⚡ 160 RODNEY FRENCH BLVD

MEMORANDUM

TO: Sunland America Corp. Investment Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 160 Rodney French Blvd, New Bedford, MA (APN: 201 013 0126)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis covers key evaluation criteria including site access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has excellent frontage on Rodney French Boulevard, a major, paved public thoroughfare in New Bedford. This provides direct and seemingly unrestricted access for personnel and standard vehicles.

Terrain & Equipment Feasibility: Based on aerial and topographic imagery, the 5.03-acre parcel is exceptionally flat, consistent with its coastal location. This is highly advantageous, as it will minimize civil work and grading costs. Access for heavy equipment, including cranes, transformers, and containerized BESS units, appears feasible directly from the boulevard. However, a formal route survey is required to confirm the absence of low-clearance bridges or road weight restrictions between the Port of New Bedford (or other likely delivery hub) and the site.

Easement Concerns: While direct road frontage is a major positive, a preliminary title report is a critical next step. This will be necessary to identify any existing utility easements, access rights-of-way, or other encumbrances that could restrict the placement of equipment on the parcel. Given the urban setting, undisclosed subsurface utility easements are a moderate risk.

2. Environmental Constraints

FEMA Flood Zone: This represents a critical, potentially fatal flaw. Preliminary analysis using the FEMA Flood Map Service Center indicates the property is located within both Zone AE and Zone VE. Zone AE is the 100-year floodplain, and Zone VE is a coastal high-hazard area with added risk from wave velocity. Development in these zones is highly regulated and expensive. All critical equipment, including battery enclosures, inverters, and transformers, would need to be elevated above the Base Flood Elevation (BFE), likely requiring construction on costly pile-supported platforms. This will dramatically increase the project's capital expenditure.

Wetlands: The property's coastal location presents a high risk for the presence of jurisdictional wetlands, particularly coastal salt marshes or other estuarine features. Requires Verification: A formal wetlands delineation is mandatory. Any identified wetlands will trigger significant setback requirements (typically 50-100 feet) under the Massachusetts Wetlands Protection Act and administered by the New Bedford Conservation Commission, potentially reducing the buildable area.

Habitat & Species: While initial data shows no critical habitat, the coastal environment could be a habitat for protected shorebirds or other species. A formal desktop screening using the USFWS IPaC tool is recommended to confirm this.

Brownfield/Superfund Status: The presence of 22 known contamination sites within a two-mile radius is a significant concern, suggesting a history of industrial use in the area. A Phase I Environmental Site Assessment (ESA) is non-negotiable to determine if this specific parcel has contamination. If the site is confirmed as a brownfield through a Phase II ESA, it could paradoxically become an advantage by qualifying the project for the 10% IRA brownfield tax credit adder. However, the risk of discovering contamination requiring costly remediation is high.

Pipeline Proximity: No gas transmission pipelines are located within three miles, which is a positive finding that eliminates a common safety and setback constraint.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The nearest identified substation (ARSENE) is 2.9 miles away, and the nearest transmission line (115kV) is 2.4 miles away. For a ≤5MW project, these distances are economically unviable for a dedicated line extension. The cost would run into many millions of dollars, rendering the project non-starters if this were the only option.

Likely Interconnection Point: The project's only feasible path to interconnection is via the 3-phase overhead distribution feeder running directly along Rodney French Boulevard. The interconnecting utility is NSTAR Electric Company, now operating as Eversource Energy. The likely interconnection voltage would be on this distribution circuit, probably 13.8kV.

Capacity & Cost: The viability of this site is entirely dependent on the available capacity of this local feeder. Requires Verification: A formal interconnection pre-application with Eversource is the single most important next step. If the feeder has sufficient thermal and voltage capacity