⚡ 494 W MAIN ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Brookfield" (494 W MAIN ST, West Brookfield, MA)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) on a 2-acre parcel in West Brookfield, Worcester County, Massachusetts. The analysis covers key development pillars including site access, environmental constraints, grid infrastructure, regulatory hurdles, and incentive eligibility.

1. Site Access & Topography

The subject property is located directly on West Main Street (Massachusetts Route 9), a major east-west state highway. This provides excellent primary road access. Based on aerial imagery, the parcel appears to be a cleared, relatively flat commercial lot, which is highly favorable for construction. The terrain in this part of Worcester County can be rolling, but this specific site does not appear to have significant topographical challenges that would complicate civil engineering or increase grading costs.

• Equipment Delivery: Access from Route 9 should be sufficient for the delivery of heavy equipment, including tractor-trailers carrying battery containers, inverters, and the main power transformer. A detailed route survey would be required to confirm bridge weight limits and turning radii from Route 9 onto the site, but initial assessment is positive.
• Heavy Equipment Access: The flat, open nature of the lot suggests that cranes for setting the transformer and battery enclosures can operate on-site with standard ground preparation.
• Easement Concerns: As the property has direct frontage on a public highway, a dedicated access easement is not anticipated to be necessary. However, an easement will be required for the generator lead line to connect to the point of interconnection (POI). If the POI is across Route 9 or on an adjacent property, securing this easement could introduce complexity and cost. This requires verification once a POI is identified.

2. Environmental Constraints

The environmental profile of this site presents significant unknowns that constitute a primary development risk. While some data points are positive, the gaps are critical on a small 2-acre parcel where constraints can easily render a project unviable.

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap. A preliminary review of the FEMA Flood Map Service Center is an immediate next step. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase due to requirements for elevating equipment, and in some cases, development may be prohibited.
• Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). The presence of even a small wetland area could severely restrict the buildable envelope of this 2-acre parcel, potentially making a ≤5MW BESS project infeasible. A desktop screening using MassGIS and the National Wetlands Inventory (NWI) is required immediately, followed by a formal wetland delineation if the screening indicates risk.
• Critical Habitat / Species: The data indicates no critical habitat or protected areas on site, which is a positive finding. This lowers the risk of encountering endangered species issues that could trigger lengthy consultations with USFWS or state agencies.
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• Brownfield/Superfund Status: The site is not a brownfield and is not near a Superfund site. While this indicates a clean site, it is a disadvantage from an incentives perspective, as the project will not be eligible for the 10% IRA Brownfield tax credit adder.
• Pipeline Proximity: No gas pipelines are located within 3 miles. This is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Grid access is the most critical and concerning aspect of this site. While proximity to infrastructure is present, its voltage class is