⚡ 236 W MAIN ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for Norton, MA (APN: 21_206_0)

This report provides a comprehensive due diligence analysis for the property located at 236 W Main St, Norton, MA, a 2.38-acre parcel being considered for a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid interconnection, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has excellent frontage directly on West Main Street (MA Route 123), a two-lane state-maintained road. This provides direct, high-quality paved access, which is a significant advantage for construction and operations.

Equipment Delivery: West Main Street appears to be a standard-width road suitable for heavy truck traffic. Low-boy trailers carrying battery containers (typically 40-53 feet) and large power transformers should be able to access the site entrance. However, a detailed turning radius analysis will be required to ensure trucks can safely enter and exit the property without significant traffic disruption or road modifications. The feasibility of a temporary construction entrance versus a permanent access point needs to be evaluated during the site planning phase.

Terrain & Topography: Based on aerial imagery and regional topography, the site appears to be relatively flat with minimal grade changes. This is highly favorable, as it will likely minimize earthwork and civil engineering costs. A formal topographic survey is required for confirmation, but significant grading challenges are not anticipated.

Easement Concerns: As the parcel has direct frontage on a public right-of-way, a dedicated access easement is not expected to be necessary. However, a title search must be conducted to identify any existing utility easements or other encumbrances that could cross the property and interfere with the proposed BESS layout.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This represents a critical and potentially fatal flaw risk. Any portion of the site within a 100-year floodplain (e.g., Zone A or AE) would impose severe restrictions, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing costs or rendering the site unusable. A FEMA FIRMette review is an immediate next step.

Wetlands: Requires Verification. The presence of wetlands is unknown. Massachusetts has stringent wetlands protection regulations, and the presence of jurisdictional wetlands could significantly reduce the 2.38-acre buildable envelope. Given the small parcel size, even a minor wetland feature with its associated buffer zone could make a 5MW BESS layout impossible. A desktop review using MassGIS OLIVER followed by a formal wetlands delineation by a certified professional is a high-priority diligence item.

Critical Habitat / Endangered Species: The initial screening shows no critical habitat or protected areas on site. This is a positive finding, reducing the risk of project delays or mitigation requirements from state (MA NHESP) or federal (USFWS) agencies. This should be confirmed via the official state databases.

Brownfield/Superfund Status: The site is not a known brownfield, and no superfund sites are located within a 2-mile radius. While this mitigates the risk of soil contamination and associated cleanup liability, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, which is a financial disadvantage.

Pipeline Proximity: No gas transmission pipelines are located within 3 miles. This eliminates risks associated with pipeline setbacks, explosion modeling, and consultations with pipeline operators, streamlining the permitting process.

3. Grid Infrastructure & Interconnection

Nearest Substation: The CHARTLEY P