⚡ 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, Massachusetts. The 5.45-acre parcel presents a potentially viable opportunity for a distribution-scale BESS project, primarily due to its favorable proximity to significant grid infrastructure. However, substantial risks related to interconnection cost, regulatory approvals, and environmental conditions must be thoroughly investigated and mitigated before committing further capital.

1. Site Access & Topography

Road Access & Feasibility: The site exhibits excellent road access. It is located on Oak Street, a major commercial thoroughfare in Brockton, immediately adjacent to the Westgate Mall. This road appears to be well-maintained and capable of supporting heavy truck traffic.

Terrain & Equipment Access: Based on satellite imagery and the property's use as a commercial lot, the topography is presumed to be flat and graded, which is ideal for BESS construction. Access for heavy equipment, including cranes for setting transformers and battery containers, appears straightforward from Oak Street. No significant topographical challenges are anticipated, though a formal survey is required for confirmation.

Easement Concerns: While on-site access is strong, a significant concern is the need for easements to reach the point of interconnection (POI). The nearest substation is 0.8 miles away. Securing the necessary easements for a new distribution line of this length, potentially crossing multiple private parcels and public rights-of-way, represents a major project risk in terms of both cost and timeline. Existing utility or access easements on the subject parcel must also be identified through a title search.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. A preliminary desktop review suggests the area is likely Zone X (minimal flood risk), but this Requires Verification via an official FEMA flood map analysis. Any designation other than Zone X could impose significant design constraints, increase costs, or render the site undevelopable.

Wetlands: The presence of wetlands is Unknown. Given the developed nature of the area, on-parcel jurisdictional wetlands may be unlikely, but nearby wetlands could still trigger buffer and setback requirements under Massachusetts state and local regulations. A wetlands delineation study will be necessary to confirm conditions and define the buildable area.

Critical Habitat / Species Risk: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding that reduces the risk of significant environmental permitting delays.

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 an opportunity.

• Risk: The subject property itself could have historical contamination, necessitating costly remediation. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
• Opportunity: If the site itself qualifies as a brownfield (as defined by the EPA), the project could be eligible for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This potential financial benefit warrants immediate investigation.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a significant safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located 0.8 miles from Substation UNKNOWN136273 and an associated 115kV transmission line. This proximity to a high-voltage substation is the site's primary strength. The substation is a robust injection point, suggesting high potential for available capacity.

Interconnection Voltage & Feeder: For a distribution-scale project (≤5MW), a 115kV transmission-level interconnection would be cost-prohibitive. The recommended pathway is to interconnect to a distribution-level feeder (likely 13.8 kV) originating from the substation. The exact route, capacity, and proximity of the nearest suitable 3-phase distribution feeder Requires Verification from the interconnecting utility, which is presumed to be National Grid.

Cost & Timeline Estimate: The 0.8-mile (approx. 4,200 feet) distance to the substation is a major cost driver. A new distribution line extension of this length could range from $750,000 to $2,000,000+, depending on whether it is overhead or underground, pole conditions, and the complexity of road/property crossings. The interconnection process with National Grid in the ISO-New England territory is notoriously complex and lengthy, with timelines often extending 18-36 months from application submission to Commercial Operation Date (COD).

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Brockton is the primary AHJ for all zoning and building permits.

Zoning Compatibility: The parcel is zoned I-1 (Industrial). While industrial zoning is generally more favorable for BESS than commercial or residential, energy storage is a new use not explicitly defined in many municipal codes. It is highly unlikely to be a permitted "by-right" use.

Permitting Pathway: The most probable permitting pathway will be a Special Permit from the Brockton Zoning Board of Appeals (ZBA) or City Council. This process involves public hearings, discretionary review, and the potential for site-specific conditions of approval. This introduces significant timeline risk and uncertainty. A pre-application meeting with the Brockton Planning Department is essential to confirm the required process.