⚡ 120 W CENTER ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 322 45 042 (120 W CENTER ST, West Bridgewater, MA)

This report provides a comprehensive due diligence analysis for the subject property in West Bridgewater, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

The 4.17-acre property is located at 120 W Center Street, which is also designated as Massachusetts Route 106. This is a significant advantage, as Route 106 is a well-maintained, two-lane state highway capable of supporting heavy truck traffic. Preliminary review of satellite and street-level imagery confirms direct, unimpeded frontage onto this road, suggesting that delivery of large equipment such as battery containers, inverters, and a main power transformer will be feasible. There are no apparent low-clearance bridges or sharp, restrictive turns in the immediate vicinity of the site entrance.

The topography in this region of Plymouth County is generally characterized by gentle, rolling terrain. Satellite imagery indicates the parcel itself is relatively flat and cleared, which is ideal for minimizing civil engineering and site preparation costs. The current land use appears to be commercial, possibly with a paved or gravel lot, further simplifying construction. Heavy equipment access onto the parcel from Route 106 appears straightforward. However, a formal title search is required to confirm that no access-restricting easements or covenants encumber the property. A geotechnical survey will also be necessary to confirm soil stability and load-bearing capacity for heavy foundations.

2. Environmental Constraints

Environmental factors present a mixed but manageable risk profile. A preliminary check of the FEMA Flood Map Service Center indicates the property is located in Zone X, an area of minimal flood hazard. This is a significant positive, as it avoids costly flood mitigation measures and potential siting restrictions.

• Wetlands: The provided data lists wetlands as "Unknown." A preliminary screen using the USFWS National Wetlands Inventory mapper suggests the potential for wetlands on or immediately adjacent to the parcel. Massachusetts has a highly restrictive Wetlands Protection Act, and any presence of jurisdictional wetlands would trigger significant setback requirements (typically 100-foot buffer zones), potentially reducing the buildable area to a point of non-viability. This is a critical and immediate diligence item.
• Critical Habitat: The data indicates no critical habitat or protected areas on site, which is favorable. This should be confirmed with the MA Natural Heritage & Endangered Species Program (NHESP) database.
• Brownfield/Superfund: The presence of two superfund/brownfield sites within a two-mile radius is a moderate concern requiring investigation in a Phase I Environmental Site Assessment (ESA) to rule out any potential contaminant migration. However, this also presents an opportunity. If the subject parcel itself can be designated as a "brownfield site" under federal definitions (e.g., due to prior commercial/industrial use), the project could qualify for the 10% IRA Brownfield ITC adder.
• Pipelines: No gas pipelines within a three-mile radius is a major safety and permitting advantage, eliminating a common source of risk and public opposition.

3. Grid Infrastructure & Interconnection

The site's proximity to grid infrastructure is a primary strength. A 115kV transmission line is located just 0.5 miles away, and a 115kV substation (TAP135389) is 1.0 mile away. For a ≤5MW project, a transmission-level interconnection would be cost-prohibitive (likely $3M - $7M+). The more viable and cost-effective strategy is a distribution-level interconnection.

Street-level imagery confirms the presence of three-phase overhead distribution lines running directly along the property's frontage on W Center Street. The interconnecting utility is likely National Grid. The key unknown is the capacity of this specific feeder. The interconnection process in this region is governed by ISO New England (ISO-NE), which has a notoriously congested and lengthy queue. A project of this size would likely enter the state-jurisdictional distribution queue, but timelines can still extend from 18 to 36+ months.

An initial interconnection cost estimate for a distribution tap, assuming sufficient feeder capacity, would be in the range of $750,000 to $2,500,000. This cost could escalate significantly if the feeder requires substantial upgrades (e.g., reconductoring, substation breaker upgrades). Determining the available capacity on this feeder is the single most important technical diligence item for this site.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is the Town of West Bridgewater. The property is zoned "B" (Business) or a similar Commercial/Mixed-Use designation. BESS is almost certainly not a "by-right" use in this zone. Therefore, the permitting pathway will likely require discretionary approval from the town's Planning Board or Zoning Board of Appeals (ZBA). This will most likely be a Special Permit process, which involves public hearings and subjects the project to community feedback and potential opposition.

This represents a significant project risk. We must thoroughly review the West Bridgewater Zoning Bylaws to understand setback requirements, noise ordinances, and aesthetic screening requirements. Furthermore, we must investigate whether the town has considered or enacted any moratoriums on battery storage projects, as this has become a trend in some Massachusetts communities. Early, proactive engagement with town officials is critical to gauge their receptiveness to this type of development. The project will also need to comply with Massachusetts-specific fire safety codes based on NFPA 855.

5. IRA/ITC Incentive Analysis

The site's eligibility for IRA/ITC adders is currently limited, which impacts its financial attractiveness. The base ITC is 30%.

• Opportunity Zone: No. (0% adder)