⚡ PLYMOUTH ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 052 17_63_0 (PLYMOUTH ST)

This report provides a comprehensive due diligence analysis for the property located on Plymouth Street, Plymouth County, MA (APN 052 17_63_0), for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis reveals significant risks related to grid interconnection, environmental constraints, and a lack of financial incentives, warranting a highly cautious approach.

1. Site Access & Topography

Road Access & Feasibility: The property is located on "PLYMOUTH ST," but specific road frontage and quality are unknown. Initial desktop analysis suggests this is a local, potentially rural road. A site visit is required to confirm if the road is paved, its width, and its condition. The access route from major state highways to the site must be evaluated for any potential obstructions, such as low-clearance bridges, tight turning radii, or weight-limited culverts, which could impede the delivery of heavy equipment like transformers, switchgear, and battery containers (often weighing over 80,000 lbs).

Terrain Characteristics: Located in Plymouth County, MA, the terrain is anticipated to be gently rolling with significant tree cover, characteristic of rural New England. A full topographical survey is essential. The parcel size is listed inconsistently as 24.16 acres and 10.86 acres in different data sources; this discrepancy must be resolved via a survey. Undulating terrain could increase civil work costs for grading and foundation preparation. The presence of rocky soil or ledge is common in this region and could further escalate site preparation expenses.

Heavy Equipment Access: Feasibility is currently a major unknown. Assuming a suitable buildable area is identified within the parcel, an internal access road will need to be constructed. The primary concern is the 1.5-mile distance to the Carver substation; the entire route for the collection line and any access roads must be assessed for constructability.

Easement Concerns: Significant easement acquisition will be required. A 1.5-mile generation tie-line (gen-tie) from the project to the Carver substation will need to cross multiple third-party parcels and potentially public rights-of-way. Securing these easements can be a time-consuming and expensive process, posing a significant project risk. An ALTA survey is required to identify any existing easements (e.g., utility, conservation) that could encumber the property.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Requires Verification. This is a critical data gap. Any portion of the site within a Special Flood Hazard Area (e.g., Zone A, Zone AE) would be severely constrained, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing costs and potentially rendering the site unviable.

Wetlands: The presence of wetlands is Requires Verification. Massachusetts has some of the most stringent wetlands regulations in the country under the Massachusetts Wetlands Protection Act. A desktop screening using the National Wetlands Inventory (NWI) is an immediate first step, but a formal field delineation by a certified professional will be mandatory. The presence of state-jurisdictional wetlands would trigger significant setbacks (typically a 100-foot buffer zone) and a lengthy, complex permitting process with the local Conservation Commission.

Critical Habitat / Endangered Species: The initial screen shows no critical habitat on site, which is a positive. However, this must be confirmed by cross-referencing project plans with the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no impacts on state-listed rare species or their habitats.

Brownfield/Superfund Status: There are two remediation sites within a two-mile radius, but none on the subject parcel itself. This proximity necessitates a Phase I Environmental Site Assessment (ESA) to rule out any potential contaminant migration. While this poses a risk, the Phase I ESA should also investigate the site's historical use. If any past activity qualifies the site as a "brownfield" under IRA guidelines, the