⚡ HARVEY ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 218 30_39_0 (Harvey St, Bristol County, MA)

This report provides a comprehensive due diligence analysis for the property located on Harvey Street in Bristol 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. The final recommendation is a NO GO for this site.

1. Site Access & Topography

• Road Access & Feasibility: The site has frontage on Harvey Street, which appears to be a two-lane, paved local road based on aerial imagery. This road connects to larger state routes (MA-123), suggesting that standard construction vehicle access is likely feasible. However, a formal route survey is required to confirm the absence of low-clearance bridges, weight-restricted roads, or sharp turns that would impede the delivery of oversized/overweight equipment like transformers and battery containers.
• Terrain Characteristics: Based on regional topography, the site is presumed to be relatively flat with some gentle rolling terrain, typical of southeastern Massachusetts. The parcel appears to be heavily wooded. Significant clearing and grading will be required, adding to site preparation costs. A formal topographic survey is necessary to confirm site conditions and inform the civil engineering design.
• Heavy Equipment Access: Direct access from Harvey Street to the parcel seems straightforward. The primary access challenge is not to the site itself, but for the electrical interconnection. A 1.3-mile gen-tie route to the Chartley Pond substation will require extensive access rights and construction feasibility analysis.
• Easement Concerns: While direct site access from the public road is likely, the project will require a significant new electrical easement for the 1.3-mile interconnection route. Acquiring these rights-of-way from multiple landowners can be time-consuming, costly, and may not be possible, posing a major risk to the project schedule and budget.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is listed as Requires Verification. This is a critical data gap. Any portion of the site within a 100-year floodplain (e.g., Zone A, AE) would be subject to significant development restrictions and would likely require all equipment to be elevated above the Base Flood Elevation, adding substantial cost. A high-risk flood zone could be a fatal flaw.
• Wetlands: The presence of wetlands is also listed as Requires Verification. Massachusetts has extremely stringent wetlands regulations under the Massachusetts Wetlands Protection Act. Given the wooded and undeveloped nature of the site, the presence of state or federally regulated wetlands is highly probable. A desktop screening using MassGIS data is an immediate priority, to be followed by a formal field delineation. Wetlands and their associated buffers could severely constrain the buildable area.
• Critical Habitat / Endangered Species: The initial screening shows no critical habitat on site. This is a positive indicator, but must be verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids environmental remediation risks, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, a significant financial disadvantage.
• Pipeline Proximity: No major pipelines are located near the site, eliminating risks associated with pipeline easements and safety setbacks.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The Chartley Pond substation is 1.3 miles away and has a maximum voltage of 115 kV. This distance is manageable for a gen-tie, but the voltage is a major concern. A 115 kV interconnection is a transmission-level connection, which is exceptionally complex and expensive for a small ≤5MW BESS project.
• Transmission Line Proximity: A 345 kV transmission line is only 0.1 miles away but is noted as "NOT AVAILABLE." This is typical for high-voltage lines, as tapping them for a small generator is technically and economically infeasible. This line should be considered irrelevant for our purposes.
• Recommended Interconnection Voltage: The ideal interconnection for a ≤5MW project is on a local 13.8 kV (or similar) distribution feeder. The data points only to a 115 kV transmission substation. It is possible a distribution bus exists within the Chartley Pond substation, but interconnecting there would still require a 1.3-mile distribution line buildout. A critical next step is to identify the nearest 3-phase distribution feeder, which may be closer than the substation itself. Assuming the only option is the 115kV bus, this site is not viable.
• Estimated Cost & Timeline:
  • Transmission (115 kV): Interconnection costs would likely be $3M - $7M+, including a step-up transformer, dead-end structures, and extensive protection equipment. The timeline through the ISO-New England queue would be 3-5+ years. This scenario makes the project