⚡ 27 HEALY ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 27 Healy St, New Bedford, MA (APN: 111 0150)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at 27 Healy Street in New Bedford, MA. The analysis evaluates the site's suitability based on key development criteria, including access, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The subject property is located on Healy Street within an established industrial park in the northern part of New Bedford. Preliminary review via satellite imagery indicates that Healy Street is a paved, two-lane industrial road connected to the local road network, including Coffin Ave and the Route 140 highway. Access appears adequate for standard construction vehicles.

Equipment Delivery: The industrial nature of the surrounding area suggests that local roads are designed to accommodate heavy truck traffic. Delivery of large, heavy equipment such as 40-foot battery containers, switchgear, and a main power transformer via flatbed truck appears feasible. A detailed route survey would be required to confirm bridge weight limits, turning radii, and overhead line clearances prior to financial close.

Topography: The site and surrounding area appear to be relatively flat, which is typical for this coastal region of Massachusetts. This is highly advantageous, as it will likely minimize the need for extensive civil work and grading, thereby reducing site preparation costs. A formal topographic survey is required to confirm elevations and contours.

Easement Concerns: As the property has direct frontage on Healy Street, a dedicated access easement may not be necessary. However, a preliminary title report is a critical next step to identify any existing utility easements, rights-of-way, or other encumbrances that could restrict the placement of BESS equipment on the 3.22-acre parcel.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown and represents a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs would increase significantly due to the need to elevate all equipment above the Base Flood Elevation (BFE). A location in Zone X (minimal flood risk) is strongly preferred.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Given the site's proximity to the Acushnet River, a preliminary desktop analysis using MassGIS is warranted, followed by a formal wetland delineation by a certified professional. The Massachusetts Wetlands Protection Act imposes significant buffer zones (typically 100 feet) that could severely constrain the buildable area.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitats or protected areas on site, which is a significant positive. This reduces the risk of encountering project-delaying issues related to the Endangered Species Act. A standard verification using the USFWS IPaC tool should still be performed.

Brownfield/Superfund Status: This is a major risk and potential opportunity. The data indicates 13 brownfield or superfund sites within a two-mile radius. The subject property's history as an industrial site (owner: INTERNATIONAL PARALLEL MACHINES INC) suggests a high probability of on-site contamination.

• Risk: Potential for soil or groundwater contamination could lead to costly remediation and long-term liability.
• Opportunity: If the site qualifies as a "brownfield site" under CERCLA § 101(39), the project would be eligible for the 10% ITC adder under the Inflation Reduction Act (IRA). This financial incentive could be substantial enough to offset moderate remediation costs. An immediate Phase I Environmental Site Assessment (ESA) is mandatory to assess this.

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

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's proximity to grid infrastructure is its strongest attribute. The ACUSHNET TAP substation is located only 0.4 miles away. A 115