⚡ JACOBS LN

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 36C-89-8 (Jacobs Ln), Whitman, MA

This report provides a comprehensive due diligence analysis for the 13.56-acre parcel located on Jacobs Lane in Whitman, Plymouth County, Massachusetts. The analysis evaluates the site's suitability for a distribution or utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The provided data does not specify the quality of road access. A desktop review indicates that Jacobs Lane is a minor local road, likely not designed for heavy industrial traffic. A physical site visit is mandatory to assess the road's width, surface condition (paved vs. gravel), and load-bearing capacity. It is critical to determine if the road can support low-boy trailers carrying multi-ton battery containers, inverters, and the main power transformer without significant and costly upgrades.

Terrain Characteristics: Based on the topography of Plymouth County, the site is likely characterized by gently rolling terrain with significant tree cover. While major grading may not be necessary, a formal topographical survey is required to confirm the site's flatness and identify the most suitable area for the BESS pad to minimize civil engineering costs. The presence of mature forest would also add significant clearing and grubbing costs.

Heavy Equipment Feasibility: The primary constraint for heavy equipment will be the "last mile" access via Jacobs Lane. We must verify turning radii from main roads, the absence of low-hanging utility lines, and the structural integrity of any small bridges or culverts along the access route. Without confirmation of adequate access, the site's buildability is considered a major risk.

Easement Concerns: The parcel appears to have limited frontage on Jacobs Lane. It is highly probable that an access easement will need to be negotiated with adjacent landowners, both for construction access and for a permanent operations and maintenance right-of-way. This introduces negotiation risk, potential costs, and timeline delays.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap and a potential fatal flaw. An immediate review of FEMA's Flood Insurance Rate Maps (FIRMs) is required. If any portion of the buildable area falls within a Special Flood Hazard Area (e.g., Zone A, AE), development will be severely restricted or require elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity.

Wetlands: The presence of wetlands is Unknown. Given the region, it is highly likely that state or federally jurisdictional wetlands and/or streams are present on the 13.5-acre parcel. Massachusetts has a robust Wetlands Protection Act with significant buffer zone requirements (typically 100 feet). A formal wetland delineation is a mandatory next step, as the presence of extensive wetlands could drastically reduce the buildable acreage to a point of non-viability.

Critical Habitat / Endangered Species: The data indicates no critical habitat, which is a positive initial finding. However, this must be verified through a Phase I Environmental Site Assessment (ESA) to screen for state-listed species or sensitive ecological areas not captured in the initial dataset.

Brownfield/Superfund Status: The presence of a superfund/brownfield site within two miles is a dual-edged sword. It presents a risk of potential soil or groundwater contamination on our subject parcel, which must be investigated via a Phase I ESA. Conversely, if our specific parcel can be classified as a "brownfield site" under federal guidelines (e.g., due to prior land use or contamination), it could qualify for the 10% IRA Brownfield ITC Adder. This potential advantage warrants immediate investigation.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and design advantage, eliminating the need for complex setback analyses and safety consultations with pipeline operators.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid proximity is its strongest attribute. It is located just 0.8 miles from a 115 kV substation and a mere 0.2 miles from a 115 kV transmission line. This proximity dramatically reduces the potential cost and complexity of the generator lead line (gen-tie).

Recommended Interconnection Voltage: Given the 115 kV infrastructure, a transmission-level interconnection is the most logical path for a utility-scale project. For a smaller distribution-scale project (≤5MW), we must investigate if a viable three-phase distribution feeder originates from the nearby substation and runs along a public right-of-way. The primary target, however, should be the 115 kV line.

Cost & Timeline Estimate: For a 0.2-mile tap to the 115 kV line, a preliminary interconnection cost estimate is $2.0M - $4.5M, inclusive of line work, a small project switchyard, and protection/metering equipment. This is a rough estimate and requires a formal study. The interconnecting utility is likely National Grid, and the process would be managed by ISO New England (ISO-NE). The ISO-NE interconnection queue is notoriously congested, and a realistic timeline from application to Commercial Operation Date (COD) is 4-6 years.

Feeder Configuration: The transmission line configuration appears to be a standard overhead line. A detailed review of its structure and right-of-way is needed to determine