⚡ 1 PEARL ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 1 Pearl St, New Bedford, MA (APN: 072 0173)

This report provides a comprehensive due diligence analysis for the subject property for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) site. The analysis reveals significant challenges, primarily related to grid interconnection feasibility and environmental uncertainty, which temper the initial appeal of its industrial zoning.

1. Site Access & Topography

Road Access & Equipment Delivery: The site is located at 1 Pearl Street in an established industrial area of New Bedford. Pearl Street appears to be a paved, local road. Access to major transportation corridors, such as I-195, is straightforward via nearby Coggeshall St and Route 18. Based on satellite imagery, road quality appears sufficient for standard construction traffic. However, a physical site visit is required to confirm the absence of low-clearance bridges, weight-limited roads, or sharp turning radii that could impede the delivery of heavy equipment.

Terrain & Buildability: As is typical for New Bedford, the topography is expected to be relatively flat, which is advantageous for minimizing civil engineering and site preparation costs. The 2.65-acre parcel size is small but potentially adequate for a 5MW BESS, assuming minimal environmental setbacks. The key buildability constraint will be the net usable acreage after applying all required zoning and environmental buffers.

Heavy Equipment & Easements: Access for large cranes, transport trucks carrying battery containers, and the main power transformer appears feasible given the industrial context. Requires Verification: A title search is necessary to confirm that the property has direct, unencumbered access to Pearl Street and is not reliant on any access easements across adjacent properties, which could complicate development.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical risk. New Bedford is a coastal city, and many areas are susceptible to flooding. Development within a Special Flood Hazard Area (e.g., Zone AE) would trigger significant design constraints, including elevating all critical equipment, and could make the project uninsurable or un-financeable. This is an immediate go/no-go diligence item.

Wetlands: The presence of wetlands is Unknown. Given the site's proximity to the coast, there is a moderate to high risk of jurisdictional wetlands being present. Any wetlands would require significant setbacks (typically 50-100 feet in Massachusetts), which could severely reduce the buildable area on this small 2.65-acre parcel and render the project infeasible.

Brownfield/Superfund Status: The data indicates a high concentration of 34 brownfield or superfund sites within a 2-mile radius. This presents both a risk and a potential opportunity. The risk is that the subject parcel itself may have soil or groundwater contamination from past industrial use, which would require costly remediation. The opportunity is that if the site can be officially classified as a "brownfield site" under IRA guidelines, the project would be eligible for the 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is mandatory to clarify this.

Other Constraints: The site has no identified critical habitats, protected areas, or nearby pipelines, which are positive findings that simplify development.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The nearest identified substation is ACUSHNET TAP, located 1.9 miles away, which is a 115kV transmission-level facility. The nearest transmission line is also 115kV at a distance of 1.8 miles. This infrastructure is not suitable for a small distribution-scale BESS project.

Interconnection Feasibility & Recommendation: An interconnection at 115kV would be prohibitively expensive (likely $5M+) and complex for a ≤5MW project. The viability of this site is entirely dependent on the presence of a suitable 3-phase distribution feeder (e.g., 13.8kV) adjacent to or very near the property. The provided data has a critical gap here. The primary recommendation is to identify a viable distribution-level Point of Interconnection (POI). Without an adjacent, high-capacity distribution feeder, this site is a non-starter.