⚡ 665 WAREHAM ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – 665 Wareham St, Middleborough, MA (APN: 110-2588)

This report provides a comprehensive due diligence analysis for the property located at 665 Wareham Street in Middleborough, Plymouth County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

The subject property is located directly on Wareham Street (MA Route 28), a major state-numbered highway. This provides excellent, high-quality road access for both construction and operational phases. Preliminary review of satellite imagery indicates the road is a two-lane paved highway capable of supporting heavy truck traffic.

• Equipment Delivery: Access from a state highway is a significant advantage. The delivery of heavy equipment, including multi-ton transformers, switchgear, and containerized battery systems via flatbed trucks, appears highly feasible without requiring significant local road upgrades. A formal route survey would be required prior to transport.
• Terrain Characteristics: The site appears to be relatively flat and heavily wooded. This topography is generally favorable for BESS development, as it should minimize the need for extensive civil grading work, thereby reducing site preparation costs. However, significant tree clearing will be required, which will be a line item in the construction budget and may be a factor in local permitting.
• On-Site Access: An access road will need to be constructed from Wareham Street onto the project site. The exact path and length will depend on the final BESS location within the parcel.
• Easement Concerns: A significant data discrepancy exists regarding parcel size (2.01 acres vs. 45.55 acres). Assuming the larger 45.55-acre parcel is the target, we must confirm that the entire parcel is under single ownership and that no prohibitive internal easements (e.g., conservation, utility) exist. An access easement from the public right-of-way is not anticipated to be an issue given the direct road frontage.

2. Environmental Constraints

The environmental profile presents several critical unknowns that represent a primary risk factor for this site. Massachusetts has stringent environmental protection regulations that will heavily influence the developable area.

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. Any location within a Special Flood Hazard Area (e.g., Zone A, AE) would introduce significant design challenges and costs, requiring all equipment to be elevated above the Base Flood Elevation, or could render the site undevelopable. This is a potential fatal flaw that must be investigated immediately.
• Wetlands: Requires Verification. The presence of wetlands is unknown but highly likely given the site's wooded nature in this region of Massachusetts. The Massachusetts Wetlands Protection Act imposes strict regulations, including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A formal wetlands delineation by a certified professional is a mandatory, high-priority due diligence step. The outcome will directly determine the net buildable acreage.
• Critical Habitat / Species: The initial screening indicates no critical habitat or protected areas on site, which is a positive finding. This should be confirmed through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database as part of a formal environmental review.
• Brownfield/Superfund Status: The site is not a known brownfield, which avoids potential remediation costs and liabilities. However, this also means the project is ineligible for the 10% ITC adder for projects on brownfield sites under the Inflation Reduction Act (IRA).
• Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and design advantage, eliminating setback requirements and explosion-risk concerns often associated with co-locating BESS and gas infrastructure.

3. Grid Infrastructure & Interconnection

Grid access is a mixed bag, with proximity to high-voltage infrastructure that may not be suitable for a distribution-scale project. The project's viability is entirely dependent on the availability of a suitable distribution-level connection point.

• Substation & Transmission: The site is 1.0 mile from the SEMASS TAP substation and 0.6 miles from a 115kV transmission line. While geographically close, a 115kV transmission-level interconnection for a ≤5MW BESS is typically cost-prohibitive, often running upwards of $5 million and involving a lengthy ISO New England (ISO-NE) study process. This is not a recommended pathway for a project of this scale.
• Interconnecting Utility: The local utility is the Middleborough Gas and Electric Department (