⚡ N CARY ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – N CARY ST, Brockton, MA (APN: 163-252)

This report provides a comprehensive due diligence analysis for the property located on N Cary St in Brockton, Plymouth County, MA, for its potential as a distribution-scale or utility-scale Battery Energy Storage System (BESS) project. The analysis is based on preliminary data and identifies key risks, opportunities, and recommended next steps.

1. Site Access & Topography

Road Access & Feasibility: The site has frontage on N Cary Street, which appears to be a paved, two-lane industrial road based on aerial imagery. This type of road is generally suitable for heavy truck traffic, including flatbeds for battery containers and multi-axle heavy-haul trucks for the main power transformer. However, a route survey is required to confirm turning radii from major highways, bridge weight limits, and any overhead line clearance issues along the final approach.

Terrain Characteristics: Preliminary review of aerial and topographic maps suggests the parcel is relatively flat with minimal grade changes, a highly favorable characteristic for BESS construction as it minimizes civil work costs. The parcel appears to be partially wooded, which will require clearing and grubbing. A formal ALTA survey with 2-foot contours is necessary to confirm the topography and identify the net buildable area. There is a discrepancy in listed acreage between data sources (13.68 vs. 8.57 acres), which must be clarified by the ALTA survey and title report.

Heavy Equipment Access: Given the industrial zoning and existing road infrastructure, access for critical heavy equipment like a 150-ton crane, transformers, and containerized BESS units appears feasible. The primary constraint will be the on-site road network, which will need to be constructed with an appropriate aggregate base to support the required loads.

Easement Concerns: As a vacant industrial parcel, there is a moderate risk of pre-existing utility easements (e.g., gas, sewer, electric) crossing the property. A title commitment must be ordered immediately to identify any recorded easements that could sterilize portions of the buildable area or conflict with the proposed site layout.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Requires Verification. This is a critical, potentially fatal flaw. Any portion of the site within a 100-year floodplain (Zone A/AE) would impose significant costs and design challenges, requiring all equipment to be elevated above the Base Flood Elevation. A definitive determination using FEMA's Map Service Center is an immediate next step.

Wetlands: The presence of wetlands is Requires Verification. Massachusetts has stringent wetlands protection regulations (Massachusetts Wetlands Protection Act). Given the site's undeveloped nature, the presence of state or federally regulated wetlands is highly probable. A desktop screening using MassGIS OLIVER should be performed, followed by a formal wetland delineation by a certified professional. The discovery of significant wetlands could severely restrict the buildable envelope due to required buffer zones (typically 100 feet in MA).

Critical Habitat / Endangered Species: The initial screen indicates no critical habitat or protected areas on site. This is a positive finding, but it must be verified through a formal request to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The data indicates an alarming 34 brownfield or superfund sites within a two-mile radius. This strongly suggests a history of heavy industrial use in the area and elevates the risk that this specific parcel may be contaminated. This is a dual-edged sword:

• Risk: Potential for soil or groundwater contamination could trigger costly remediation requirements and project delays. A Phase I Environmental Site Assessment (ESA) is non-negotiable.
• Opportunity: If the site qualifies as a brownfield under IRA guidelines, the project could be eligible for a 10% ITC adder. This potential benefit must be weighed against the remediation risk.

Pipeline Proximity: No major gas transmission pipelines were identified within three miles, which significantly de-risks the project from a pipeline safety and setback perspective.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The grid infrastructure is the strongest attribute of this site. It is located just 0.7 miles from a 115 kV substation and a mere 0.1 miles from an existing 115 kV transmission line. This proximity is excellent and dramatically reduces the cost and complexity of the generator tie-line.

Recommended Interconnection: For a utility-scale project (>5MW), a direct 115 kV transmission-level interconnection is the recommended and most logical pathway. This avoids potential capacity constraints on local distribution feeders and allows the project to participate more fully in