⚡ NEWPORT AVE

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 77_287_A (Newport Ave), Attleboro, MA

This report provides a comprehensive due diligence analysis for the 2.5-acre property located on Newport Ave, Attleboro, MA (APN 77_287_A) for its suitability as a distribution-scale Battery Energy Storage System (BESS) project. The analysis concludes that the site possesses multiple fatal flaws and is not a viable candidate for development.

1. Site Access & Topography

Road Access & Equipment Delivery: Initial desktop analysis using aerial imagery and county parcel data indicates a critical, likely fatal, flaw: the parcel appears to be completely landlocked. It is situated behind a row of single-family homes fronting Newport Avenue with no dedicated, deeded access road. Any access would require negotiating and purchasing a permanent, 50-foot-wide access and utility easement from an adjacent residential property owner. This process is fraught with risk, high cost, and a low probability of success.

Terrain Characteristics: Based on regional topography, the site is presumed to be relatively flat with minor undulations, which is generally favorable for BESS construction. However, this positive attribute is rendered irrelevant by the lack of access. Requires Verification: A formal survey and geotechnical study would be needed, but is not recommended given other site flaws.

Heavy Equipment Feasibility: Access for heavy equipment—including cranes for setting transformers and switchgear, and flatbed trucks for delivering battery containers—is currently impossible. Securing an easement wide enough to accommodate the turning radii and weight of construction vehicles would be a significant challenge and a primary point of negotiation with any potential seller of an easement.

Easement Concerns: The primary concern is the need to acquire a new, permanent easement for both construction and long-term operational access. This introduces significant project risk, timeline delays, and unpredictable costs. It would also likely face strong opposition from the residential community.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." A preliminary check of the FEMA Flood Map Service Center suggests the area is likely designated as Zone X, an area of minimal flood hazard. Requires Verification: A formal flood zone determination is required, but this is considered a low-to-moderate risk.

Wetlands: The wetlands status is "Unknown." This represents a significant risk. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act), and preliminary desktop screening of the area indicates a high probability of jurisdictional wetlands on or adjacent to the parcel. A formal wetland delineation would be required, which could severely limit or even eliminate the buildable area.

Critical Habitat / Endangered Species: The data indicates no known critical habitats or protected areas on the parcel, which is a positive factor. A standard desktop review using the USFWS IPaC tool is still recommended as a best practice.

Brownfield/Superfund Status: The site itself is not a brownfield. While a superfund site exists within two miles, it is unlikely to impact this parcel. The lack of brownfield status means the project is ineligible for the 10% IRA brownfield tax credit adder, making it less financially competitive.

Pipeline Proximity: No major gas pipelines are located within a three-mile radius, which is a significant safety and design advantage, eliminating the need for specialized setbacks and safety protocols related to pipeline hazards.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The nearest substation is National Grid’s Read Street Substation, located 1.4 miles away. This is a 115 kV transmission-level substation. For a ≤5MW BESS, a transmission-level interconnection is financially and technically infeasible. The project would need to interconnect to a local distribution feeder.

Recommended Interconnection: The only viable interconnection path is to a 3-phase distribution feeder, likely running along a nearby primary road. The key challenges are: 1) securing a utility easement from the landlocked parcel to the public right-of-way, and 2) the capacity of the local feeder. A feeder this far from the substation (1.4 miles) in a residential area may lack the thermal or voltage capacity to accommodate a 5MW injection without extensive and costly upgrades. Requires Verification: The interconnecting utility is presumed to be National Grid; this must be confirmed.

Estimated Cost & Timeline: Interconnection costs are estimated to be very high, likely in the $1.5M - $3.0M+ range. This includes the cost of a 1.4-mile line extension to the substation if the local feeder is not viable, or significant feeder upgrade costs. The ISO-New England (ISO-NE) interconnection queue process is notoriously long and complex, with timelines often exceeding 24-36 months for study and approval, even for distribution-scale projects.

Feeder Configuration: The likely point of interconnection would be an overhead 3-phase distribution line. The exact voltage (e.g., 13.8 kV) and available capacity are unknown and represent a major project risk.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Attleboro Planning Board and City Council.

Zoning Compatibility: The parcel is zoned SR-D (Single Residence D). This is a fatal flaw. A BESS is a utility/industrial use and is fundamentally incompatible with single-family residential zoning.

Permitting Pathway: The project would not be permitted by-right. It would require, at a minimum, a Use Variance from the Zoning Board of Appeals. This is an extremely difficult entitlement to secure, as it requires proving a legal hardship unique to the property. The likelihood of success is near zero, especially given the high potential for organized community opposition (NIMBYism) to an industrial facility in a residential neighborhood. A full rezoning application would be even more arduous.

Setbacks & Restrictions: Specific BESS setbacks are not defined in the residential code. Any approval would be subject to conditions imposed during a public hearing process, which would likely be highly restrictive. The risk of a project-specific or city-wide moratorium being enacted in response to this application is high.

5. IRA/ITC Incentive Analysis

The site's location offers no competitive advantages from Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA).

• Opportunity Zone: No. (0% adder)
• Energy Community: No. (0% adder)
• Low-Income Community: No. (0% adder)

Potential Cumulative ITC Adder: 0%. The project would only be eligible for the 30% base ITC, assuming prevailing wage and apprenticeship requirements are met. This lack of incentive stacking makes the project's economics significantly less attractive compared to sites that qualify for one or more adders.

6. BESS Score & Rationale

Overall BESS Suitability Score: 20 / 100

• Location (3/20): The site is landlocked within a residential neighborhood, making it fundamentally unsuitable for industrial development.
• Grid Access (5/25): While grid infrastructure is nearby, the distance to the substation is long for distribution, feeder capacity is a major unknown, and interconnection costs are projected to be prohibitively high.
• Environmental (7/15): The high likelihood of wetlands presents a significant constraint on the buildable area. Other environmental factors are minor.