⚡ SONGBIRD DR

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for SONGBIRD DR, Dartmouth, MA (APN: 072 66_2_142)

This report provides a comprehensive due diligence analysis for a 13.17-acre parcel located on Songbird Drive in Dartmouth, 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 due to fundamental and likely insurmountable challenges related to zoning, grid access, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property is located at the end of Songbird Drive, which appears to be a paved, two-lane residential cul-de-sac. Access for standard vehicles is excellent; however, access for heavy construction equipment presents a significant risk. Delivery of multi-ton battery containers, switchgear, and pad-mount transformers requires wide roads with generous turning radii and no weight restrictions or low-hanging overhead utility lines. Songbird Drive is unlikely to meet these criteria without significant disruption to local residents.

Terrain & Site Preparation: Based on aerial imagery and regional topography, the parcel is heavily wooded and appears to have some rolling terrain. Significant site work, including extensive tree clearing, grubbing, and grading, will be required to create a level pad for the BESS equipment. This will increase construction costs and may trigger additional environmental review, such as stormwater management permitting under the EPA's Construction General Permit (CGP) and local conservation commission review.

Heavy Equipment & Easements: A new access road will need to be constructed from the end of Songbird Drive onto the parcel. The feasibility of this depends on frontage, slope, and potential environmental features (e.g., wetlands) near the road. We must verify that no existing access easements for other properties encumber our proposed development area. The residential nature of the access route is a primary logistical and community relations challenge.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Requires Verification. This is a critical data gap. If any portion of the planned equipment pad falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment above the Base Flood Elevation (BFE), adding substantial cost and complexity. Any development within a flood zone would trigger a more intensive permitting process.

Wetlands: The presence of wetlands is Requires Verification but is considered highly likely given the undeveloped, wooded nature of the site in coastal Massachusetts. The Massachusetts Wetlands Protection Act (WPA) and local Dartmouth bylaws impose stringent regulations, including a typical 100-foot buffer zone ("Riverfront Area") around perennial streams and a 100-foot buffer around Bordering Vegetated Wetlands (BVW). The presence of significant wetlands could severely reduce or eliminate the buildable area, rendering the site unviable.

Habitat & Other Risks: The site has no known federal critical habitat or proximity to superfund sites. The lack of a brownfield designation means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a competitive disadvantage. While no critical habitat is noted, a review of the MA Natural Heritage & Endangered Species Program (NHESP) database is required to screen for state-listed species whose presence could trigger project delays and mitigation requirements. The absence of nearby pipelines is a notable positive, eliminating a common safety and setback concern.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The provided data identifies only high-voltage transmission infrastructure. The nearest substation (TAP135408) is 1.9 miles away and the nearest transmission line is 1.5 miles away, both operating at 115 kV. For a ≤5MW BESS project, a transmission-level interconnection is financially and technically infeasible. The cost for a 1.5+ mile 115kV line extension and a new bay at an existing substation would likely exceed $5 million and take over three years, making the project uneconomical.

Recommended Interconnection & Feasibility: