⚡ 32 SCOTLAND BLVD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 32 Scotland Blvd, Bridgewater, MA (APN: 042 59_5_0)

1. Site Access & Topography

Road Access & Equipment Delivery: The subject property is located on Scotland Boulevard, which appears to be a well-maintained, paved two-lane road within an established industrial park. Based on satellite imagery review, the road seems capable of supporting heavy truck traffic, including standard semi-trailers. This is a significant advantage for the delivery of BESS containers, transformers, and switchgear. Direct access from a public right-of-way is evident, minimizing the need for complex, off-site road improvements.

Terrain & Buildability: As is typical for industrial parks in this region of Massachusetts, the topography is expected to be relatively flat and previously graded. This significantly reduces anticipated civil engineering and site preparation costs. We assume the 4.75-acre parcel is largely usable, but this must be confirmed. Heavy equipment, including a 100-ton crane for setting the main power transformer (MPT) and battery enclosures, should have no significant issues accessing and maneuvering on the site, assuming stable soil conditions.

Easement Concerns: While the site has direct road frontage, an access easement will be required for the interconnection gen-tie line. The nearest transmission line is 0.2 miles away and the substation is 0.5 miles away. This will necessitate securing an easement from one or more adjacent property owners or potentially utilizing the public right-of-way, which can introduce permitting complexity and cost. A title search is required to identify any existing easements (utility, access, etc.) that could encumber the property and constrain the site layout.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap and a potential fatal flaw. If the site is located within a 100-year floodplain (e.g., Zone AE), all equipment pads would need to be elevated above the Base Flood Elevation (BFE), adding substantial cost. Siting within a high-risk zone or a floodway could render the project un-permittable or financially non-viable. This must be the first environmental diligence item investigated.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act (WPA). The presence of jurisdictional wetlands would trigger significant buffer and setback requirements (typically 100 feet), which could severely reduce the buildable area on a 4.75-acre parcel. A formal wetland delineation by a certified professional is essential to determine the developable envelope of the site.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding that lowers the risk of encountering project delays or mitigation requirements related to threatened and endangered (T&E) species. However, a desktop screening using the state's MassGIS OLIVER tool is still recommended as a low-cost verification step.

Brownfield/Superfund Status: The site is not a listed brownfield, and there are no superfund sites within a 2-mile radius. From a liability perspective, this is a positive, as it avoids potential soil contamination and remediation costs. However, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable commercial disadvantage.

Pipeline Proximity: The absence of gas transmission pipelines within a 3-mile radius is a significant safety and design advantage. It eliminates the need for specialized risk assessments, blast studies, and restrictive setbacks that can complicate site layout and increase costs.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's proximity to grid infrastructure is its strongest attribute. It is located just 0.5 miles from the major BRIDGEWATER substation and 0.2 miles from a 115kV transmission line. This proximity dramatically reduces the potential cost and complexity of the gen-tie line.

Interconnection Voltage & Strategy:

• Distribution (≤5MW Target): For our target distribution-scale project, the ideal interconnection would be to a 13.8kV (or similar) distribution feeder. The presence of such a feeder with sufficient hosting capacity along Scotland Blvd is Requires Verification. This is the most cost-effective path but is entirely dependent on feeder availability and thermal/voltage capacity.
• Transmission (Utility-Scale Option): The 115kV line offers a highly viable, albeit much more expensive, interconnection point suitable for a larger utility-scale project (e.g., 20MW+). The BRIDGEWATER substation's 345kV bus is not a realistic POI for a project of our target size.

Cost & Timeline Estimate:

• Distribution IX (If Feasible): Estimated cost of $750,000 - $2,000,000, with a timeline of 18-30 months through the ISO-New England (ISO-NE) queue process.
• Transmission IX (115kV): Estimated cost of $4,000,000 - $8,000,000+, requiring a new substation bay or switching station. The timeline would likely be 36-48+ months.

Utility & Queue: The interconnecting utility is likely National Grid, but this Requires Verification. All non-trivial interconnections in this region are processed through the ISO-NE queue, which is known for being backlogged, complex, and expensive. Early engagement via a pre-application is critical to understand feasibility and timeline.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The AHJ is the Town of Bridgewater, Massachusetts.

Zoning Compatibility: The parcel is zoned IA (Industrial). This is generally highly favorable for BESS development, as it is often considered a compatible "utility" or "industrial" use and minimizes conflicts with sensitive receptors like residences. However, we must verify if BESS is an explicitly defined use in the Bridgewater Zoning Bylaw.

Permitting Pathway: It is unlikely that BESS is a "by-right" use. The most probable permitting pathway is a Special Permit and Site Plan Review from the Bridgewater Planning Board. This process involves public hearings and discretionary approval, introducing timeline and outcome risk. We must obtain and review the town's zoning bylaws to confirm the exact process and requirements.