⚡ 275 COLLINS CORNER RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis – "Project Dartmouth"

PROPERTY: 275 Collins Corner Rd, Dartmouth, MA 02747 (APN: 072 79_8)

This report provides a comprehensive due diligence analysis for the subject property's suitability for a distribution-scale or utility-scale Battery Energy Storage System (BESS). The analysis concludes that while the site possesses exceptional grid infrastructure proximity, it faces significant regulatory and environmental risks that must be aggressively mitigated before further capital is committed.

1. Site Access & Topography

Road Access: The 10.05-acre parcel has direct frontage on Collins Corner Road, a two-lane, paved local road. A preliminary desktop review indicates the road is in fair condition and appears sufficiently wide to accommodate standard semi-trucks for the delivery of battery containers, inverters, and medium-voltage transformers. There are no obvious low-clearance bridges or sharp turns on the immediate approach routes.

Topography & Site Conditions: Satellite imagery shows the parcel is heavily wooded and appears to be relatively flat, which is typical for this region of Bristol County. While the flat terrain is advantageous for minimizing civil engineering and grading costs, the dense tree coverage will necessitate significant clearing and grubbing, adding to site preparation expenses and potentially triggering local tree removal ordinances.

Heavy Equipment Feasibility: Access for heavy equipment, including a large crane for setting the main power transformer (MPT) and switchgear, appears feasible directly from Collins Corner Road. A temporary construction entrance with a stabilized access drive will be required.

Easement Concerns: As the property has direct road frontage, a primary access easement is not anticipated. However, a utility easement will be required to construct the ~0.1-mile generation tie-line to the target 115kV transmission line. The path for this easement appears to cross undeveloped land, but the ownership and willingness of the adjacent landowner(s) to grant an easement is a critical unknown.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA status is unknown and represents a critical data gap. A formal flood zone determination is required immediately. If the buildable area is within a Special Flood Hazard Area (e.g., Zone AE), it could render the site undevelopable or require costly mitigation, such as elevating all equipment above the Base Flood Elevation, which is often impractical for BESS.

Wetlands: Requires Verification. The presence of wetlands is unknown and is the most significant environmental risk. Desktop screening using state GIS layers is necessary, but a formal wetland delineation by a certified professional will be required. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), typically enforcing a 100-foot buffer zone from delineated wetland boundaries. The presence of significant wetlands could severely restrict the buildable acreage.

Critical Habitat / Endangered Species: The initial screen shows no critical habitat. However, this must be confirmed via the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database. If the site falls within a Priority Habitat, development could be restricted or require time-consuming consultations and mitigation plans.

Brownfield/Superfund Status: The site is not a brownfield. While this indicates a clean environmental history, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable financial disadvantage compared to alternative sites.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating the need for specialized setbacks and safety consultations with pipeline operators.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's primary strength is its exceptional proximity to high-voltage infrastructure. An NSTAR (Eversource) 115kV transmission line is located just 0.1 miles from the parcel boundary. The High Hill Switching Station (115kV) is 1.0 mile away, confirming the robustness of the local transmission network.

Recommended Interconnection: A transmission-level interconnection at 115kV is the most logical and valuable pathway. This would allow for a larger utility-scale project (>5MW) to participate in ISO-New England wholesale markets. While distribution lines are present on Collins Corner Road for a smaller project, the capacity on those feeders is unknown and likely limited. The 115kV tap is the superior strategy.

Cost & Timeline Estimate: Interconnecting at 115kV is a capital-intensive and lengthy process.

• Cost: Expect an estimated range of $4M - $9M for the required 3-breaker ring bus switchyard, MPT, protection and controls, and the short gen-tie line. This is a rough, high-level estimate pending a formal study.
• Timeline: The ISO-New England interconnection queue is notoriously slow. A realistic timeline from application submission to commercial operation is 36-48 months, subject to study delays and network upgrade requirements.

Utility & Process: The interconnecting utility is Eversource, and the RTO is ISO-NE. We would need to enter the formal ISO-NE interconnection queue, a complex process requiring specialized engineering support and significant financial securities.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): Town of Dartmouth, MA.

Zoning Compatibility: The parcel is zoned SR-B (Single Residence B). This is a highly unfavorable zoning designation for an energy facility. BESS is not a by-right use and is likely not explicitly defined in the town's zoning bylaws.

Permitting Pathway: The project will, at a minimum, require a Special Permit from the Dartmouth Planning Board. It is also highly likely that a Use Variance from the Zoning Board of Appeals (ZBA) will be necessary, which has a much higher legal threshold to meet. This discretionary process is a major project risk, as it