⚡ 37 FOSDICK RD

Sunland America Corp.

BESS Site Diligence Analysis Report

Date: October 26, 2023

Analyst: Senior BESS Site Evaluation Analyst

Site Name: Carver-Fosdick

Property Address: 37 FOSDICK RD, Carver, Plymouth County, MA 02330

APN: 052 65_1_B

1. Site Access & Topography

Road Access: The subject property is located on Fosdick Road in Carver, MA. A preliminary desktop review indicates Fosdick Road is a two-lane, paved local road. It appears to connect to regional thoroughfares, but its condition, width, and weight-bearing capacity are unknown and require verification. The primary concern is whether the road can support the transport of heavy and oversized loads, such as a 50-ton step-up transformer or 40-foot battery containers delivered via flatbed truck. The turning radii from main roads onto Fosdick Road must be assessed by a logistics expert or civil engineer.

Terrain & Equipment Access: The topography of Plymouth County is generally characterized by gently rolling hills and sandy soils left by glaciers. We anticipate the site to be relatively flat, but a formal topographical survey is essential to confirm this and identify any grading requirements, which add cost and time. The small parcel size of 2.36 acres presents a significant constraint for construction. There may be limited space for laydown areas, construction vehicle parking, and maneuvering of cranes needed for setting transformers and battery enclosures. The ability to get heavy equipment onto the parcel from Fosdick Road without extensive temporary road construction or tree clearing is a key unknown.

Easement Concerns: Requires Verification. A title search is a critical next step to identify any existing access, utility, or conservation easements that could encumber the property. An undiscovered easement could severely restrict the buildable area and render the site unviable for a BESS project, which requires a specific, unencumbered footprint.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap and a potential fatal flaw. If any portion of the buildable area is within a 100-year floodplain (e.g., Zone A or AE), development will be heavily restricted or prohibitively expensive, requiring equipment to be elevated above the Base Flood Elevation (BFE). We must immediately consult the FEMA Flood Map Service Center for this parcel.

Wetlands: Requires Verification. The presence of wetlands is another potential fatal flaw, especially in Massachusetts, which has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. A desktop review using MassGIS OLIVER is the first step, but a formal wetland delineation by a certified professional will be required. Any identified wetlands will trigger significant setbacks (typically a 100-foot buffer zone), which on a small 2.36-acre parcel, could eliminate the entire buildable area.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, we recommend a query of the USFWS IPaC system and the MA Natural Heritage & Endangered Species Program (NHESP) database to confirm there are no state or federally listed species with habitats in the vicinity that could be impacted by construction noise or activity.

Brownfield/Superfund Status: The presence of one Superfund site within two miles is noted but does not directly impact this parcel. Importantly, this does not qualify our project for the 10% IRA brownfield tax credit adder, as the subject property itself is not a designated brownfield. This is a risk, not an advantage, as it simply indicates nearby contamination without providing any financial benefit.

Other Considerations: The site is not in the Chesapeake Bay Critical Area. Proximity to pipelines and gas wells is not a concern based on available data, which simplifies safety planning and setback requirements.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The CARVER substation is located approximately 1.0 mile from the site. This is a favorable distance. Its maximum voltage of 345 kV indicates it is a major transmission hub, which almost certainly has distribution-level voltage buses (e.g., 13.8 kV) suitable for a project of our target size (≤5MW). The proximity of a 115kV transmission line (0.4 miles) is noted as "NOT AVAILABLE," which we interpret as meaning a tap is not feasible or the line is at capacity. Our strategy should therefore focus exclusively on the substation.

Interconnection Strategy & Cost: The recommended interconnection path is a new distribution feeder line from the CARVER substation to the project site. For a ≤5MW BESS, a 13.8 kV interconnection is standard. The primary challenge is the 1.0-mile distance. A line extension of this length is a major cost driver. A rough order-of-magnitude (ROM) cost estimate would be $1.5M - $3.0M, highly dependent on whether the route requires underground boring vs. overhead poles, the number of road/water crossings, and existing utility pole congestion.

Utility & Process: Requires Verification. The interconnecting utility is not specified but is likely Eversource or National Grid. Both operate under ISO New England (ISO-NE) tariffs. The interconnection process in Massachusetts is notoriously slow and complex. After submitting an application, we should anticipate a timeline of 24-48 months to reach commercial operation, factoring in study periods, potential system upgrades, and construction queues. A pre-application report is essential to get an initial capacity screen and a non-binding cost estimate from the utility.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Carver. The parcel is zoned "RA" - Commercial/Office/Residential (Mixed Use). This zoning presents a significant regulatory hurdle. Battery energy storage is an industrial/utility use that is rarely permitted "by-right" in a mixed-use or commercial district.

Permitting Pathway: The most likely permitting pathway will be a Special Permit from the Carver Planning Board and/or a Use Variance from the Zoning Board of Appeals (ZBA). A variance is particularly difficult to obtain as it requires proving a unique hardship. A Special Permit process involves public hearings and discretionary approval, opening the project to significant community opposition, costly design modifications, and potential denial.

Regulatory Risks: We must conduct a thorough review of the Town of Carver's Zoning Bylaws to see if BESS is defined or addressed. Many Massachusetts towns have enacted or are considering moratoriums on BESS development due to safety and aesthetic concerns. The risk of a moratorium or the creation of an unfavorable BESS-specific bylaw during our permitting process is high. Setback requirements will be determined by the bylaw or negotiated during the special permit process and could further constrain the site layout.

5. IRA/ITC Incentive Analysis

ITC Adder Stacking: The project's eligibility for IRA tax credit adders is poor.

• Opportunity Zone: No (0% adder)
• Energy Community: No (0% adder)
• Low-Income Community: No (0% adder)

Cumulative ITC: The project will only be eligible for the base 30% Investment Tax Credit (contingent on meeting prevailing wage and apprenticeship requirements). The lack of