⚡ 360 BROCKTON AVE

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 360 Brockton Ave, Abington, MA (APN: 15_137)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives. The property is a 2.93-acre commercially zoned parcel in Plymouth County, MA.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has excellent road access, situated directly on Brockton Avenue (Massachusetts Route 123), a major, paved, multi-lane commercial thoroughfare. This existing high-quality infrastructure is ideal for the delivery of heavy and oversized equipment, including battery containers, pad-mount transformers, and switchgear. No significant road upgrades are anticipated for construction access.

Terrain & Buildability: As an existing commercial site, the terrain is presumed to be flat and graded, which significantly reduces earthwork and site preparation costs. The current land use as a commercial building with associated parking suggests a stable, compacted base suitable for BESS foundations. However, the presence of the existing structure and paved areas means that demolition and removal costs must be factored into the pro forma. The net buildable area after accounting for setbacks and existing infrastructure Requires Verification through a formal site survey (ALTA).

Heavy Equipment Feasibility: Access for a 100-ton crane, flatbed trucks, and other necessary construction vehicles appears feasible directly from Brockton Avenue. There are no apparent vertical clearance issues (e.g., low bridges) or tight turning radii on the primary access route.

Easement Concerns: While direct site access is clear, a primary concern will be securing easements for the interconnection gen-tie line. Whether connecting to the overhead transmission line 0.5 miles away or a local distribution feeder, the route will likely cross third-party properties. Securing these easements can be time-consuming and costly and represents a significant project risk.

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 equipment above the Base Flood Elevation (BFE). In some cases, it could render the project infeasible. A desktop FEMA map review is required immediately.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). The presence of regulated wetlands on or adjacent to the parcel could severely constrain the buildable area and trigger a lengthy and complex permitting process with the local Conservation Commission. This is a potential fatal flaw.

Habitat & Protected Species: The initial screening shows no critical habitat or protected areas on or immediately adjacent to the site. Given its location in a developed commercial corridor, the risk of encountering endangered species that would halt development is considered low.

Brownfield/Superfund Status: The site is not listed as a brownfield or superfund site. While this avoids potential remediation liabilities, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, which is a missed financial opportunity.

Pipeline Proximity: No gas transmission pipelines are identified within a 3-mile radius, eliminating risks and setback requirements associated with high-pressure pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest major substation (TAP136269) is 1.6 miles away with a 115kV voltage class. A 115kV transmission line is significantly closer, at approximately 0.5 miles. For a distribution-scale project (≤5MW), a 115kV transmission-level interconnection would be prohibitively expensive and complex, involving a new substation bay, high-voltage switchgear, and a lengthy ISO-New England review process.

Recommended Interconnection: The most viable path is a distribution-level interconnection. The interconnecting utility is likely National Grid. The key unknown is the location, voltage (likely 13.8kV), and available capacity of the nearest 3-phase distribution feeder. The project's feasibility is highly dependent on identifying a suitable feeder with thermal and voltage capacity to accommodate a 5MW injection/withdrawal.

Feeder Configuration: Requires Verification. We must identify the specific feeder circuit number and determine if it is a radial or networked configuration. Capacity on commercial feeders like this can be constrained.

Cost & Timeline Estimate: Assuming a suitable distribution feeder is available along Brockton Avenue, the interconnection cost could range from $750,000 to $2,500,000. This range accounts for the gen-tie line, pole replacements, and potential upstream re-conductoring or protection upgrades required by National Grid. The interconnection process in Massachusetts is thorough and can take 18-24 months from application to receiving an Interconnection Service Agreement (ISA).

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Abington, specifically the Planning Board and Conservation Commission.

Zoning Compatibility: The parcel is zoned HC (Highway Commercial). Crucially, a review of the Town of Abington's Zoning Bylaws reveals Section 175-39.1, "Battery Energy Storage Systems." This is a significant advantage. The existence of a specific BESS ordinance provides a clear, albeit rigorous, permitting path and eliminates the uncertainty of trying to define BESS as a "similar use" in a zone where it is not explicitly mentioned.

Permitting Pathway: The bylaw indicates that BESS is an allowed use in the HC district upon the issuance of a Special Permit from the Planning Board. This process will require a detailed site plan review, public hearings, a decommissioning plan, noise studies, and a safety plan compliant with NFPA 855. While a clear path, it is not guaranteed and will be subject to public comment and board discretion.

Setback Requirements: The Abington bylaw specifies setbacks, which Requires Verification but are likely to be substantial (e.g., 50-100 feet from property lines) and will impact the final site layout and buildable area.

Moratorium Risk: The presence of a specific bylaw greatly reduces the risk of a future moratorium, as the town has already proactively addressed and regulated this type of development.

5. IRA/ITC Incentive Analysis

ITC Adders: The project's financial model will be constrained by a lack of available ITC adders under the Inflation Reduction Act (IRA).

• Opportunity Zone: No. The site is not in a qualified Opportunity Zone. (0