⚡ 171 OLD OAKEN BUCKET RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 171 Old Oaken Bucket Rd, Scituate, MA (APN: 264 47_1_4_D)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at the subject property in Scituate, Plymouth County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including grid infrastructure, environmental constraints, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property has direct frontage on Old Oaken Bucket Road, a two-lane, paved public road. Based on aerial imagery review, the road appears to be in good condition and sufficiently wide to accommodate standard construction traffic and delivery of BESS containers and other large equipment. The primary access point to the parcel itself will need to be confirmed or potentially improved to handle heavy-axle loads associated with a fully loaded transformer or mobile crane.

Topography & Site Conditions: The parcel is currently designated as agricultural crop land. Satellite imagery confirms this, showing a largely cleared, flat field. This topography is highly advantageous for BESS development, as it will significantly reduce the need for extensive civil work and grading, thereby lowering site preparation costs. The total parcel size is listed as 6.67 acres, though a separate data source (Regrid) indicates 8.74 acres; this discrepancy requires verification via a formal survey. The existing cleared land appears sufficient for a 5MW / 20MWh project, pending environmental and zoning setbacks.

Heavy Equipment Feasibility: Access for heavy equipment, including cranes for setting transformers and containerized BESS units, appears feasible from Old Oaken Bucket Road. No immediate obstructions such as low-hanging bridges or sharp, unnavigable turns are apparent on the primary access route. A detailed logistics and transportation study would be required prior to construction.

Easement Concerns: While the site has direct road access, easements will be a critical consideration for the generator lead line to the Point of Interconnection (POI). Whether connecting to the transmission line 0.7 miles away or the substation 1.2 miles away, the route will almost certainly cross third-party properties, necessitating the negotiation and acquisition of multiple easements. This process can be time-consuming and costly.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This represents a critical data gap and a significant project risk. Scituate is a coastal town with known flood-prone areas. Any designation within a 100-year floodplain (e.g., Zone AE) would likely render the site undevelopable for critical infrastructure like a BESS or require cost-prohibitive mitigation measures such as elevating all equipment on platforms.

Wetlands: The presence of wetlands is Unknown. Given the site's location in coastal Massachusetts, there is a high probability of state or federally regulated wetlands being present on or adjacent to the parcel. The Massachusetts Wetlands Protection Act imposes stringent regulations, including significant buffer zones (typically 100 feet) that would reduce the buildable area. A formal wetland delineation is an essential and immediate next step.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on site. This is a positive finding, but it must be formally verified through a consultation with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed species or priority habitats are impacted.

Brownfield/Superfund Status: The site is not a brownfield, and there are no superfund sites within a two-mile radius. While this reduces the risk of encountering soil contamination and associated cleanup liabilities, it also means the project is ineligible for the 10% IRA Brownfield tax credit adder, which is a notable economic disadvantage.

Pipeline Proximity: No gas pipelines are located within a three-mile radius, which is a significant safety and permitting advantage. This eliminates risks associated with pipeline-related setbacks, safety protocols, and potential co