⚡ SLADES CORNER RD

MEMORANDUM

TO: Sunland America Corp. Development Team
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 072 27_24 (Slades Corner Rd, Dartmouth, MA)

This report provides a comprehensive due diligence analysis for the 2.02-acre property located on Slades Corner Road in Dartmouth, Bristol County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access: The property has direct frontage on Slades Corner Road, a two-lane, paved local road. A preliminary review via satellite imagery suggests the road is in fair condition and suitable for standard construction traffic. However, a physical site visit is required to confirm the absence of low-hanging utility lines, narrow culverts, or tight turning radii that could impede oversized vehicle access.

Equipment Delivery: The primary concern for equipment delivery is the transport of large, heavy components such as the main power transformer and 40-foot battery containers. While Slades Corner Road appears navigable, the final turn-in to the site itself must be assessed. A temporary construction entrance with sufficient swing radius will need to be designed and permitted by the Dartmouth Department of Public Works. The feasibility is moderate but requires verification of road weight limits and a detailed logistics plan.

Topography & Easements: The terrain in this region of Massachusetts is typically flat to gently rolling, often with significant tree cover. The subject parcel appears heavily wooded. This will necessitate clearing and grading, adding to site preparation costs. The small 2.02-acre size leaves little room for error in layout. As the parcel has direct road frontage, a dedicated access easement is likely not required, but this must be confirmed via a title search to ensure no encumbrances exist.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap and a high-priority risk. Any designation within a Special Flood Hazard Area (e.g., Zone A, AE) would likely render the project infeasible or require costly mitigation, such as elevating all equipment pads above the Base Flood Elevation, which is challenging on a small site.

Wetlands: The presence of wetlands is Unknown but highly probable given the site's location and undeveloped state. Massachusetts has stringent wetland regulations under the Wetlands Protection Act, which mandates significant buffer zones (typically a 100-foot "Buffer Zone" and a 25-foot "No Disturb Zone"). On a 2-acre parcel, the presence of regulated wetlands could severely restrict or eliminate the buildable area, making this a potential fatal flaw.

Habitats & Contamination: The site is clear of designated critical habitats, protected areas, and is not in proximity to Brownfield or Superfund sites. While the lack of Brownfield status means the project is ineligible for the 10% IRA Brownfield adder, it also avoids significant environmental liability and remediation costs. The absence of nearby pipelines or gas wells is a notable safety and permitting advantage.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is Eversource's (formerly NSTAR) FISHER ROAD Substation, located 1.6 miles from the site. This substation has a 115 kV bus, which is transmission-level voltage. A direct transmission interconnect for a ≤5MW BESS is technically complex and financially non-viable.

Interconnection Point & Cost: The only feasible interconnection path for a project of this scale is to a 3-phase distribution feeder. The critical question is the location of the nearest suitable feeder. If a 3-phase line runs along Slades Corner Road, the interconnection would involve a shorter tap line. However, if a new 3-phase distribution line must be extended 1.6 miles from the substation, the cost would be prohibitive, likely in the $1.5M - $3.0M+ range. This cost alone would likely make a 5MW project uneconomical. Verification of 3-phase power availability at the road frontage is the single most important technical diligence item.

Utility Process: The interconnecting utility is Eversource. Their interconnection process in Massachusetts is well-defined but notoriously slow and backlogged. Even for a distribution-level project, the timeline from application to an Interconnection Service Agreement (ISA) can easily exceed 24-36 months.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Dartmouth. The property is zoned SR-B (Single Residence B). Energy storage is not a by-right use in any residential zone in Dartmouth.

Permitting Pathway: Development will require, at a minimum, a Special Permit from the Dartmouth Planning Board and likely a Use Variance from the Zoning Board of Appeals. This is a discretionary and high-risk process. It involves public hearings where opposition from neighbors regarding noise, safety (fire risk), and aesthetic impact on the residential character of the area is highly likely and often leads to project denial.

Setbacks & Restrictions: The town's zoning bylaws must be reviewed for specific setback requirements for utility uses, which are likely to be substantial (e.g., 50-100 feet from all property lines). These setbacks would consume a significant portion of the 2-acre lot. Furthermore, we must investigate if Dartmouth has enacted or is considering a moratorium on BESS development, as many Massachusetts municipalities have done. The residential zoning is a major, and potentially insurmountable, obstacle.

5. IRA/ITC Incentive Analysis

This site's location offers no competitive advantages from key Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA).

• Opportunity Zone: No (0% adder)
• Energy Community: No (0% adder)
• Low-Income Community: No (0% adder)

Potential Cumulative ITC: 0% in adders. The project would only be eligible for the 30% base ITC (