⚡ PHILLIPS RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Phillips Road, New Bedford, MA (APN: 136 0467)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 3.8-acre parcel located on Phillips Road in New Bedford, Bristol County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The subject property is located on Phillips Road within the New Bedford Business Park, a well-established industrial area. Based on aerial imagery review, Phillips Road is a paved, two-lane industrial road capable of supporting heavy truck traffic. Access appears to be direct and unobstructed from major local thoroughfares.

Terrain Characteristics: The site is situated in a developed industrial park in coastal Massachusetts. The topography is expected to be flat to gently graded, which is ideal for BESS development as it minimizes the need for extensive civil work and site grading. This assumption Requires Verification with a formal topographic survey.

Heavy Equipment Access: The existing road network is designed for semi-trailer trucks and industrial traffic. Therefore, delivery and placement of heavy equipment, including multi-ton transformers, switchgear, and containerized battery enclosures, is anticipated to be highly feasible. A detailed logistics review should be conducted to confirm turning radii from public roads onto the site and to identify any potential overhead utility line conflicts along the delivery route.

Easement Concerns: As a vacant parcel within a planned business park, there is a moderate risk of pre-existing utility easements (e.g., water, sewer, gas, communications) crossing the property. A title report and ALTA survey are required to identify any such encumbrances, which could constrain the final site layout and reduce the buildable area. No access easements are anticipated to be required given the direct road frontage.

2. Environmental Constraints

FEMA Flood Zone: The property's FEMA flood zone designation is currently Unknown. This represents a critical data gap and a potential fatal flaw. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs would increase significantly due to requirements for elevating all equipment above the Base Flood Elevation, or the site could be rendered undevelopable. Immediate review of FEMA's Flood Insurance Rate Maps (FIRMs) is a top priority.

Wetlands Presence: The presence of state or federally regulated wetlands is Unknown. Given the site's location in coastal Massachusetts, there is a high probability of wetlands or other jurisdictional water bodies on or adjacent to the parcel. The Massachusetts Wetlands Protection Act imposes significant regulations, including 100-foot buffer zones, which could severely restrict or eliminate the buildable area. A desktop screening using MassGIS OLIVER data is the immediate next step, likely to be followed by a formal field wetland delineation.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitats or protected areas on the site. This is a positive finding, reducing permitting complexity. However, as a standard diligence step, a review of the MA Natural Heritage & Endangered Species Program (NHESP) database should be performed to confirm no state-listed species habitats are present.

Brownfield/Superfund Status: Data indicates one superfund/brownfield site within a two-mile radius, but not on the subject parcel itself. This proximity necessitates a Phase I Environmental Site Assessment (ESA) to ensure no contamination has migrated to our site. Crucially, if the Phase I ESA identifies historical use that qualifies this specific parcel as a "brownfield site" under federal definitions, it could unlock a 10% ITC adder via the Energy Community incentive. This turns a potential risk into a significant financial opportunity.

Pipeline Proximity: No major gas transmission pipelines are located within three miles of the site, which is a significant safety and layout advantage. This eliminates concerns regarding pipeline-related setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid access is its strongest attribute. The Eversource (formerly NSTAR) "INDUSTRIAL PARK" substation is located only 0.3 miles from the parcel. This substation has a maximum voltage of 115 kV, indicating it is a robust node on the transmission system. A 115 kV transmission line is also present at the same distance. This extreme proximity dramatically reduces the cost and complexity of the generator lead line.

Recommended Interconnection: For a distribution-scale project (≤5MW), the recommended point of interconnection (POI) would be on a distribution feeder (likely 13.8 kV) originating from the Industrial Park substation, not a direct tap to the 115 kV transmission line. A distribution-level interconnection is substantially less expensive and follows a more streamlined (though still lengthy) utility process.

Cost & Timeline Estimate: Given the sub-half-mile distance, the physical interconnection cost (poles, wires) should be relatively low. The primary cost driver will be any necessary protection and control upgrades within the substation itself. A preliminary, high-level cost estimate ranges from $750,000 to $2,000,000. This Requires Verification via a formal interconnection study from Eversource. The interconnection process within ISO New England is notoriously long; a timeline of 24-36 months from application to Commercial Operation