⚡ 990 ELM ST

MEMORANDUM

TO: Sunland America Corp. Investment Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 990 Elm St, Bridgewater, MA (APN: 042 30_21_0)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at 990 Elm Street in Bridgewater, Plymouth County, Massachusetts. The 2.57-acre parcel is zoned for industrial use and possesses compelling grid infrastructure proximity. However, significant risks related to environmental constraints and a lack of federal incentive adders must be carefully considered.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has direct frontage on Elm Street, a two-lane, paved road common in industrial parks. Based on satellite and street-level imagery, the road appears to be in good condition and suitable for heavy truck traffic, including flatbeds for battery containers and heavy-haul trucks for the main power transformer. The entrance to the property appears wide enough for standard construction vehicles.

Terrain Characteristics: The property is located in an established industrial area and is currently designated for warehouse use. This strongly suggests the site is already graded and relatively flat, which is ideal for BESS construction as it minimizes civil engineering costs. The surrounding topography in this region of Massachusetts is generally characterized by gentle, rolling hills, but this specific parcel appears to have been developed for industrial purposes, mitigating significant topographical challenges.

Heavy Equipment Feasibility: Access for critical heavy equipment is deemed highly feasible. The primary concern would be confirming that Elm Street and any local bridges between the site and the nearest major highway (e.g., Route 24) do not have prohibitive weight restrictions. Turning radii from Elm Street onto the property should be sufficient for a 53-foot trailer.

Easement Concerns: Requires Verification. No access easements are anticipated as the property has direct road frontage. However, a full title report is required to identify any existing utility easements (for gas, water, sewer, or electrical) that could cross the property and constrain the buildable area. Given the adjacent transmission line, a right-of-way easement is almost certainly present along one of the property boundaries.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown and represents a critical risk. A review of the FEMA Flood Insurance Rate Map (FIRM) is an immediate next step. If the site is located within a 100-year floodplain (Zone AE) or a 500-year floodplain (Zone X-shaded), development could be prohibited or require costly mitigation, such as elevating all equipment above the Base Flood Elevation (BFE), rendering the project economically unviable.

Wetlands: Requires Verification. The presence of wetlands is unknown. Massachusetts has stringent wetland protection laws under the Massachusetts Wetlands Protection Act. A desktop screening using MassGIS and National Wetlands Inventory (NWI) data is required immediately. Any potential wetlands on or near the site would trigger significant buffer/setback requirements (typically 100 feet), which could severely limit the 2.57-acre parcel's buildable area. A formal wetlands delineation by a certified professional will be necessary if the desktop screening indicates a risk.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on site. This is a positive finding, but should be confirmed via the USFWS IPaC tool and a query of the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species are present.

Brownfield/Superfund Status: The presence of two brownfield/superfund sites within a two-mile radius indicates historical industrial activity in the area. This is a double-edged sword. It presents a risk that our target parcel could have legacy contamination requiring remediation. However, if the site itself can be officially designated as a brownfield (per the definition in CERCLA), it could qualify for the 10% IRA Brownfield Tax Credit Adder. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk and opportunity.

Pipeline Proximity: No gas transmission pipelines are located within three miles of the site, which is a significant safety and permitting advantage, eliminating a major hazard from consideration.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's primary strength is its grid proximity. It is located just 1.2 miles from the major 345 kV BRIDGEWATER substation and, critically, has an existing 345 kV transmission line directly adjacent ("0.0 mi"). This proximity minimizes the need for extensive line construction.

Recommended Interconnection: For a distribution-scale project (≤5MW), a 345 kV transmission-level interconnection is financially infeasible, as it would require a new, multi-million-dollar switching station. The viable path is a distribution-level interconnection. There appear to be 3-phase overhead distribution lines running along Elm Street. Verification of the feeder voltage (likely 13.8 kV) and available capacity with the utility is a top priority. The interconnecting utility is presumed to be National Grid.

Cost & Timeline Estimate: Assuming a viable distribution feeder is present on Elm Street, the interconnection cost for a 5 MW BESS could range from $750,000 to $2,000,000. This would cover the utility-side upgrades, line extensions, and protection equipment. The interconnection process would be managed through the ISO New England (ISO-NE) queue, which is known for being lengthy and complex. The estimated timeline from application submission to commercial operation is typically 24-48 months.

Feeder Configuration: The likely point of interconnection (POI) would be a tap off the existing overhead distribution feeder on Elm Street, with a short underground run into the project site switchgear. A detailed system impact study will be required to determine the extent of upgrades needed on the local circuit.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Bridgewater, MA.

Zoning Compatibility: The current zoning is "Industrial (General) - Warehouse" (IE). This is highly favorable, as BESS is often considered a compatible light industrial or utility use. It is unlikely to face fundamental use-based opposition in an industrial zone.

Permitting Pathway: Requires Verification. A review of the Town of Bridgewater's zoning bylaws is necessary. It is unlikely that BESS is a "by-right" use. The most probable permitting pathway is a Special Permit from the Bridgewater Planning Board. This process involves site plan review, public hearings, and potential conditions of approval. It introduces