⚡ 170 OAK ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Oak" - 170 OAK ST, Brockton, MA

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at 170 Oak Street in Brockton, Plymouth County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory pathways, and financial incentives.

1. Site Access & Topography

The subject property exhibits excellent characteristics for BESS development from a physical and logistical standpoint. Located within the Westgate Mall commercial complex, the site has direct frontage on Oak Street, a multi-lane arterial road. It is also immediately adjacent to Route 24, a major regional highway, allowing for straightforward and efficient transportation logistics.

• Road Access & Equipment Delivery: Access is superb. The existing road infrastructure is designed to accommodate frequent semi-trailer truck deliveries for mall anchor tenants. This capacity is more than sufficient for the delivery of heavy BESS equipment, including 40-foot battery containers, multi-ton transformers, and heavy cranes required for installation. No significant road upgrades are anticipated.
• Terrain Characteristics: Satellite imagery review confirms the site is a large, paved parking lot. The topography is flat and pre-graded, which is ideal for a BESS facility. This condition drastically reduces potential civil engineering and site preparation costs, eliminating the need for extensive clearing, grading, or soil stabilization.
• Access Easement Concerns: While on-site access is excellent, two primary easement concerns exist. First, as part of a larger commercial parcel, there are likely existing cross-access easements and restrictive covenants benefiting other tenants that must be reviewed. Second, and more critically, an easement will be required for the interconnection line running from the site to the Point of Interconnection (POI). The 0.8-mile distance to the substation suggests this could be a complex and potentially costly process involving multiple private and/or public right-of-way negotiations.

2. Environmental Constraints

The environmental profile of this site presents a mixture of significant risks and potential opportunities that require immediate investigation. While the site is clear of certain common constraints, several critical data gaps exist.

• FEMA Flood Zone: The flood zone designation is currently unknown. This is a critical flaw in the initial data. A location within a Special Flood Hazard Area (e.g., Zone AE) could necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity, or could render the site undevelopable. A formal flood zone determination is a priority.
• Wetlands: Presence of jurisdictional wetlands is unknown. While the paved nature of the parcel makes on-site wetlands unlikely, adjacent properties may contain features that could impose buffer and setback requirements onto our project area. A desktop National Wetlands Inventory (NWI) screening followed by a formal wetland delineation will be necessary.
• Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on or near the site. This is a positive finding that lowers permitting risk with state (MA NHESP) and federal (USFWS) wildlife agencies.
• Brownfield/Superfund Status: The data reveals an alarming density of 33 brownfield or superfund sites within a two-mile radius. This creates a material risk that the subject parcel or adjacent properties have historical contamination, which could trigger costly remediation requirements. A Phase I Environmental Site Assessment (ESA) is non-negotiable. Conversely, if the site itself can be officially classified as a brownfield, it may become eligible for the 10% ITC "Brownfield Adder," turning a significant risk into a financial advantage.
• Pipeline Proximity: The absence of any gas pipelines within a three-mile radius is a significant safety and design advantage, eliminating setback constraints and explosion-risk concerns.

3. Grid Infrastructure & Interconnection

The site's proximity to robust grid infrastructure is a primary advantage, though the specific interconnection pathway remains a key uncertainty.

• Substation & Transmission: The