⚡ 3 LAZYWOOD LN

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 3 LAZYWOOD LN, Swansea, MA (APN: 292 005.0_0000_0010.B)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS) on the 3.89-acre parcel at 3 Lazywood Lane in Swansea, Bristol County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The subject parcel has frontage on Lazywood Lane, a local road directly accessible from U.S. Route 6 (G.A.R. Highway), a major regional arterial. This primary access via a major highway is a significant advantage for the delivery of construction materials and BESS equipment. However, Lazywood Lane itself appears to be a smaller, potentially residential road.

Equipment Delivery: The critical delivery path will be from U.S. Route 6 onto Lazywood Lane. A detailed logistics study is required to confirm that the turn radius is sufficient for lowboy trailers carrying heavy equipment such as transformers and 40-foot battery containers. The load-bearing capacity and condition of Lazywood Lane must also be verified.

Terrain & Topography: Based on satellite imagery and regional topography, the site appears to be relatively flat and undeveloped, consisting primarily of mature woodland. This will necessitate significant site clearing and grading, adding to construction costs. The flat terrain is otherwise favorable for BESS construction, minimizing the need for extensive earthwork.

Easement Concerns: The parcel appears to have direct road frontage, minimizing the risk of needing off-site access easements. However, a title search is required to confirm that no restrictive easements or covenants exist that would impede access or development. We must also confirm Lazywood Lane is a public road suitable for commercial/industrial traffic.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. The site's relative proximity to the Palmer River and associated wetlands increases the risk that portions of the parcel may lie within a Special Flood Hazard Area (e.g., Zone A or AE). Any development within a designated flood zone would require significant mitigation, such as elevating all equipment above the Base Flood Elevation, which can render a project economically unviable. Immediate verification using the FEMA Flood Map Service Center is required.

Wetlands: The presence of wetlands is Unknown but highly likely given the undeveloped, wooded nature of the site and its location in a coastal Massachusetts region. Massachusetts has stringent wetland protection regulations under the Wetlands Protection Act. A formal wetlands delineation will be required to identify any jurisdictional wetlands and associated buffer zones (typically 100 feet), which could severely constrain the buildable area of this 3.89-acre parcel.

Critical Habitat / Species: The initial screen shows no designated critical habitat on site. This is a positive finding. However, a more detailed desktop analysis using state-level resources like MassGIS is recommended to screen for any state-listed endangered or threatened species whose habitats may be present.

Brownfield/Superfund Status: The data indicates one Superfund/brownfield site within a two-mile radius, but not on the subject parcel itself. This presents a minor risk of potential contaminant migration that should be assessed in a Phase I Environmental Site Assessment (ESA). Importantly, because the project site itself is not a designated brownfield, it is ineligible for the 10% IRA brownfield bonus credit, which is a significant economic disadvantage.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and potential operational hazards.

3. Grid Infrastructure & Interconnection

Nearest Substation: The SWANSEA substation is located approximately 1.6 miles from the site. This is a challenging distance for a distribution-scale project. The substation has a 115 kV bus, indicating it is a transmission-level asset that also steps down to distribution voltages.

Interconnection Feasibility: The most likely Point of Interconnection (POI) would be a 3-phase distribution feeder originating from the SWANSEA substation, likely running along U.S. Route 6. A 1.6-mile distribution line extension (gen-tie line) will be required. This is a major cost driver.

Recommended Voltage & Cost: Interconnection will be at a distribution voltage, likely 13.8 kV. The estimated cost for a 1.6-mile overhead/underground line