⚡ 175 E ASHLAND ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 175 E Ashland St, Brockton, MA (APN: 044 161-098)

This report provides a comprehensive due diligence analysis for the subject property in Brockton, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis concludes with a suitability score and a recommended course of action.

1. Site Access & Topography

The subject property, located at 175 E Ashland Street, benefits from excellent physical access. E Ashland Street is a paved, multi-lane municipal road that appears well-maintained and suitable for heavy commercial traffic. This is a significant advantage for the delivery of oversized and overweight equipment, such as BESS containers, switchgear, and the main power transformer, which are typically transported via lowboy trailers.

Based on aerial imagery and regional topographic data, the site appears to be relatively flat with minimal grade change, which is ideal for BESS development. A flat site significantly reduces civil engineering and earthwork costs associated with grading, foundation work, and site preparation. The 2.57-acre parcel size is adequate for a ≤5MW BESS, providing sufficient space for equipment pads, access roads, and required zoning setbacks.

Heavy equipment access appears feasible directly from E Ashland Street. The property has direct road frontage, minimizing the need for complex access easements. However, a formal title search is Required for Verification to confirm that no restrictive easements or access limitations encumber the parcel. The industrial nature of the surrounding area suggests that local road infrastructure is built to withstand heavy vehicle loads.

2. Environmental Constraints

The environmental profile of this site presents both significant risks and a key potential advantage that must be carefully investigated.

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. Immediate verification using the FEMA Flood Map Service Center is required. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs could increase substantially due to requirements for elevating equipment above the Base Flood Elevation, or the site could be rendered undevelopable.
• Wetlands: The presence of wetlands is also Unknown. Given Massachusetts' strict Wetlands Protection Act, which mandates significant buffers (typically 100 feet) from delineated wetland resources, this is a major potential constraint. A desktop screening using state GIS layers and the National Wetlands Inventory (NWI) must be conducted immediately, followed by a formal field delineation if any indicators are present.
• Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding, reducing the risk of project delays or mitigation requirements from state (MA NHESP) or federal (USFWS) agencies. This should be formally confirmed during the permitting process.
• Brownfield/Superfund Status: The presence of 33 known contamination sites within a two-mile radius, combined with the site's industrial zoning, suggests a moderate to high probability that the subject parcel could have historical contamination. This is a dual-edged sword:
  • Risk: On-site contamination could necessitate costly remediation and introduce long-term liability. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
  • Advantage: If the Phase I ESA determines the site meets the federal definition of a "brownfield site," the project could qualify for the 10% Brownfield ITC Adder under the Inflation Reduction Act (IRA), significantly improving project economics.
• Pipeline Proximity: No major gas pipelines are located within three miles, which is a positive safety and design factor, eliminating concerns about pipeline-related setbacks or explosion risks.

3. Grid Infrastructure & Interconnection

The site's proximity to robust grid infrastructure is its most compelling feature and a primary driver of its potential value.

• Substation Proximity: The site is located just 0.6 miles from a major substation with a maximum voltage of 115 kV. This short distance is highly advantageous, minimizing the cost and complexity of the generator lead line. The utility is National Grid, and interconnection will be governed by the ISO New England (ISO-NE) tariff.
• Transmission Access: A 115 kV transmission line is located only 0.1 miles from the property boundary. This provides a theoretical, albeit expensive and complex, transmission-level interconnection option.
• Recommended Interconnection: For a ≤5MW project, a distribution-level interconnection is the most economically viable and common pathway. A three-phase distribution feeder, likely operating at 13.8 kV, is almost certainly running along E Ashland Street. This is the recommended point of interconnection (POI). Verification of the feeder voltage and available capacity with National Grid is a critical next step.
• Estimated Costs & Timeline: For a 0.6-mile distribution tie-in, interconnection costs could range from $750,000 to $2,000,000, highly dependent on the required feeder upgrades and substation breaker work identified in the ISO-NE system impact study. The ISO-NE queue is notoriously congested, and a realistic timeline from application submission to commercial operation is approximately 24-48 months. Securing a queue position early is paramount.

4. Regulatory & Zoning Analysis

The regulatory landscape appears favorable but requires local confirmation.

• Authority Having Jurisdiction (AHJ): The City of Brockton is the primary AHJ for all zoning and construction permits.
• Zoning Compatibility: The parcel is zoned I-2 (Industrial General). This is highly favorable, as BESS facilities are typically considered an industrial or utility use, which is often allowed in such zones. This significantly de-risks the entitlement process compared to sites in commercial or residential zones.
• Permitting Pathway: It is unlikely that BESS is a "by-right" use. The most probable pathway is a Special Permit issued by the Brockton Planning Board or Zoning Board of Appeals.