⚡ 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 site is a 5.45-acre parcel currently part of a larger commercial shopping center. 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 property has excellent access. It is situated within the Westgate Mall complex, fronting Oak Street, a major multi-lane commercial thoroughfare with direct connections to Route 24. Existing curb cuts and robust internal paved roads, designed to accommodate heavy semi-trailer deliveries for anchor tenants, are in place.

Terrain Characteristics: Based on aerial imagery and the site's current use as a paved parking lot, the topography is flat, graded, and highly favorable for BESS development. This condition significantly reduces the need for extensive civil work, grading, and site preparation, lowering overall construction costs and timelines.

Heavy Equipment Access: Access for heavy equipment, including cranes for setting transformers and battery containers, is considered low-risk. The existing infrastructure can clearly support the weight and size of all necessary construction and delivery vehicles.

Easement Concerns: A significant concern is the likely existence of complex operating and easement agreements (O&EAs) or Covenants, Conditions, and Restrictions (CC&Rs) associated with the shopping mall. These agreements could restrict development, dictate land use, or grant access/parking rights to other parcel owners within the complex. A full title report and review of all recorded encumbrances is a critical next step to ensure a BESS project is a permissible use and that we can secure exclusive use of the project area.

2. Environmental Constraints

FEMA Flood Zone: The provided data lists the flood zone as "Unknown." A preliminary check of the FEMA Flood Map Service Center indicates the parcel is located in Zone X, an area of minimal flood hazard. While this is a positive initial finding, it Requires Verification through a formal floodplain report during due diligence. Siting outside of the 0.2% and 1% annual chance floodplains is critical to avoid significant design modifications and permitting challenges.

Wetlands: Presence is listed as "Unknown." A desktop review using MassGIS data suggests no state-mapped wetlands are on the parcel itself, but some resources may be located nearby. A formal wetland delineation will be required to confirm the absence of jurisdictional wetlands and to establish any required buffer zones (typically 100 ft in MA), which could constrain the buildable area.

Critical Habitat / Endangered Species: The data indicates no critical habitat. This should be confirmed via the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present. Given the site's highly disturbed, paved nature, this risk is considered low.

Brownfield/Superfund Status: The presence of 33 brownfield or superfund sites within a two-mile radius is a significant flag. While this presents a risk of potential contamination migrating onto our site, it also presents an opportunity. If a Phase I Environmental Site Assessment (ESA) identifies Recognized Environmental Conditions (RECs) that classify this parcel as a "brownfield site" per IRA guidelines, the project could be eligible for the 10% Brownfield ITC adder. This is the only potential location-based incentive for this site and warrants careful investigation.

Pipeline Proximity: No gas transmission pipelines are located within three miles, which is a positive safety and siting attribute, eliminating the need for specialized pipeline-related risk assessments and setbacks.

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 proximity is favorable, suggesting a potentially robust point of interconnection (POI). The 115kV rating indicates significant capacity may be available, reducing the risk of costly upstream transmission system upgrades.

Interconnection Voltage & Feeder: For a ≤5MW project, the most likely and cost-effective interconnection would be to a local 13.8kV (or similar) distribution feeder from the utility, which is almost certainly National Grid for this service territory. A three-phase