⚡ HARVEY ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

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

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 17.81-acre parcel located on Harvey Street in Norton, Bristol County, Massachusetts. The analysis concludes with a BESS Suitability Score and a final recommendation.

1. Site Access & Topography

Road Access & Feasibility: The subject parcel lacks direct frontage on Harvey Street, a two-lane, paved local road. Initial GIS analysis indicates the parcel is landlocked behind existing residential properties. This is a potential fatal flaw. Access would require a deeded, all-weather easement across an adjacent parcel. The quality of such an easement is critical; it must be wide enough (minimum 30-40 feet) and constructed to support heavy haul loads, including a 100-ton crane, a fully loaded 5 MVA transformer (approx. 60,000 lbs), and 40-foot battery containers. Any existing residential driveway would be insufficient.

Terrain Characteristics: Based on regional topography and aerial imagery, the site is presumed to be relatively flat with some wooded areas, which is typical for this part of Massachusetts. However, a formal topographical survey is required to confirm grades, identify any localized steep slopes, and plan for necessary civil work, which could include extensive tree clearing and grading.

Heavy Equipment Access: Assuming a suitable easement could be secured, Harvey Street itself appears capable of handling truck traffic. However, a route survey would be necessary to identify any potential obstructions such as low-hanging utility lines, narrow turns, or weight-restricted bridges between the site and major state highways.

Easement Concerns: This is the most significant risk in this category. The lack of direct road frontage and a confirmed, pre-existing, and legally sufficient access easement presents a high probability of project failure. Negotiating and purchasing a new easement would be time-consuming, expensive, and may not be possible. This requires immediate verification via a title search.

2. Environmental Constraints

FEMA Flood Zone: The FEMA designation is currently listed as "Unknown." This is a critical data gap. A desktop analysis using the FEMA Flood Map Service Center must be conducted immediately. If any portion of the buildable area falls within a Special Flood Hazard Area (SFHA), such as Zone A or AE, it would necessitate elevating all equipment above the Base Flood Elevation (BFE), significantly increasing civil engineering costs and potentially triggering more stringent local review.

Wetlands: The wetlands status is "Unknown." Massachusetts has some of the most stringent wetlands regulations in the country under the Wetlands Protection Act (WPA). A review of MassGIS OLIVER data layers is the first step to identify state-delineated wetlands. Any such features on or near the site would trigger, at a minimum, a 100-foot buffer zone where development is heavily restricted or prohibited. A formal wetland delineation by a certified professional would be required, and the presence of significant wetlands could render the site undevelopable.

Habitat & Species: The data indicates no critical habitat, which is a positive initial finding. This should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitats database to ensure no state-level concerns exist.

Brownfield/Superfund Status: The site is not a brownfield. While this avoids environmental remediation risk and liability, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, placing it at a financial disadvantage compared to qualifying sites.

Pipeline Proximity: No pipelines within 3 miles is a significant safety and layout advantage, eliminating setback requirements and explosion-risk concerns.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is CHARTLEY POND, 1.3 miles away, with a 115 kV voltage class. This is a transmission substation. Interconnecting a ≤5MW BESS at transmission voltage is financially and technically infeasible. The nearby 345kV line is similarly not a viable Point of Interconnection (POI). Our project requires a distribution-level interconnection.

Recommended Interconnection: The target POI would be a 3-phase, 13.8 kV (Requires Verification) distribution feeder, likely operated by National Grid, the incumbent utility in Norton. A desktop survey using satellite imagery suggests distribution poles run along Harvey Street. However, it is critical to verify if this is a 3-phase circuit with sufficient thermal and voltage capacity. If it is only single-phase, the cost to extend 3-phase power to the site could exceed $1M and kill project economics.

Cost & Timeline: Assuming a viable 3-phase feeder is adjacent to the property, interconnection costs could range from $750,000 to $2,000,000. This would cover the utility-side upgrades (recloser, protection, metering) and developer-side costs (line extension from the road to the BESS pad). The 1.3-mile distance to the substation is a negative indicator, as longer feeders often have less available capacity and are more prone to voltage issues, potentially triggering costly substation upgrades. The Massachusetts interconnection queue, managed under the DPU, is notoriously slow; timelines from application to construction can easily exceed 24-36 months.

Feeder Configuration: Requires immediate verification via a National Grid pre-application report. The viability of this entire project hinges on the presence of a suitable