⚡ 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 the property located at 170 Oak Street in Brockton, MA. The site is a 5.45-acre parcel currently zoned for commercial/industrial use. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The site exhibits excellent road access. It is located directly on Oak Street, a major commercial thoroughfare, and appears to be part of the Westgate Mall complex. This provides direct access to regional transportation routes. The existing entrance is wide and designed for commercial truck traffic, which is ideal for construction and delivery of heavy equipment.

Terrain & Buildability: Based on satellite imagery, the parcel is a large, paved parking lot. This is highly advantageous as the terrain is flat, graded, and already compacted. This significantly reduces the need for extensive civil work, such as grading and clearing, which will lower site preparation costs and shorten the construction timeline.

Heavy Equipment Access: Access for heavy equipment, including cranes for setting transformers and battery containers, is considered low-risk. The existing pavement and sub-base are likely sufficient to handle heavy loads, though a geotechnical survey will be required to confirm load-bearing capacity. There are no apparent overhead obstructions or tight turning radii that would impede delivery.

Easement Concerns: As part of a larger shopping center, the property is almost certainly subject to multiple easements. Requires Verification: A full title report must be reviewed to identify any cross-access easements, utility easements (power, water, sewer), or restrictive covenants (CC&Rs) that could limit the placement of a BESS or prohibit its use as a "utility facility." Securing a leasehold or partial carve-out from the owner will require careful legal review to ensure our development rights are not encumbered.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." This is a critical data gap. A preliminary desktop review suggests the area is likely Zone X (minimal flood risk), but this must be confirmed via an official FEMA Flood Insurance Rate Map (FIRM) analysis. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), all equipment would need to be elevated above the Base Flood Elevation, adding significant cost and complexity.

Wetlands: The presence of wetlands is "Unknown." While the developed, paved portion of the site is unlikely to contain jurisdictional wetlands, there may be drainage features or undeveloped perimeter areas that qualify. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act), and any impact would require a lengthy and complex permitting process with the local Conservation Commission. A desktop screening followed by a field delineation by a wetland scientist is a necessary early-stage diligence item.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site. Given the highly disturbed and commercialized nature of the parcel, the risk of encountering endangered species is extremely low.

Brownfield/Superfund Status: The presence of 33 brownfield or superfund sites within a two-mile radius is a significant finding. This presents both a risk and a major opportunity.

• Risk: The high density of nearby sites increases the probability that this parcel could have on-site contamination from historical use, which would require costly remediation.
• Opportunity: If a Phase I Environmental Site Assessment (ESA) determines this specific parcel qualifies as a "brownfield site" under IRA guidelines, the project would be eligible for the 10% ITC brownfield adder. This potential incentive is a major driver for the project's financial viability.

Pipeline Proximity: No gas pipelines are located within three miles, which is a positive finding that eliminates risks related to pipeline safety setbacks and co-location concerns.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation (UNKNOWN136273) and a 115kV transmission line are located approximately 0.8 miles from the site. This is an excellent proximity for a BESS project, minimizing the length and cost of the required generator lead line. The substation'