⚡ 170 OAK ST

MEMORANDUM

TO: Sunland America Corp. Investment 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 5.45-acre subject property is part of a larger commercial shopping center. The analysis concludes that while the site possesses excellent physical and grid characteristics, significant financial and regulatory hurdles must be overcome for the project to be viable.

1. Site Access & Topography

Road Access & Feasibility: The site has excellent access. It is located within the Westgate Mall shopping plaza, directly off Oak Street, a major multi-lane commercial thoroughfare. Existing curb cuts, internal access roads, and large parking areas are designed for heavy truck traffic, including semi-trailers for retail deliveries. This existing infrastructure is more than adequate for the delivery of BESS equipment.

Terrain Characteristics: Based on aerial imagery and the site's current use as a paved parking lot, the topography is flat, graded, and stable. This is an ideal condition for a BESS project, as it will dramatically reduce civil engineering and site preparation costs. No significant grading or earthwork is anticipated.

Heavy Equipment Access: Access for cranes, transformers, and battery containers is considered low-risk. The wide, paved surfaces can easily accommodate the necessary turning radii and weight-bearing capacity for all construction and delivery vehicles. The primary consideration will be coordinating laydown areas and construction traffic to minimize disruption to active retail operations on the parcel.

Easement Concerns: While the parcel has direct road frontage, the BESS would occupy a subsection of the larger lot. A formal access and utility easement from the fee simple owner (JMR SQUARE INVESTMENT LLC) will be a critical component of any lease or purchase agreement. This easement must grant perpetual, unrestricted 24/7 access for construction, operations, and maintenance.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently listed as Requires Verification. A preliminary desktop review suggests the property is located in Zone X, an area of minimal flood hazard. However, this must be confirmed via a formal Flood Hazard Determination. If any portion of the proposed footprint falls within a Special Flood Hazard Area (e.g., Zone A or AE), the BESS equipment pads and control systems would need to be elevated above the Base Flood Elevation, adding significant cost and complexity.

Wetlands: The presence of jurisdictional wetlands is Requires Verification. While the site is heavily developed, wetlands can persist in commercial areas, particularly in drainage features or undeveloped portions. A desktop screening using state (MassDEP) and federal (NWI) databases is an immediate next step, to be followed by a formal wetland delineation if any potential indicators are found. The presence of wetlands would trigger state and local setback requirements (typically 50-100 feet in MA), which could constrain the buildable area.

Critical Habitat / Endangered Species: Data indicates no designated critical habitats on or adjacent to the site. This is a significant positive, reducing the risk of project delays or mitigation requirements under the Endangered Species Act. A standard USFWS IPaC report should still be generated to formalize this finding.

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

• Risk: There is an elevated risk of on-site contamination from historical uses or migration from nearby sites. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
• Opportunity: If the Phase I ESA identifies a Recognized Environmental Condition (REC) and the site can be officially classified as a "brownfield" per IRA guidelines, the project could qualify for the 10% Brownfield ITC adder. This is potentially the most critical financial lever for this project's success.

Pipeline Proximity: The absence of major