⚡ 49 HASSEY ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 49 Hassey St, New Bedford, MA (APN: 201 037 0315)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at the subject property. The analysis covers key development pillars including site characteristics, environmental constraints, grid interconnection, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has direct frontage on Hassey Street, a paved, two-lane industrial road. A preliminary review of satellite imagery and street-level views indicates the road is in good condition and sufficiently wide to accommodate lowboy trailers for delivering battery containers, power conversion systems (PCS), and the main power transformer. There are no apparent vertical clearance issues (e.g., low bridges) or sharp turns on the immediate approach routes from major highways like I-195. Access appears robust for all phases of construction and operation.

Terrain Characteristics: The property is located in a flat, coastal region. The current land use within an established industrial park suggests the site has been previously graded and is likely level, with minimal topographical challenges. This significantly reduces earthwork and civil engineering costs. A formal topographical survey is required for detailed design but initial assessment is highly favorable.

Heavy Equipment Feasibility: Access is deemed feasible for all necessary heavy equipment, including a 100-ton crane for setting the transformer and battery enclosures. The industrial zoning and existing road infrastructure are well-suited for such activities.

Easement Concerns: Requires Verification. No access easements are immediately apparent, as the parcel has direct road frontage. However, a full title report and ALTA survey are critical to identify any utility easements (power, water, sewer) that may cross the property and constrain the buildable area. The parcel shape is a simple rectangle, reducing the likelihood of complex easement issues.

2. Environmental Constraints

FEMA Flood Zone: A preliminary check of the FEMA Flood Map Service Center (Map Panel 25005C0382G) indicates the property is located in Zone X, an area of minimal flood hazard. This is a significant advantage, as it obviates the need for costly mitigation measures such as building equipment on raised platforms and reduces insurance premiums.

Wetlands: Requires Verification. A desktop review of the U.S. Fish & Wildlife Service National Wetlands Inventory shows no mapped wetlands directly on the parcel. However, mapped freshwater forested/shrub wetlands are present in the vicinity. A formal wetlands delineation by a certified professional is a mandatory next step to confirm the absence of jurisdictional wetlands and to establish any required buffer zones, which could impact the site layout.

Critical Habitat / Endangered Species: The provided data indicates no critical habitat. This must be confirmed via a formal request to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) and a review of the USFWS IPaC database. Given the site's long-standing industrial use, the risk of sensitive species is considered low but must be formally cleared.

Brownfield/Superfund Status: The presence of 22 known contamination sites within a two-mile radius is a material concern. While this proximity raises the risk of potential contaminant migration onto the subject parcel, it also presents a significant opportunity. If the site itself can be classified as a "brownfield" per IRA guidelines (e.g., through a Phase I/II ESA identifying contamination), the project could qualify for the 10% ITC Brownfield Adder. This is a critical go/no-go diligence item. A Phase I ESA is an immediate and non-negotiable next step.

Pipeline Proximity: The absence of major gas pipelines within three miles is a positive finding, eliminating significant safety risks, setback complications, and coordination challenges with pipeline operators.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The nearest major substation is Eversource's ARSENE substation, located 2.4 miles away with a 115 kV bus. A 115 kV transmission line is slightly closer at 1.8 miles. For a ≤5MW project, these distances are economically prohibitive for a dedicated line extension or transmission-level tap, which would cost several million dollars.

Likely Interconnection Voltage & Feeder: The only viable path for this project is to interconnect to a local 13.8 kV distribution feeder. The critical unknown is the location, capacity, and voltage of the nearest 3-phase distribution line originating from the ARSENE substation (or another local circuit). The success of this project is entirely dependent on the presence of a suitable distribution feeder adjacent to or very near the site. This is the single greatest risk factor for the project.

Estimated Cost & Timeline: Requires Verification. If a suitable feeder is on Hassey Street, interconnection costs could be in the $500k - $1M range. If a feeder extension of even 0.5 miles is required, costs could escalate to $1.5M+. The Massachusetts/Eversource interconnection process is complex and can take 24-36 months from application to commercial operation. A pre-application report from Eversource is the highest priority action item.

Utility & Process: The interconnecting utility is Eversource (formerly NSTAR). The project would fall under the Massachusetts DPU state-level interconnection tariff. The queue is known to be congested, and hosting capacity on industrial feeders can be limited. Early engagement with the utility is paramount.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of New Bedford is the primary AHJ for all zoning, building, and electrical permits. The New Bedford Fire Department will be a key stakeholder for safety and NFPA 855 compliance.

Zoning Compatibility: The parcel is zoned IB (Industrial B). This is highly favorable for BESS development. Industrial zones typically permit utility infrastructure and power generation facilities. A review of the New Bedford zoning ordinance is needed to confirm if BESS is an explicitly defined use.

Permitting Pathway: The most likely pathway is a Special Permit and Site Plan Review from the New Bedford Planning Board. It is unlikely to be a by-right use. This process will involve public hearings and require detailed site plans, drainage reports, noise studies, and a decommissioning plan. Proactive engagement with city planners and officials is recommended.