⚡ 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 distribution-scale Battery Energy Storage System (BESS) project at 170 Oak Street in Brockton, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives under the Inflation Reduction Act (IRA).

1. Site Access & Topography

• Road Access & Equipment Delivery: The subject property is located on Oak Street, a major commercial thoroughfare in Brockton. Preliminary review via satellite imagery indicates Oak Street is a multi-lane, paved road capable of supporting heavy truck traffic. Access appears to be excellent for the delivery of large BESS equipment, including battery containers, inverters, and main power transformers. The site is part of a larger commercial shopping center, suggesting existing, robust entrance and exit points.
• Terrain Characteristics: The property is currently developed as a commercial retail center with a large, paved parking lot. The topography appears to be flat and level, which is ideal for BESS construction. This significantly reduces the need for extensive civil work and site grading, lowering potential construction costs and timelines. The existing paved surface may even be usable as a base for equipment pads, pending a geotechnical analysis.
• Heavy Equipment Feasibility: Given the high-quality road access and flat terrain, there are no apparent barriers to moving heavy equipment onto the site. Turning radii from Oak Street into the shopping center's access drives appear sufficient for tractor-trailers. A final confirmation via a site walk and transportation logistics study would be required.
• Easement Concerns: As a developed commercial property, existing access easements are likely in place. However, a new utility easement will be required to run conduit from the BESS facility to the Point of Interconnection (POI). The 0.8-mile distance to the substation will necessitate securing off-site easements from adjacent landowners or rights-of-way from the municipality, which can be a time-consuming and costly process. This is a significant diligence item.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap and a potential fatal flaw. A FEMA FIRMette map must be reviewed immediately. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs will increase substantially due to requirements for elevating equipment above the Base Flood Elevation, and permitting may become impossible.
• Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), which typically enforce a 100-foot buffer zone around delineated wetlands. A desktop screening using the National Wetlands Inventory (NWI) is the immediate next step, to be followed by a formal field delineation by a certified wetland scientist if the screening indicates potential wetlands 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 with the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.
• Brownfield/Superfund Status: The presence of 33 brownfield or superfund sites within a two-mile radius indicates a history of industrial activity in the area. This presents both a risk and an opportunity.
  • Risk: There is an elevated risk of on-site contamination from past uses or migration from nearby sites. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
  • Opportunity: If the site itself can be classified as a brownfield under IRA guidelines, the project would be eligible for a 10% ITC bonus adder. This potential financial upside warrants a thorough investigation.
• Pipeline Proximity: No major gas pipelines are located within three miles of the site. This is a major safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The site is located only 0.8 miles from a substation with a maximum voltage of 115 kV. This proximity is highly favorable and is a primary strength of the site. Requires Verification: The specific name and operator of the substation must be confirmed. The interconnecting utility for Brockton is likely National Grid.
• Transmission Line Proximity: A 115 kV transmission line is also located 0.8 miles away, confirming the presence of robust grid infrastructure capable of handling significant power injection and withdrawal.
• Recommended Interconnection Voltage: For a distribution-scale project (≤5MW), a 115 kV transmission-level interconnection would be prohibitively expensive. The recommended strategy is to identify a 3