⚡ MARGESON LN # 7-18

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 173 16.0_45.0 (Margeson Ln, Mattapoisett, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project on a 2.83-acre parcel in Mattapoisett, Plymouth County, MA. The analysis covers critical site attributes, including access, environmental constraints, grid infrastructure, regulatory hurdles, and incentive eligibility. The findings indicate significant, likely fatal, flaws for BESS development at this location.

1. Site Access & Topography

• Road Access & Equipment Delivery: The property is located on Margeson Lane, which, based on preliminary mapping, appears to be a minor, local residential road. It is potentially narrow, unpaved, or has a low weight rating, which would pose a significant challenge for heavy equipment delivery. The feasibility of transporting multi-ton battery containers, transformers, and cranes via this route is highly questionable without significant road improvements. A physical site visit to verify road width, surface condition, turning radii, and any posted weight limits is a critical and immediate next step.
• Terrain Characteristics: As a coastal Massachusetts town, Mattapoisett's topography is likely flat to gently rolling. This is generally favorable for construction, minimizing the need for extensive grading. However, low-lying coastal terrain increases the risk of encountering a high water table or poor soil conditions, which would require deeper foundations and increase civil engineering costs. A geotechnical study would be required to confirm soil bearing capacity.
• Heavy Equipment Accessibility: The primary concern is the "last mile" access via Margeson Lane. If the lane is inadequate, the project would be non-viable unless a new, heavy-haul-rated access road can be constructed from a more substantial public road. This would add significant cost and complexity.
• Easement Concerns: Access to the parcel via a private or shared lane like Margeson Lane raises immediate concerns about legal access rights. A title search is required to confirm that a sufficient legal easement for ingress, egress, and utility purposes exists. If one does not exist or is insufficient for commercial traffic, negotiating a new easement with neighboring landowners would be time-consuming and costly, with no guarantee of success.

2. Environmental Constraints

• FEMA Flood Zone: The flood zone designation is currently unknown. This is a critical data gap. Given the site's location in a coastal community, there is a high risk it falls within a Special Flood Hazard Area (e.g., Zone AE or VE). Development within these zones requires that all equipment be elevated above the Base Flood Elevation (BFE), adding substantial structural and cost burdens. If located in a high-risk zone like a coastal VE zone or a floodway, development may be prohibited entirely.
• Wetlands: The presence of wetlands is unknown. Massachusetts has extremely stringent wetland protection regulations (Massachusetts Wetlands Protection Act). The presence of regulated wetlands on or adjacent to the 2.83-acre parcel could severely restrict or eliminate the buildable area due to mandatory buffer zones (typically 100 feet). A formal wetland delineation is essential and represents a major potential fatal flaw.
• Critical Habitat / Endangered Species: The initial data indicates no critical habitat on site, which is a positive finding. However, a desktop screening should still be performed to confirm there are no state or federally listed species with habitat in the vicinity that could be impacted by the project.
• Brownfield/Superfund Status: The site is not a brownfield. While this means a clean development slate and lower environmental liability, it also means the project is ineligible for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA), placing it at a competitive disadvantage.
• Pipeline Proximity: No major gas pipelines are located nearby, which is a positive safety factor, simplifying site layout and eliminating the need for specialized pipeline-related safety and setback studies.

3. Grid Infrastructure & Interconnection

• Nearest Substation & Transmission: The nearest identified grid infrastructure is a 115kV transmission-level substation located 1.0 mile from the site. Interconnecting a small-scale (≤5MW) BESS project at 115kV is economically infeasible. The cost of a 1-mile transmission line extension, a new bay at the substation, and a project-side step-up substation would likely exceed $5-10 million, rendering the project unfinanceable.
• Recommended Interconnection: The only viable path for a project of this scale is to interconnect to a local 3-phase distribution feeder, typically operating at 13.8kV in this region (