⚡ 100 WILLIAMS ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – 100 Williams St, Dighton, MA (APN: 076/002.0-0020-0000.0)

1. Site Access & Topography

The subject property, an 8.76-acre parcel, exhibits strong physical access characteristics. It is located at 100 Williams Street, which is also designated as Massachusetts Route 138. This is a major state-maintained road, ensuring high-quality, year-round access suitable for heavy construction traffic. Preliminary review of aerial imagery indicates the site has significant direct frontage along this route, which should simplify the creation of construction and permanent access points.

The terrain appears to be relatively flat and previously graded, consistent with its current use as a commercial gas station. This is highly advantageous, as it will likely minimize civil engineering and site preparation costs. The ability for heavy equipment, including tractor-trailers delivering battery containers, switchgear, and pad-mount transformers, to access the site is considered excellent. The primary concern is not the external road network, but the internal circulation once on-site, which will be dictated by the layout of the existing gas station infrastructure that must be demolished.

No immediate access easement concerns are apparent, as the property fronts a public right-of-way. However, a full title report is required to identify any potential utility easements or other encumbrances crossing the property that could restrict the developable area or complicate internal access routes for construction and maintenance.

2. Environmental Constraints

The environmental profile of this site presents a mixed but significant set of risks that require immediate investigation.

• FEMA Flood Zone: The flood zone designation is currently unknown. Requires Verification. Given the site's relative proximity to the Taunton River, a formal FEMA Flood Insurance Rate Map (FIRM) analysis is a critical next step. Any designation within a 100-year floodplain (e.g., Zone AE) would impose significant design constraints, requiring elevated equipment pads and potentially rendering portions of the site undevelopable.
• Wetlands: The presence of wetlands is unknown. Requires Verification. Bristol County is known for extensive wetland systems. A desktop screening using Massachusetts' MassGIS OLIVER mapping tool is the immediate first step, to be followed by a formal wetlands delineation by a certified professional if the screening indicates potential resources on or near the parcel. State and local wetland setback requirements could materially reduce the buildable acreage.
• Brownfield/Superfund Status: While no Superfund sites are listed nearby, the property's current use as a gas station creates a high probability of on-site contamination from Leaking Underground Storage Tanks (LUSTs). This is a major risk that necessitates a Phase I Environmental Site Assessment (ESA) immediately. If contamination is found, a Phase II ESA (soil and groundwater testing) and subsequent remediation will be required, adding significant cost and time. However, this risk could also be an opportunity; if the site qualifies as a "brownfield site" under CERCLA § 101(39), it could be eligible for the 10% Energy Community ITC adder, which would be a major economic benefit.
• Critical Habitat & Pipelines: The site shows no signs of critical habitat or proximity to major pipelines, which are significant positives that de-risk the project from these specific environmental and safety standpoints.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents the single greatest challenge and a potential fatal flaw for this project. The nearest substation, Cleary Flood, is 3.1 miles away. For a distribution-scale project (≤5MW), this distance is economically prohibitive for a dedicated line extension, which could cost upwards of $3-6 million. The project's viability is therefore entirely dependent on the presence of a suitable three-phase distribution feeder directly adjacent to the site along Williams Street (Route 138).

The interconnecting utility is presumed to be National Grid. The likely interconnection voltage would be at the distribution level, typically 13.8kV in this region. Requires Verification. A formal pre-application report or feasibility study must be submitted to National Grid immediately to confirm:

1. The existence, voltage, and phase of the feeder(s) along the property frontage.
2. The available thermal and voltage capacity of the local circuit to accommodate a 5MW injection.
3. A high-level cost estimate for the interconnection and any required system upgrades.

4. Regulatory & Zoning Analysis

The regulatory outlook is a significant strength for this site. The Authority Having Jurisdiction (AHJ) is the Town of Dighton. The parcel's zoning is listed as "B" (Business), which aligns with its commercial use. Crucially, a review of Dighton's bylaws reveals the town has proactively adopted a specific "Battery