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MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 122 63_101, Hanover, Plymouth County, MA

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) project on a 2.08-acre parcel in Hanover, Massachusetts. The analysis concludes that while the site possesses exceptional grid infrastructure access, it faces severe regulatory and financial incentive challenges that present significant development risks.

1. Site Access & Topography

Road Access: Requires Verification. The specific road frontage for this parcel is not provided. However, given its location in Hanover and proximity to major grid infrastructure, it is likely accessible from a paved local or county road. A desktop review using satellite imagery is required to confirm the quality of the road, identify the nearest major thoroughfare (e.g., Route 3 or Route 53), and assess any potential obstructions like narrow bridges or tight turns.

Equipment Delivery: The feasibility of delivering heavy equipment is a primary concern. BESS projects require transport of multi-ton battery containers, a main power transformer, and switchgear. The access route must be able to support heavy haul trucks. We must conduct a route survey to confirm bridge weight limits, turning radii, and overhead line clearances from the nearest highway to the site entrance.

Topography & Buildability: Requires Verification. As a vacant parcel in Plymouth County, the terrain is likely to be relatively flat to gently rolling, characteristic of Eastern Massachusetts. However, the presence of glacial till, rock outcroppings, or significant vegetation cannot be ruled out without a site visit and geotechnical survey. The small parcel size of 2.08 acres is tight for a 5MW project, which typically requires 1-1.5 acres of cleared, level ground. Any significant grade or unbuildable areas would severely constrain the site layout.

Easements: The proximity to a 115kV transmission line (0.1 mi) suggests a high likelihood of existing utility easements crossing or abutting the property. A title search is mandatory to identify any easements that could restrict the buildable area or dictate access routes. We must also secure a temporary construction easement and a permanent access easement from the landowner if the primary access point is not directly on a public right-of-way.

2. Environmental Constraints

FEMA Flood Zone: Unknown. This is a critical data gap and a potential fatal flaw. Any designation within a 100-year floodplain (Zone A or AE) would likely render the site undevelopable for critical infrastructure like a BESS or require cost-prohibitive mitigation, such as elevating all equipment on platforms. A FEMA panel review must be conducted immediately.

Wetlands: Unknown. Massachusetts has some of the most stringent wetland protection regulations in the country under the Massachusetts Wetlands Protection Act. The presence of state or federally delineated wetlands on or near the parcel would trigger significant setback requirements (typically 100-foot buffer zones) and a lengthy, complex permitting process with the Hanover Conservation Commission. A wetland delineation study by a certified professional is a non-negotiable next step.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This significantly de-risks the project from a federal Endangered Species Act perspective. However, this must be confirmed through the MA Natural Heritage & Endangered Species Program (NHESP) database.

Brownfield/Superfund Status: The absence of nearby brownfield or superfund sites is a double-edged sword. It reduces the risk of soil contamination and associated cleanup liabilities. However, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant financial disadvantage.

Pipeline Proximity: No major gas pipelines are identified within a 3-mile radius, eliminating risks associated with pipeline easements, setbacks, and potential explosion hazards.

3. Grid Infrastructure & Interconnection

Substation & Transmission: This is the site's premier asset. The WATER STREET substation is only 0.5 miles away, and a 115kV transmission line is a mere 0.1 miles from the parcel boundary. This proximity is exceptional and dramatically reduces the potential cost and complexity of the generator lead line. The 115kV voltage class is ideal for a utility-scale BESS project (5MW or larger), allowing for efficient power injection into the bulk electric system.

Interconnection Recommendation: A transmission-level interconnection at 115kV is the recommended pathway. This avoids potential capacity constraints on a local distribution feeder and provides greater market participation opportunities within ISO-New England (ISO-NE). The likely point of interconnection (POI) would be a new three-breaker ring bus or tap station on the existing 115kV line.

Cost & Timeline: While the short distance is highly favorable, a 115kV transmission tap is still a capital-intensive undertaking. Estimated interconnection costs could range from $1.5M to $4M+, depending on utility (likely National Grid) requirements for protection, metering, and switchgear. The ISO-NE interconnection queue is notoriously long and complex. The timeline from application submission to a signed Interconnection Agreement can easily be 24-36 months, followed by another 12-18 months for construction.

Utility & Feeder: Requires Verification. The interconnecting utility is almost certainly National Grid, the incumbent utility for this area. We must confirm this and begin researching their specific interconnection standards (e.g., ESB 756) and application processes.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Hanover, specifically its Planning Board and Zoning Board of Appeals.

Zoning Compatibility: This is the site's most significant challenge. The current zoning is R-A (Residential-Agricultural). A BESS is an industrial utility use and is fundamentally incompatible with residential zoning. It is highly unlikely to be a permitted use "by-right."

Permitting Pathway: The most likely pathway would be to apply for a Special Permit or a Use Variance. A Special Permit is possible only if the Hanover Zoning Bylaw explicitly allows for "public utility" or similar uses in the R-A zone under special conditions. A Use Variance is much more difficult to obtain, as it requires proving a legal hardship unique to the parcel. This process will be lengthy, expensive, and carries a high risk of denial. It will require extensive public hearings and is likely to face strong community opposition (NIMBYism) due to the residential context.

Setbacks & Restrictions: Requires Verification. We must immediately review the Hanover Zoning Bylaw for any specific ordinances related to battery storage or energy facilities. Many Massachusetts towns have enacted moratoriums or highly restrictive bylaws with large property line setbacks (e.g., 200-500 feet), noise limitations (dBA at property line), and extensive safety/decommissioning requirements. The small size of this parcel may make it impossible to meet aggressive setback requirements.

5. IRA/ITC Incentive Analysis

This site is at a significant financial disadvantage from an IRA perspective.

• Opportunity Zone: No. (0% adder)
• Energy Community: No. (0% adder)
• Low-Income Community: No. (0% adder)

Potential Cumulative ITC: The project will only be eligible for the base 30% Investment Tax Credit, assuming it meets the Prevailing Wage and Apprenticeship (PWA) requirements. The lack of any 10% adders makes the project's economics less competitive compared to sites in designated Energy Communities or Brownfield locations. We must investigate Massachusetts-specific incentives, such as the Clean Peak Energy Standard or other state programs, to bridge this financial gap.

6. BESS Score & Rationale

Overall BESS Suitability Score: 48 / 1