⚡ 15 SILVER ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 15 Silver St, Hanover, MA (APN: 122 30_8)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) project at the subject property. The analysis concludes with a BESS Suitability Score and a final recommendation.

1. Site Access & Topography

Road Access: The 4.74-acre parcel has direct frontage on Silver Street, a two-lane, paved local road. Initial review of satellite imagery suggests the road is in fair condition and likely sufficient for construction traffic, including standard trucks and concrete mixers.

Equipment Delivery: The primary concern is access for oversized and overweight vehicles, such as a lowboy trailer carrying a main power transformer (MPT) or pre-fabricated battery containers. While Silver Street itself appears straight near the property, a full route survey is required to evaluate turning radii from major state routes (e.g., MA-3, MA-53) to the site. Any tight turns, low-clearance bridges, or weight-restricted local roads could render heavy equipment delivery infeasible or prohibitively expensive.

Topography & Site Prep: The site is currently wooded and appears relatively flat, which is favorable for minimizing earthwork costs. However, significant tree clearing and grubbing will be required, adding to site preparation expenses and potentially triggering local tree removal ordinances. The flat terrain is advantageous for establishing the BESS pad and internal access roads.

Easements: As the property has direct road frontage, a dedicated access easement is not anticipated. However, an internal gravel access road will need to be constructed from Silver Street to the BESS pad location, the cost of which must be factored into the project pro-forma.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development costs will increase substantially due to requirements for elevating all critical equipment above the Base Flood Elevation (BFE). This could necessitate costly raised structural steel platforms. A definitive flood zone determination is an immediate priority.

Wetlands: The presence of wetlands is Unknown. Given the wooded nature of the site in coastal Massachusetts, the probability of jurisdictional wetlands is high. The Massachusetts Wetlands Protection Act imposes stringent regulations, typically including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. The presence of significant wetlands could render the 4.74-acre parcel undevelopable for a project of our target size. A formal wetlands delineation is a critical and immediate next step.

Habitat & Species: The site is clear of designated critical habitats and protected areas, which is a significant positive. However, we recommend cross-referencing the site with the MA Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-listed species habitats are present, which could trigger further review.

Contamination Status: The site has no known brownfield or superfund sites nearby. While this eliminates environmental remediation risk, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, a notable financial disadvantage.

Pipelines: The absence of high-pressure gas pipelines within a 3-mile radius is a major safety and layout advantage, removing significant setback and risk mitigation concerns.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The most viable POI appears to be the 115kV transmission line located 0.8 miles from the site. The nearest substation, WATER STREET, is 1.9 miles away, a distance that would likely make a dedicated distribution-level feeder extension financially unviable for a ≤5MW project.

Interconnection Voltage & Cost: A 115kV transmission-level interconnection is the recommended path. This involves a significantly higher cost and complexity than a distribution connection. A preliminary, high-level cost estimate for a 0.8-mile 115kV tap, line extension, and associated switchgear would be in the $4M - $8M range. This high cost is likely a fatal flaw for a smaller distribution-scale project.

Utility & Process: The interconnecting utility is likely National Grid, and the process would be governed by ISO New England (ISO-NE). The ISO-NE interconnection queue is notoriously long and complex, with timelines for a transmission-level project often exceeding 36 months from application to commercial operation. This timeline presents a major risk to project scheduling and financing.

Feeder Configuration: While there appear to be distribution poles along Silver Street, their voltage class (likely 13.8kV) and available capacity are unknown. It is imperative to file a pre-application with the utility to determine if any capacity exists on these local circuits, as this would be a dramatically cheaper, albeit less likely, interconnection path.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Hanover Planning Board and Zoning Board of Appeals (ZBA).

Zoning Compatibility: The parcel is zoned R-A (Residential-Agricultural). This is a critical, potentially fatal flaw. BESS is an industrial utility use and is fundamentally incompatible with residential zoning. It is almost certain that BESS is not a permitted use "by-right" in this district.

Permitting Pathway: The only conceivable pathway would be to obtain a Use Variance from the Hanover ZBA. A variance requires proving a legal hardship unique to the land, a very high bar to clear. A Special Permit might be another route if the town's bylaws have any provisions for utility facilities, but this is unlikely. Both are discretionary processes that are lengthy, expensive, and subject to significant public opposition, especially for an industrial facility in a residential neighborhood.

Regulatory Risk: The risk of permit denial is extremely high. Furthermore, many Massachusetts towns, wary of BESS development, have enacted or are considering moratoriums. An immediate inquiry with the Hanover Planning Department is required to determine the town