⚡ HOME DEPOT DR

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 239 089-000-013-015, Plymouth, MA

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project located on Home Depot Dr, Plymouth, Massachusetts. The analysis covers key evaluation criteria to determine the site's viability for development.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on "Home Depot Dr," which strongly suggests excellent, pre-existing commercial-grade road access. A desktop review using satellite imagery confirms the site is adjacent to a major commercial corridor with wide, paved roads designed to accommodate heavy truck traffic, including tractor-trailers. This is a significant advantage, as it indicates that delivery of heavy equipment such as battery containers, inverters, and the main power transformer will be straightforward without the need for costly road improvements.

Terrain & Buildability: Located in a developed commercial area of Plymouth, the parcel appears to be relatively flat and cleared, likely graded during the development of the surrounding retail centers. This is highly favorable, as it will minimize civil engineering and site preparation costs. Heavy equipment should be able to access the buildable area of the site with minimal difficulty. There is a notable discrepancy in the provided data regarding parcel size (28.05 acres vs. 7.64 acres from Regrid). This must be clarified immediately via a title search and survey, as it dramatically impacts the potential project scale.

Easement Concerns: While direct access from a public road is a positive, a formal title search is required to identify any existing utility, access, or drainage easements that may encumber the property and restrict the buildable envelope. Given the commercial nature of the area, such easements are common and must be mapped onto the preliminary site design.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are listed as "Unknown." These are critical, potentially fatal-flaw risks, especially in Massachusetts, which has stringent environmental regulations under the Massachusetts Wetlands Protection Act. Any presence of regulated wetlands or location within a 100-year floodplain (Zone A/AE) would trigger significant setbacks, complex permitting through the local Conservation Commission, and potentially render a large portion of the site undevelopable. This is the highest priority for immediate investigation.

Brownfield/Superfund Status: The data notes one Superfund/brownfield site within a two-mile radius, but the subject parcel itself is not identified as such. This presents both a potential risk and an opportunity. A Phase I Environmental Site Assessment (ESA) is mandatory to ensure the property is clean. If the Phase I ESA identifies Recognized Environmental Conditions (RECs), it could be a liability. However, if the site can be formally classified as a brownfield under federal definitions, it could qualify for the 10% IRA brownfield tax credit adder, significantly improving project economics. This requires further investigation.

Other Constraints: The site is clear of critical habitats, protected areas, and nearby gas wells, which is a positive. Proximity to pipelines is not a concern. As the site is in Massachusetts, the Chesapeake Bay Critical Area regulations are not applicable.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The most likely POI is the distribution substation (TAP174345) located 1.1 miles from the site. The provided voltage of "-999999 kV" is a data error and must be verified. We assume this is a standard distribution substation, likely operating at 13.8 kV or 23 kV, which is ideal for our target ≤5MW project size. The nearby 345 kV transmission line is not a viable POI for a distribution-scale project due to the prohibitively high cost and complexity of a high-voltage interconnection.

Interconnection Cost & Timeline: A 1.1-mile line extension from the substation to the site will be a major project cost. A rough order-of-magnitude (ROM) cost for an overhead distribution line extension is $1M - $2M per mile. This could represent a substantial portion of the project budget and must be refined immediately. The interconnecting utility is likely Eversource. The interconnection process in Massachusetts is managed through ISO New England (ISO-NE), which has a notoriously long and complex queue process. Even for a distribution-level project, timelines from application to commercial operation can easily exceed 24-36 months.

Feeder Configuration: The likely feeder will be a standard three-phase overhead distribution circuit originating from the target substation. A pre-application report from the utility is essential to confirm the feeder has sufficient thermal capacity and hosting capacity to accommodate a 5MW BESS without requiring major upstream upgrades (e.g., a substation transformer replacement), which would add significant cost and delay.

4. Regulatory & Zoning Analysis

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

Zoning Compatibility: The parcel is zoned HC (Highway Commercial). BESS facilities are a relatively new use and are often not explicitly defined in municipal zoning bylaws. It is highly unlikely that a BESS would be considered a "by-right" use in an HC zone. The most probable permitting pathway will be a Special Permit and Site Plan Review from the Planning Board. This process involves public hearings and discretionary approval, introducing significant entitlement risk and potential for local opposition or onerous conditions of approval.

Regulations & Risks: We must conduct a thorough review of the Town of Plymouth's Zoning Bylaws to identify any specific regulations, setback requirements, or prohibitions related to battery storage or public utilities. There is a growing trend in Massachusetts municipalities to enact moratoriums on BESS development to allow time to create specific regulations. We must verify that no such moratorium exists or is planned in Plymouth.

5. IRA/ITC Incentive Analysis

Incentive Qualification: This is a major weakness of the site. According to the provided data, the property does not qualify for any of the key Investment Tax Credit (ITC) adders:

• Opportunity Zone: No
• Energy Community: No
• Low-Income Community: No

Cumulative ITC: Assuming the project meets prevailing wage and apprenticeship requirements, the project would only be eligible for the base 30% ITC. The lack of the 10% Energy Community or 10% Brownfield adder significantly diminishes the project's potential return on investment and makes it less competitive than sites that do qualify for these incentives.

6. BESS Score & Rationale

Overall BESS Suitability Score: 45/100

• Location (10/20): Sited