⚡ 117-143 KING ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Bristol"

PROPERTY: 117-143 King St, New Bedford, Bristol County, MA (APN: 113 0099)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) on the 10.47-acre parcel located at 117-143 King Street in New Bedford, MA. The analysis covers key evaluation criteria including site access, environmental constraints, grid infrastructure, regulatory landscape, and incentive eligibility.

1. Site Access & Topography

Road Access: The property has direct frontage on King Street, which appears to be a two-lane, paved industrial road in adequate condition based on aerial and street-level imagery. King Street connects to other local industrial roads and provides straightforward access to Route 140 and Interstate 195 (less than 2 miles away), which is a significant advantage for equipment and construction logistics.

Terrain & Equipment Feasibility: Based on aerial imagery, the site appears to be predominantly flat, cleared, and previously disturbed, possibly with existing gravel or paved surfaces. This topography is highly favorable for BESS development, as it will likely minimize earthwork and grading costs. The existing access from King Street appears sufficient to accommodate heavy equipment, including flatbed trucks for battery containers, cranes for installation, and delivery of the main power transformer.

Easement Concerns: While direct road frontage is a positive, a full title search is required to identify any potential access restrictions, utility easements, or other encumbrances that could impact the site layout. Requires Verification: A preliminary title report must be ordered to confirm clear access and identify any restrictive easements.

2. Environmental Constraints

FEMA Flood Zone: A preliminary review of the FEMA Flood Map Service Center (Map Panel 25005C0387G) indicates the property is located entirely within Zone X. This is an area of minimal flood hazard, which is the most desirable designation for a critical infrastructure project like a BESS. This significantly de-risks the project from a flood perspective and simplifies permitting.

Wetlands: The provided data is unknown. A review of the U.S. Fish & Wildlife Service National Wetlands Inventory suggests the potential for some forested/shrub wetlands near the southern and western property boundaries. However, the primary buildable area in the center and north of the parcel appears clear. Requires Verification: A formal wetland delineation by a certified professional is a critical next step to confirm the absence of wetlands in the proposed development footprint and establish required setbacks.

Critical Habitat / Endangered Species: The initial screening shows no designated critical habitats or protected areas on the parcel, which is a positive finding. A desktop environmental review should be conducted to confirm no state-listed species of concern have habitats in the immediate vicinity.

Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a 2-mile radius is a significant finding. This indicates a high probability of historical industrial activity in the area, posing a risk of on-site contamination. This is a major risk that could lead to costly remediation. However, it also presents a critical opportunity: if the site itself can be classified as a brownfield under IRA guidelines, the project could qualify for the 10% Brownfield ITC Adder. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk and opportunity.

Pipeline Proximity: No major gas transmission pipelines are located within 3 miles of the site, eliminating a common safety and setback concern for BESS projects.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest major infrastructure is the ACUSHNET TAP substation, located 1.2 miles to the northeast. This is a 115 kV transmission-level substation operated by NSTAR ELECTRIC COMPANY (d/b/a Eversource Energy). While the presence of a nearby substation is positive, the 1.2-mile distance is a moderate concern for a distribution-scale project.

Interconnection Recommendation: Interconnecting a ≤5MW BESS at 115 kV is financially and technically infeasible. The optimal path is to interconnect to a local distribution feeder. Aerial imagery clearly shows three-phase overhead distribution lines running along King Street, likely originating from the Acushnet Tap substation. The recommended interconnection voltage is therefore at the local distribution level, likely 13.8 kV. Requires Verification: The interconnecting utility is presumed to be Eversource. A formal interconnection pre-application is necessary to confirm the Point of Interconnection (POI), feeder voltage, and available capacity.

Cost & Timeline Estimate: If a suitable POI is available on the distribution lines adjacent to the site