⚡ 298 EAST ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 298 EAST ST, Plymouth County, MA (APN: 083 12_11-02_0)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project at the subject property. The analysis identifies significant regulatory and financial challenges that present high barriers to successful development. While the grid infrastructure appears promising, the combination of residential zoning and a lack of available IRA/ITC incentives makes this a high-risk prospect.

1. Site Access & Topography

The 4.19-acre property is located at 298 East Street, which suggests direct frontage on a public road. A preliminary desktop review indicates East Street is a two-lane, paved local road. However, its width, shoulder quality, and any potential weight-limited bridges or culverts are unknown and require verification.

• Equipment Delivery: Feasibility for delivering heavy equipment, such as a 50-ton transformer or 40-foot battery containers via lowboy trailer, is uncertain. A route survey would be required to confirm turning radii from major highways and the load-bearing capacity of East Street itself. The short distance to major regional routes is a positive factor.
• Terrain Characteristics: As is typical for Plymouth County, the terrain is likely to be gently rolling with glacial soil composition. A desktop topographic review is necessary to identify steep slopes that could increase civil engineering and grading costs. The 4.19-acre parcel size is adequate for a ≤5MW BESS project (typically requiring 1-2 acres), assuming no major topographic or environmental constraints.
• Easement Concerns: As the property is vacant and owned by a family trust, a preliminary title report is critical. We must identify any existing utility easements (for the nearby transmission line, for example) or access easements that could encumber the property and reduce the buildable envelope. This is a key unknown.

2. Environmental Constraints

The environmental profile of this site contains critical unknowns that represent potential fatal flaws. While the site appears clear of major contamination or habitat issues, water-related constraints could render it undevelopable.

• FEMA Flood Zone: The flood zone designation is unknown. This is a critical risk. If the property lies within a 100-year floodplain (e.g., Zone AE), development would require elevating all equipment above the Base Flood Elevation, dramatically increasing costs. If it is in a floodway, development would be prohibited. This must be investigated immediately via FEMA's Map Service Center.
• Wetlands: The presence of wetlands is unknown. Massachusetts has extremely stringent wetland protection laws. Given the region's hydrology, there is a high probability of jurisdictional wetlands on or adjacent to the parcel. A desktop screening using MassGIS data is the first step, but a formal wetland delineation by a certified professional will be required. Setbacks from wetlands could easily consume a significant portion of the 4.19-acre site.
• Habitat & Species: The data indicates no critical habitat or protected areas, which is a significant positive. This should be confirmed via the MA Natural Heritage & Endangered Species Program (NHESP) database as part of our standard process.
• Brownfield Status: The site is not a brownfield. This eliminates environmental liability risk but also means the project is ineligible for the 1