⚡ 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 170 OAK ST, Brockton, MA (APN: 044 036-095)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at 170 Oak Street in Brockton, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

The subject property is located on Oak Street, a major commercial thoroughfare in Brockton. Based on aerial imagery and the site's current use as a commercial shopping center, access is presumed to be excellent.

• Road Access & Equipment Delivery: The site has direct frontage on Oak Street, a multi-lane road capable of handling heavy truck traffic. Delivery of large components such as battery containers, inverters, and main power transformers appears highly feasible. A detailed logistics plan would be required to confirm turning radii from Oak Street into the specific parcel area and to identify any potential overhead utility line conflicts.
• Terrain Characteristics: As a developed commercial property, the terrain is expected to be flat, graded, and largely impervious (paved). This significantly de-risks the civil engineering scope, reducing the need for extensive grading and site preparation, which translates to potential cost and timeline savings.
• Heavy Equipment Access: Internal site access for cranes and other heavy equipment for installation should be straightforward, assuming a portion of the existing parking lot is utilized for the project footprint.
• Easement Concerns: Requires Verification. Given this is a parcel within a larger shopping center development, there is a high probability of existing cross-access easements, utility easements, and potentially restrictive covenants that could limit the placement or operation of a BESS. A full title report is an immediate and critical next step to identify any encumbrances that would constrain the buildable area.

2. Environmental Constraints

The environmental profile of this site presents several significant unknowns that must be resolved before committing further resources. The area's industrial history is a key factor.

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. This is a critical data gap. Any designation within a 100-year floodplain (e.g., Zone AE) would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. A designation in a high-risk coastal zone or floodway could render the site undevelopable. A FEMA FIRMette map must be reviewed immediately.
• Wetlands: Requires Verification. The presence of jurisdictional wetlands is unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act). A desktop screening using National Wetlands Inventory (NWI) maps is a necessary first step, followed by a formal wetland delineation by a certified professional if any potential wetlands are identified on or near the parcel.
• Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This should be confirmed via the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database.
• Brownfield/Superfund Status: The presence of 33 listed sites within a two-mile radius indicates a high-risk area for contamination. While this could present an opportunity to qualify for the 10% IRA brownfield tax credit adder if the subject parcel itself is a designated brownfield, it also carries the significant risk of pre-existing contamination and potential liability for cleanup. A Phase I Environmental Site Assessment (ESA) is strongly recommended to determine the site's specific status.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive finding that simplifies safety and setback considerations.

3. Grid Infrastructure & Interconnection

The site's proximity to robust grid infrastructure is its most compelling attribute.

• Nearest Substation: The site is located approximately 0.8 miles from a substation with a maximum voltage of 115 kV. This is an ideal distance, minimizing the cost and complexity of the generator lead line. The utility is likely National Grid, which serves the Brockton area, but this must be confirmed.
• Transmission Line Proximity: A 115 kV transmission line is also located 0.8 miles away, providing a clear and viable path for a transmission-level interconnection if the project size were to be scaled up beyond the typical distribution-scale.
• Recommended Interconnection Voltage: For a ≤5MW project, the most likely and cost-effective path would be a distribution-level interconnection, likely at 13.8 kV, tapped from a feeder originating from the nearby substation. A transmission-level (115 kV) interconnection is a possibility but would be significantly more expensive and subject to a more rigorous