⚡ 2 SARAHS WAY

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 2 SARAHS WAY, Fairhaven, MA (APN: 24-012A)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 2 Sarahs Way in Fairhaven, Bristol County, Massachusetts. The 3.92-acre parcel presents a compelling grid-adjacent opportunity but carries significant environmental and regulatory risks that must be addressed before committing further capital.

1. Site Access & Topography

Road Access: The property is located on Sarahs Way, a short, paved road likely connecting to a larger thoroughfare such as Alden Road or U.S. Route 6. Initial desktop analysis suggests this is a developed commercial area with infrastructure capable of supporting heavy vehicle traffic. The primary access appears sufficient for standard construction vehicles.

Equipment Delivery: Feasibility for delivering heavy equipment, including 40-foot battery containers, switchgear, and a main power transformer via low-boy trailers, appears high. However, a detailed logistics plan is required. Turning radii from the main road onto Sarahs Way must be confirmed via a site visit or survey to ensure large trucks can maneuver without issue. Temporary traffic control measures may be required during peak construction and delivery phases.

Topography & Buildability: As is typical for coastal Massachusetts, the terrain is expected to be relatively flat with minimal grade. This is advantageous, as it will likely minimize earthwork and site preparation costs. However, the "Buildability" and "Buildable Acres" are listed as Requires Verification. A formal ALTA survey with topographic contours is essential to confirm the grade and identify any localized features that could impact the site layout.

Easements: No existing easements are documented in the provided data. A full title report is a critical next step to identify any potential access, utility, or drainage easements that could encumber the property and reduce the net buildable area. On a small 3.92-acre parcel, any significant easement could be a fatal flaw.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is unknown. This is a critical data gap. A review of the FEMA Flood Insurance Rate Maps (FIRMs) is required immediately. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs will increase substantially due to requirements for elevating all critical equipment above the Base Flood Elevation (BFE), and some jurisdictions may prohibit critical infrastructure in these zones altogether.

Wetlands: The presence of wetlands is unknown. Given the coastal location, there is a moderate to high probability of jurisdictional wetlands on or adjacent to the parcel. Massachusetts has highly restrictive wetland regulations under the Wetlands Protection Act. A formal wetland delineation is mandatory. Any identified wetlands will trigger significant setbacks (typically 100 feet or more), which could severely constrain or eliminate the viable project area on this small site.

Habitat & Species: The data indicates no critical habitat or protected areas, which is a positive initial finding. This should be confirmed through a desktop review of the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The presence of nine brownfield or superfund sites within a two-mile radius is a significant flag. While the subject property may not be one of them, its proximity increases the risk of historic contamination. This is a double-edged sword:

• Risk: If the site is contaminated, remediation could be costly and time-consuming, potentially making the project uneconomical.
• Opportunity: If the site qualifies as a "brownfield site" under IRA guidelines (e.g., through confirmed presence of a contaminant or based on prior commercial/industrial use), the project could be eligible for a 10% ITC adder. This potential financial upside warrants a Phase I Environmental Site Assessment (ESA) immediately.

Pipeline Proximity: No major gas pipelines are identified within three miles, mitigating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's primary strength is its excellent proximity to robust grid infrastructure. A 115kV transmission line owned by NSTAR (Eversource) is only 0.3 miles away, and the ARSENE 115kV substation is 1.2 miles away. This significantly de-risks the feasibility of finding a viable Point of Interconnection (POI).

Recommended Interconnection: For a distribution-scale project (≤5MW), a 115kV transmission-level interconnection would be prohibitively expensive (likely $5M-$