⚡ 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 – Project "Bristol Industrial" (27 Healy St, New Bedford, MA)

This report provides a comprehensive due diligence analysis for the property located at 27 Healy St, New Bedford, MA (APN: 111 0150) for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key site attributes, risks, and recommended next steps for consideration.

1. Site Access & Topography

The 3.22-acre subject property has public road access via Healy Street, which appears to be a standard industrial park road capable of accommodating heavy vehicle traffic. Based on a preliminary desktop review, the site is located in a developed industrial area, which strongly suggests that access for large delivery vehicles and construction equipment is feasible.

• Equipment Delivery: Access for delivery of battery containers, pad-mount transformers, and cranes is anticipated to be straightforward. However, a physical site visit is required to confirm turning radii from public roads onto the site and to verify the absence of low-hanging overhead utility lines that could obstruct crane operations or high-load deliveries.
• Terrain Characteristics: The New Bedford area is part of the coastal plain, and the site is expected to be relatively flat with minimal grade. This is highly advantageous, as it will likely minimize earthwork and civil construction costs. A formal topographical survey will be required to confirm this assumption and inform detailed engineering design.
• Easement Concerns: While the Point of Interconnection (POI) is listed as "Onsite," a preliminary title report must be ordered to identify any existing utility, access, or drainage easements that may encumber the property. Such easements could significantly reduce the net buildable area and must be mapped against our preliminary site layouts.

2. Environmental Constraints

Environmental factors present the most significant unknowns and potential fatal flaws for this site. The "Buildability: No" flag in the source data is a major concern, likely stemming from one or more of the constraints below.

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs will increase due to requirements for elevating all critical equipment above the Base Flood Elevation. In a worst-case scenario (e.g., a floodway), development could be prohibited entirely. A FEMA FIRMette map must be reviewed immediately.
• Wetlands: The presence of wetlands is Unknown. Given the site's coastal proximity, there is a moderate to high risk of jurisdictional wetlands. Massachusetts has stringent wetland protection laws, and required setbacks (e.g., 100-foot buffer zones) could severely restrict or eliminate the buildable area on this relatively small 3.22-acre parcel. A formal wetlands delineation is a mandatory next step.
• Brownfield/Superfund Status: The property itself is not listed as a brownfield, meaning it is not eligible for the 10% IRA brownfield tax credit adder. However, the presence of 13 known contaminated sites within a two-mile radius raises the risk of historical contamination on our parcel from prior industrial uses. A Phase I Environmental Site Assessment (ESA) is non-negotiable to assess liability.
• Other Constraints: The site shows no risk related to Critical Habitats, Protected Areas