⚡ 161 CHARLES ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 161 Charles St, North Attleborough, MA (APN: 12-227)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis identifies significant challenges related to grid interconnection costs, regulatory hurdles, and limited access to federal incentives, balanced against a few favorable site characteristics. The final recommendation is MAYBE, contingent on positive outcomes from critical near-term due diligence.

1. Site Access & Topography

Road Access & Feasibility: The property is located at 161 Charles Street, which appears to be a well-maintained, paved local road with direct access to US Route 1. This provides excellent primary access for both construction crews and equipment delivery. A preliminary review of aerial imagery suggests sufficient frontage for creating a dedicated construction entrance without significant disruption to public traffic.

Terrain & Equipment Access: As the site is currently developed for commercial use (auto repair), the topography is presumed to be flat and graded. This is highly advantageous, minimizing the need for extensive civil work. The existing layout likely includes paved or compacted gravel areas capable of supporting heavy loads. Access for critical heavy equipment, including a mobile crane for setting transformers and containerized BESS units, appears feasible directly from Charles Street. However, an on-site geotechnical survey will be required to confirm soil bearing capacity.

Easement Concerns: Requires Verification. A title search is necessary to identify any existing utility or access easements that may encumber the 2.68-acre parcel. An unseen pipeline or utility right-of-way could significantly reduce the buildable area and render the site unviable for a project of our target size (~5MW). The current commercial use makes this a moderate risk.

2. Environmental Constraints

Flood & Wetlands: Requires Verification. The FEMA flood zone designation and the presence of state or federal jurisdictional wetlands are currently unknown. This represents a critical data gap and a potential fatal flaw. A desktop screening using FEMA and National Wetlands Inventory (NWI) maps is an immediate next step. Any presence of a floodway would be a fatal flaw; siting within a 100-year floodplain would require elevated foundations and add significant cost. Wetland buffers, which can be up to 100 feet in Massachusetts, could severely constrain the buildable envelope on this small parcel.

Habitat & Protected Species: The provided data indicates no critical habitat or protected areas on or immediately adjacent to the site, which is a positive finding. This is consistent with a developed commercial corridor. We recommend a check of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-level concerns.

Brownfield/Superfund Status: The site itself is not listed, but the presence of four Superfund/brownfield sites within a two-mile radius, combined with its long-term use as an "Auto Repair" facility, creates a dual-sided issue.

• Risk: There is a high probability of on-site contamination (hydrocarbons, solvents, heavy metals). A Phase I Environmental Site Assessment (ESA) is mandatory. If contamination is found, a Phase II ESA and potential remediation would be required, adding significant cost and time.
• Opportunity: If the site meets the federal definition of a brownfield, it could qualify for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This potential incentive is a key factor in this site's financial viability and warrants aggressive investigation.

Pipeline Proximity: No gas transmission pipelines are identified within a three-mile radius, eliminating risks associated with pipeline setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Substation & Feeder: The nearest identified substation (UNKNOWN133437) is 1.3 miles away. This is a significant distance for a distribution-scale project and is the single largest challenge for this site. A new 1.3-mile dedicated feeder line would be required, likely involving extensive trenching or new pole sets along public rights-of-way. The substation voltage is unknown but is likely a standard distribution class (e.g., 13.8 kV). The interconnecting utility is the North Attleborough Electric Department (NAED), a municipal light plant (MLP). MLPs have unique interconnection processes, often less standardized than major IOUs, which can be both faster or more opaque.

Interconnection Voltage & Cost: Interconnection will be at the distribution level. The 345kV transmission line is not a viable option. The cost for a 1.3-mile feeder extension will be substantial. A preliminary, high-level estimate would be in the $1.5M - $3.0M+ range, depending on whether the route is overhead or underground and the complexity of the civil work. This high cost could make the project financially unviable.

Timeline & Process: Interconnection timelines with Massachusetts utilities are lengthy, often 24-36 months from application to commercial operation. While NAED's queue may be less congested than larger utilities, their experience with BESS interconnection must be verified. An early-stage inquiry