mile overhead line extension would be $1.8M - $3.0M, plus the cost of protection and communication upgrades at the substation. This cost alone likely makes the project non-viable.

Utility & Process: The interconnecting utility for Webster, MA is National Grid. The Massachusetts interconnection process, governed by the Department of Public Utilities (DPU), is notoriously slow and complex. Queue backlogs are significant, and a project requiring a new line extension and substation upgrades could easily face a 36-48 month timeline from application to commissioning.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Webster. The parcel is zoned "LAKE 5" / "L-R" (Lake Residential). This zoning is a fundamental and likely fatal flaw. BESS facilities are an industrial/utility use and are fundamentally incompatible with