⚡ 643 STATE RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 643 State Rd, Bristol County, MA (APN: 072 164_8)

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 covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has excellent and direct frontage on State Road (US Route 6), a major, multi-lane state highway. This provides straightforward access for all phases of development, from initial surveying to final equipment delivery. No off-site road improvements are anticipated to be necessary.

Topography & Site Conditions: Based on aerial imagery, the 2.5-acre parcel appears to be relatively flat, cleared, and previously developed for commercial use. This is highly advantageous, as it will significantly reduce site preparation and grading costs. The existing curb cut and paved areas may be reusable, further lowering civil engineering expenses.

Heavy Equipment Feasibility: Access from State Road appears more than adequate for the delivery of heavy equipment, including mobile cranes, step-deck trailers carrying battery containers, and switchgear skids. The primary consideration will be ensuring sufficient on-site turning radii and laydown area, which appears feasible on a 2.5-acre lot but requires a formal site layout to confirm.

Easement Concerns: With direct frontage on a public right-of-way, no off-site access easements are anticipated. However, we must secure rights for the interconnection gen-tie route, which will likely require an easement from the utility (Eversource) to cross or run along the State Road right-of-way to the point of interconnection (POI).

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. A desktop analysis using the FEMA Map Service Center must be conducted immediately. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development costs could increase substantially due to requirements for elevating equipment above the Base Flood Elevation, or the site could be rendered undevelopable.

Wetlands: The presence of wetlands is Unknown. Given Massachusetts' stringent wetlands protection regulations, this is a primary risk. A desktop screening using MassGIS data is the immediate next step, followed by a formal wetland delineation by a certified professional if the screening indicates potential resources on or near the parcel. Any jurisdictional wetlands would trigger significant setbacks (typically 50-100 feet) that could severely constrain the buildable area on this relatively small 2.5-acre lot.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This reduces the likelihood of lengthy and costly consultations with state (MA Natural Heritage & Endangered Species Program) or federal (USFWS) agencies.

Brownfield/Superfund Status: The site is not listed as a brownfield or superfund site. While this means we cannot claim the 10% IRA brownfield ITC adder, it is a net positive from a risk management perspective, eliminating potential liability and remediation costs associated with contaminated land.

Pipeline Proximity: No major gas transmission pipelines are located in the immediate vicinity, mitigating risks related to pipeline safety setbacks and potential co-location conflicts.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located 0.9 miles from a 115 kV substation (TAP135407) and 0.8 miles from a 115 kV transmission line owned by Eversource (formerly NSTAR). While this proximity is excellent for a large utility-scale project, a 115 kV interconnection for a ≤5MW BESS is financially prohibitive, likely costing over $5 million and involving a multi-year timeline. This pathway should be considered non-viable for our target project size.

Recommended Interconnection Strategy: The most viable path is a distribution-level interconnection. Three-phase distribution feeders, likely operating at 13.8 kV, run directly along the property's frontage on State Road. This is the ideal target for a project of this scale.

Estimated Costs & Timeline: A distribution tap to an adjacent overhead feeder is the most cost-effective scenario. Estimated interconnection costs would range from $750,000 to $2,000,000, contingent on the scope of feeder upgrades (e.g., reconductoring, recloser upgrades) required by the utility study. The Eversource interconnection queue in Massachusetts is known to be congested. We should anticipate a timeline of 18-30 months from application submission to commercial operation.

Utility & Process: The interconnecting utility is Eversource. The process is governed by the Massachusetts Department of Public Utilities (DPU). Submitting a formal Interconnection Application is the only way to secure a queue position and receive a binding cost estimate. A preliminary capacity analysis (e.g., hosting capacity map review) should be conducted to assess the feeder's suitability prior to incurring application fees.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The property is located in the Town of Dartmouth, MA. The AHJ is the Dartmouth Planning Board and other town departments, not Bristol County.

Zoning Compatibility: The parcel is zoned GB (General Business). A review of the Town of Dartmouth Zoning Bylaws reveals a specific ordinance governing Battery Energy Storage Systems. BESS is not a by-right use in the GB district.

Permitting Pathway: Development will require a Special Permit from the Dartmouth Planning Board. This is a discretionary approval process that involves public hearings and abutter notifications. This pathway introduces significant timeline risk (6-12 months) and uncertainty, as approval is not guaranteed and can be subject to community opposition and extensive conditions.

Setback Requirements: The Dartmouth bylaw specifies setbacks for BESS, which must be confirmed but are typically 50-100 feet from property lines and greater distances from residential structures. On a 2.5-acre parcel, these setbacks will be a primary driver of the final project footprint and MW capacity.

Moratorium Risk: As Dartmouth has a specific BESS ordinance in place, the risk of a