⚡ WEST 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 083 23_7_0 (WEST ST, East Bridgewater, MA)

This report provides a comprehensive due diligence analysis for the subject property located on West Street in East Bridgewater, 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 property is identified by the address "WEST ST," indicating it likely has direct frontage on a public right-of-way. However, the quality of this access is a critical unknown.

• Road Access Quality: Requires Verification. A site visit is necessary to determine if West Street is a paved, public road capable of supporting heavy truck traffic. We must assess for any weight-limited bridges, sharp turns, or low-hanging utility lines between the site and major state highways.
• Terrain Characteristics: The land use designation as "Timberland, Forest, Trees" strongly suggests the site is currently undeveloped and wooded. This implies that significant tree clearing, grading, and site preparation will be required, adding to construction costs. The natural topography is unknown and a desktop topographic analysis followed by a formal survey will be necessary to identify suitable, relatively flat areas for the BESS pad, transformer, and switchgear.
• Heavy Equipment Feasibility: Access for heavy equipment, including cranes for setting transformers and multi-axle trucks for delivering battery containers, is contingent on the quality of West Street and the entry point onto the parcel. A temporary construction entrance with appropriate stabilization (e.g., crushed stone over geotextile fabric) will almost certainly be required. The feasibility is currently uncertain and poses a moderate risk.
• Easement Concerns: Requires Verification. A preliminary title report is needed to identify any existing access, utility, or conservation easements that may encumber the property and restrict the developable area. We must also confirm that the planned access point from West Street does not cross any neighboring property lines, which would necessitate negotiating a new access easement.

2. Environmental Constraints

Environmental factors present the most significant data gaps and potential "fatal flaws" for this site. Massachusetts has stringent environmental regulations, particularly concerning wetlands.

• FEMA Flood Zone: The designation is "Unknown." This is a critical risk. Any location within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable for critical infrastructure like a BESS or require significant and costly elevation of all equipment, making the project economically unviable. This must be determined immediately via FEMA's Map Service Center.
• Wetlands Presence: The status is "Unknown." Given the forested nature of the parcel in New England, the presence of state- and federally-jurisdictional wetlands is highly probable. A desktop screening is the first step, but a formal wetlands delineation by a certified professional will be mandatory. The Massachusetts Wetlands Protection Act imposes significant buffer zones (typically 100 feet) from delineated wetlands, which could severely constrain the buildable acreage.
• Critical Habitat / Endangered Species: The data indicates no known critical habitat on site, which is a positive initial finding. However, this should be confirmed through the state's Natural Heritage & Endangered Species Program (NHESP) database, as a formal project review may still be required.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids environmental remediation liabilities, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, which is a competitive disadvantage.
• Pipeline Proximity: No major gas pipelines are located nearby, mitigating risks associated with pipeline easements, setbacks, and safety protocols. This is a minor positive.

3. Grid Infrastructure & Interconnection

The site's primary strength lies in its excellent proximity to robust grid infrastructure. This is a major advantage that warrants further investigation despite other challenges.

• Nearest Substation: The EAST BRIDGEWATER substation is only 0.8 miles away. This is an ideal distance that minimizes the cost and complexity of the generator lead line. The substation's 115 kV maximum voltage indicates it is a significant node on the grid, with a high likelihood of having multiple distribution feeders and available capacity.
• Transmission Line Proximity: A 115 kV transmission line is even closer, at 0.6 miles. This provides a theoretical, albeit much more expensive, interconnection option for a larger utility-scale project.
• Recommended Interconnection: For a distribution-scale (≤5MW) project, the recommended Point of Interconnection (POI) would be a 13.8 kV (or similar) distribution feeder originating from the EAST BRIDGEWATER substation. This avoids the prohibitive costs and complexity of a 115 kV transmission-level tap.
• Estimated Cost & Timeline: A sub-mile, three-phase distribution line extension could range from $500,000 to $1.5 million, depending on pole requirements, road crossings, and utility make-ready work. The interconnection process in Massachusetts falls under ISO New England (ISO-NE) and the state's DPU. The interconnecting utility is likely National Grid. The queue process is extensive and can take 18-36 months from application to commercial operation.
• Feeder Configuration: Requires Verification. We must submit a pre-application report request to the utility to identify the specific feeder(s) serving the area, their current loading, and whether they are 3-phase, which is required for a BESS project of this scale.

4. Regulatory & Zoning Analysis

Regulatory approval presents a high degree of uncertainty and risk. The provided data contains conflicting zoning information which must be clarified immediately.

• Authority Having Jurisdiction (AHJ): The Town of East Bridgewater, specifically its Planning Board and/or Zoning Board of Appeals (ZBA).
• Zoning Compatibility: There is a critical conflict in the data. The parcel is listed as "Agricultural/Rural - Timberland" (Code: 100) and also "R-2" (Residential). If zoned Agricultural, a BESS may be permissible as a utility use via a special permit. If it is R-2 Residential, the project will face extreme difficulty and likely be prohibited, requiring a use variance which has a very high bar for approval in Massachusetts. This discrepancy is a top-priority risk to resolve.
• Permitting Pathway: A BESS is almost never a "by-right" use. The most likely pathway, assuming favorable zoning, would be a Special Permit from the Planning Board. This process involves public hearings, site plan review, and potential conditions of approval. A use variance from the ZBA would be a path of last resort