⚡ N MAIN ST

MEMORANDUM

TO: Sunland America Corp. Investment Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – N MAIN ST, Carver, MA (APN: 052 22_8_0)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 13.03-acre parcel located on N Main St in Carver, Plymouth County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

The subject property is located on N Main St, which appears to be a two-lane, paved local road. Direct access from a public right-of-way is a significant advantage, reducing the complexity and cost associated with long, private access roads. The land use designation as "Crop Land" strongly suggests the site is predominantly cleared and possesses minimal topographic variation. This flat terrain is ideal for BESS development, as it minimizes the need for extensive civil work and grading, thereby reducing construction costs and timelines.

Feasibility for heavy equipment delivery is likely high. Standard lowboy trailers carrying battery containers, transformers, and switchgear, as well as mobile cranes required for installation, should be able to navigate N Main St and access the site without major issue. However, a formal route survey would be required to confirm bridge weight limits and turning radii from major state highways. While direct road frontage exists, an internal access road and potential access easement across a portion of the parcel will be necessary to reach the optimal buildable area, which must be sited to accommodate setbacks and any environmental features.

2. Environmental Constraints

The environmental profile of this site presents significant unknowns that constitute a primary risk.

• FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. If the buildable area falls within a Special Flood Hazard Area (e.g., Zone A or AE), development will be complicated and costly, requiring equipment to be elevated above the Base Flood Elevation. In some cases, it could render the site economically unviable. A FEMA FIRMette lookup is an immediate next step.
• Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), which typically enforce a 100-foot buffer zone from delineated wetland boundaries. Given the region, the presence of wetlands is highly probable. A desktop screening using the National Wetlands Inventory (NWI) is required, followed by a formal field delineation if the site is pursued. Wetlands could severely constrain the available buildable acreage.
• Habitat & Protected Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding that simplifies state (MEPA) and federal environmental reviews.
• Brownfield/Superfund Status: The site is not a brownfield, and there are no nearby superfund sites. While this avoids potential environmental liability and remediation costs, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable disadvantage from a project finance perspective.
• Pipeline Proximity: No major gas pipelines are located within three miles, mitigating a significant safety and setback concern common to BESS development.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents the most significant challenge for this site. The nearest listed substation is the CARVER substation, located 2.1 miles away. This distance is substantial for a distribution-scale project and would necessitate a costly and time-consuming line extension. Furthermore, the substation's maximum voltage is 345kV, which is a bulk transmission voltage. A ≤5MW BESS project cannot interconnect at this level.

The project's viability is entirely dependent on the presence of a suitable three-phase distribution feeder (e.g., 13.8kV) running along N Main St or an adjacent road. The interconnecting utility is not specified but is likely Eversource. A detailed feeder analysis is required to confirm the presence, voltage, and available capacity of a local distribution circuit. If a viable feeder exists directly adjacent to the site, interconnection costs could be in the $750k - $1.5M range. However, if a 2.1-mile distribution line extension is required to reach the substation, costs would escalate dramatically to an estimated $3M - $6M+, likely rendering the project infeasible. The ISO New England (ISO-NE) interconnection queue is notoriously backlogged, and even a distribution-level study process could take 18-24 months before an Interconnection Service Agreement (ISA) is issued. The 115kV transmission line 1.3 miles away is noted as "NOT AVAILABLE" and should not be considered a viable Point of Interconnection (POI).

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is the Town of Carver. There is a critical discrepancy in the provided zoning data: one source lists it as "Agricultural/Rural