⚡ 35 SILVA ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 35 Silva St, Carver, MA (APN: 052 67_11_0)

This report provides a comprehensive due diligence analysis for the property located at 35 Silva St in Carver, Plymouth County, Massachusetts. The 3.91-acre parcel presents a mix of promising attributes and significant, unresolved risks. The primary positive driver is its exceptional proximity to major grid infrastructure. However, critical uncertainties regarding environmental constraints, viable interconnection points for a distribution-scale project, and a challenging regulatory landscape temper this initial optimism. A phased, low-cost due diligence approach is strongly recommended to de-risk the site before committing significant capital.

1. Site Access & Topography

• Road Access & Equipment Delivery: The site has direct frontage on Silva Street, a two-lane local road. Based on satellite imagery, Silva Street appears to be paved and in reasonable condition, connecting directly to Route 58, a major state highway, approximately 0.5 miles to the west. This provides a clear and straightforward route for construction traffic and equipment delivery. However, a physical site visit is required to confirm the absence of any low-clearance bridges, sharp turns, or weight-limited infrastructure on the final approach.
• Terrain Characteristics: The property appears to be relatively flat and cleared, consistent with the topography of southeastern Massachusetts. This is a significant advantage, as it will likely minimize the need for extensive civil work and grading, thereby reducing site preparation costs. A formal topographic survey is required to confirm elevations and drainage patterns.
• Heavy Equipment Access: The existing access from Silva Street appears adequate for the delivery of heavy equipment, including mobile cranes, transformers, and containerized BESS units. No immediate physical barriers are apparent from a desktop review.
• Easement Concerns: As the parcel has direct frontage on a public road, a dedicated access easement is not anticipated to be necessary. However, we must confirm that no other utility or access easements encumber the property, which could restrict the placement of equipment. This will be verified via a title search.

2. Environmental Constraints

• FEMA Flood Zone: The flood zone designation is currently Unknown. This represents a critical and potentially fatal flaw risk. A FEMA FIRMette must be obtained immediately. If any portion of the site falls within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase substantially due to the need for elevated foundations and flood-proofing measures. It could also render the site economically unviable.
• Wetlands Presence: The presence of wetlands is Unknown. Massachusetts has extremely stringent wetland protection laws (Massachusetts Wetlands Protection Act), which mandate significant setbacks (typically 100 feet or more) from delineated wetland resources. On a small 3.91-acre parcel, the presence of wetlands could severely restrict the buildable area, potentially leaving insufficient space for a viable BESS project. A wetland delineation by a certified professional is an urgent priority.
• Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on site, which is a positive finding. However, we must still conduct a desktop review using the USFWS IPaC tool and MassGIS OLIVER to screen for state-listed species whose habitats may be protected.
• Brownfield/Superfund Status: The data notes one Superfund site within a two-mile radius. This is unlikely to impact the subject property unless a contamination plume has migrated, which can be assessed in a Phase I Environmental Site Assessment (ESA). Importantly, if the subject property itself has a history of commercial/industrial use that qualifies it as a "brownfield," it could be eligible for the 10% ITC adder under the Inflation Reduction Act (IRA). A Phase I ESA is required to determine this, potentially turning a perceived risk into a financial advantage.
• Pipeline Proximity: The absence of any major gas pipelines within a three-mile radius is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

• Nearest Substation & Transmission: The site's proximity to the CARVER 345 kV substation (0.6 miles) and an adjacent 345 kV transmission line (0.3 miles) is, on the surface, excellent. However, for a distribution-scale project (≤5MW), interconnecting at 345 kV is technically and economically infeasible. The high-voltage infrastructure is a red herring.
• Likely Interconnection Voltage & Feeder: The critical path is to identify the local distribution system. The CARVER substation almost certainly steps down power to distribution voltages (e.g., 13.8 kV). We must identify the 3-phase distribution feeder that serves the area along Silva Street or Route 58. The interconnecting utility is presumed to be Eversource. A formal pre-application must be submitted to Eversource to identify the feeder name, voltage, and available capacity. This is the most critical unknown for project viability.
• Estimated Cost & Timeline: Interconnection costs are highly variable. If a suitable 3-phase feeder with adequate capacity is adjacent to the site, costs could be in the $750,000 - $1.5 million range. If the feeder requires significant upgrades, a re-conductoring, or a new dedicated line from the substation, costs could easily exceed $2.5 million. The ISO-New England interconnection process, managed by Eversource, is notoriously slow; a realistic timeline from application to commercial operation is 24-36 months.