⚡ 366 E 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 366 E MAIN ST, East Brookfield, MA (APN: 084 004.2_0130_0066.0)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project at the subject property. The analysis covers key siting criteria, identifies significant risks, and recommends a path forward. The final recommendation is MAYBE, contingent on the successful and cost-effective resolution of several critical unknowns.

1. Site Access & Topography

Road Access: The property has excellent road access, fronting directly on East Main Street, which is also Massachusetts Route 9. This is a major state highway, ensuring it is well-maintained, paved, and capable of handling heavy vehicle traffic year-round.

Topography & Equipment Delivery: Based on aerial imagery and its current commercial use (vehicle sales/rental), the 2.19-acre parcel appears to be graded and relatively flat. This is highly advantageous for minimizing civil engineering and site preparation costs. Access from Route 9 should be more than sufficient for the delivery of heavy and oversized equipment, including 40-foot battery containers, multi-ton transformers, and large cranes. A detailed site survey and swept path analysis will be required to confirm turning radii from the main road into the planned site entrance, but no significant issues are anticipated.

Easement Concerns: As the property has direct frontage on a public right-of-way, a dedicated access easement is not anticipated to be necessary. However, a title search is a critical next step to identify any existing utility easements (e.g., for gas, water, or existing electrical lines) that may cross the property. Such easements could significantly constrain the usable buildable area and must be identified early.

2. Environmental Constraints

FEMA Flood Zone: The property's flood zone designation is currently Requires Verification. This is a critical data gap. If the site is located within a 100-year floodplain (e.g., Zone AE), development costs would increase substantially due to the need to elevate all equipment above the Base Flood Elevation (BFE). A location within a floodway would likely represent a fatal flaw. A FEMA FIRMette review is an immediate priority.

Wetlands: The presence of wetlands is Requires Verification. Given the small parcel size, the discovery of regulated wetlands and their associated buffers (typically 50-100 feet in Massachusetts) could severely limit or eliminate the buildable area for a 5MW BESS. A desktop screening using MassGIS and National Wetlands Inventory (NWI) data is required immediately, to be followed by a formal wetland delineation by a certified professional if any indicators are present.

Habitat & Protected Species: Initial screening shows no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding that reduces permitting complexity. We recommend a confirmatory check of the USFWS IPaC and Massachusetts NHESP databases as a standard diligence step.

Site Contamination: The site is not listed as a brownfield or superfund site, and none are located within a 2-mile radius. While this minimizes environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage.

Other Constraints: No pipelines or gas wells are located in the immediate vicinity, eliminating significant safety and setback concerns. The site is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation, TAP162179, is located approximately 1.0 mile from the site and has a maximum voltage of 69 kV. The absence of transmission lines within a 3-mile radius confirms this project must pursue a distribution-level interconnection. The 1.0-mile distance is manageable but represents a significant cost driver for the interconnection.

Interconnection Pathway & Cost: The likely point of interconnection (POI) would be a 3-phase distribution feeder running along Route 9. The interconnecting utility is Requires Verification but is likely National Grid. The project would require a 1.0-mile line extension from the substation to bolster the local feeder or a direct line to the site. This is a substantial distance. Estimated interconnection costs could range from $750,000 to $2,000,000+, depending on whether the line is overhead vs. underground, pole ownership, and the extent of required substation upgrades (e.g., new breaker, reclosers). The capacity of the existing feeder is a critical unknown.

Utility Process & Timeline: The interconnection process in Massachusetts under ISO-New England is notoriously slow and complex. Upon submitting an application, we should anticipate a study process lasting 18-2