⚡ 446 WEST ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Project "Bridgewater Grid" (446 West St, East Bridgewater, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 446 West St, East Bridgewater, Plymouth County, MA (APN: 083 33_11_0). The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property has excellent road access, with direct frontage on West Street (MA Route 106), a two-lane state highway. This provides a clear and established access point for both construction and ongoing operations & maintenance (O&M).

Topography & Feasibility: Based on aerial imagery and regional topography, the site appears to be a previously developed commercial lot that is predominantly flat and cleared. This is highly advantageous, as it will likely minimize the need for extensive civil work, grading, and clearing, thereby reducing site preparation costs and timelines. The existing level surface is well-suited for the placement of concrete pads for battery containers and transformers.

Heavy Equipment Access: Access from a state highway directly onto the parcel is ideal for the delivery of heavy and oversized equipment, including multi-ton battery enclosures, medium-voltage transformers, and switchgear. No significant road improvements or temporary access roads appear necessary, although a detailed logistics plan and turning radius analysis for delivery vehicles is still required.

Easement Concerns: With direct frontage on a public right-of-way, no off-site access easements are anticipated. However, an internal access road design will be required to ensure emergency vehicle access around the BESS array in compliance with NFPA 855 and local fire department requirements.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Action Item: A FEMA Flood Insurance Rate Map (FIRM) review must be conducted immediately. If the site is located in a Special Flood Hazard Area (e.g., Zone A, AE), development costs could increase substantially due to the need to elevate all equipment above the Base Flood Elevation (BFE), or the site could be rendered undevelopable. A designation of Zone X (minimal flood risk) is strongly preferred.

Wetlands: The presence of wetlands is Unknown. Given the site's location in Massachusetts, which has stringent wetland protection laws (Massachusetts Wetlands Protection Act), this is a high-priority risk. A desktop screening followed by a formal wetland delineation by a certified professional is required. The presence of jurisdictional wetlands could trigger significant setbacks (typically 100-foot buffer zones) that would severely constrain the buildable area on this relatively small 2.41-acre parcel.

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 reduces the risk of triggering lengthy and complex environmental reviews under the Massachusetts Endangered Species Act (MESA) or federal regulations.

Brownfield/Superfund Status: The site is not a listed brownfield or superfund site. While this is positive from a liability and remediation standpoint, it means the project is ineligible for the 10% IRA Brownfield Adder ITC. This is a notable financial disadvantage.

Pipeline Proximity: No major gas transmission pipelines are located within three miles, mitigating risks associated with pipeline-related safety setbacks, easements, and potential explosion hazards.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid access is its strongest attribute. It is located just 0.6 miles from the EAST BRIDGEWATER substation (max voltage 115 kV) and 0.3 miles from a 115 kV transmission line. This exceptional proximity dramatically reduces the cost and complexity of the electrical line extension.

Recommended Interconnection: For a distribution-scale project (≤5MW), the recommended point of interconnection (POI) is a distribution-level feeder (likely 13.8 kV) originating from the EAST BRIDGEWATER substation. A direct tap to the 115 kV transmission line would be cost-prohibitive and unnecessarily complex for a project of this size.

Cost & Timeline Estimate: A 0.6-mile, 3-phase overhead distribution line extension could range from $750,000 to $1.75 million, subject to a detailed utility study. The primary risk factor is the interconnection process itself. The interconnecting utility is likely National Grid, and the system operator is ISO New England (ISO-NE). The ISO-NE queue is notoriously congested and slow-moving. The total timeline from application to commercial operation can realistically be 24-48 months, with significant study costs and upgrade securities required along the way.

Feeder Configuration & Capacity: The likely feeder route would be along West Street. A critical next step is to submit a pre-application report to the utility to determine if the targeted feeder has sufficient thermal capacity and hosting capacity to accommodate a 5MW BESS without requiring major upstream upgrades at the substation, which could kill the project's economics.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of East Bridgewater. Permitting will be handled by the town's Planning Board and/or Zoning Board of Appeals.

Zoning Compatibility: There is a data conflict