⚡ FREEMAN ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 22_46_0 (Freeman St), Norton, MA

This report provides a comprehensive due diligence analysis for a 14.97-acre parcel located on Freeman Street in Norton, 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 appears to have frontage on Freeman Street, a paved, two-lane local residential road. Initial satellite imagery review suggests this road is in good condition and suitable for standard construction traffic.

Equipment Delivery: While the road itself seems adequate, the feasibility of delivering heavy equipment, such as a main power transformer (MPT) and prefabricated battery enclosures, is a concern. A detailed route survey would be required to assess turning radii from main thoroughfares (e.g., Route 140), bridge weight limits, and potential overhead line conflicts. Accessing the site directly from Freeman Street may require significant tree clearing and the construction of a new, robust access road capable of supporting crane and delivery vehicle loads.

Topography: Based on satellite and topographical maps, the parcel is relatively flat and heavily wooded. This is advantageous as it minimizes the need for extensive civil work and grading. However, the cost of clearing, grubbing, and stumping the required project area (typically 2-3 acres for a 5MW BESS) must be factored into the construction budget.

Easements: Requires Verification. It is currently unknown if direct, unrestricted access is available from Freeman Street or if an access easement across an adjacent parcel would be required. A title search is necessary to confirm legal access rights.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown and represents a critical data gap. If the buildable area is located within a Special Flood Hazard Area (e.g., Zone AE), it would necessitate elevating all equipment above the Base Flood Elevation (BFE), significantly increasing civil engineering and construction costs and potentially complicating permitting. A desktop FEMA map review is an immediate next step.

Wetlands: Requires Verification. The presence of wetlands is unknown and poses a major risk, particularly in Massachusetts with its stringent Wetlands Protection Act. Given the wooded and undeveloped nature of the site, the probability of jurisdictional wetlands is high. A formal wetland delineation by a certified professional will be required. Any identified wetlands will trigger significant setbacks (typically a 100-foot buffer zone), which could severely constrain or eliminate the buildable area on the 15-acre parcel.

Critical Habitat / Species: The initial screening indicates no critical habitat or protected areas on site. This is a positive finding, but it should be confirmed through a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The site is not a brownfield. This is a double-edged sword: it indicates a lower risk of soil contamination and associated cleanup liabilities, but it also means the project is ineligible for the 10% IRA Brownfield Adder, making the project economics less competitive.

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

3. Grid Infrastructure & Interconnection

Nearest Substation: The site is located approximately 0.5 miles from a substation identified as "UNKNOWN136320". This proximity is a major advantage and the most compelling feature of this site, as it drastically reduces the potential cost and complexity of the generator lead line. The substation voltage is listed as an error (-999999 kV) and Requires Verification. Given the area, it is likely a distribution substation owned by National Grid, operating at a standard voltage like 13.8 kV.

Transmission Access: A 115kV transmission line is 2.0 miles away but is noted as "NOT AVAILABLE". This distance makes a transmission-level interconnection economically unfeasible for a ≤5MW project.

Recommended Interconnection: The only viable path is a distribution-level interconnection, likely at 13.8 kV, to the nearby substation. The 0.5-mile distance suggests a relatively straightforward overhead or underground feeder extension.

Estimated Costs & Timeline: Assuming a 13.8 kV interconnection over 0.5 miles, a preliminary cost estimate would be in the range of $750,000 to $2,000,000. This is highly speculative and dependent on feeder upgrades, protection requirements, and whether the line is overhead vs. underground. The interconnection process in Massachusetts with National Grid, coordinated through ISO-New England, is notoriously slow; a realistic timeline from application to commercial operation is 24-48 months, assuming the queue is not overly congested.

Utility & Feeder: The interconnecting utility is almost certainly National Grid. A formal interconnection pre-application is required to identify the specific feeder, its current loading, hosting capacity, and whether it is a 3-wire or 4-wire system. The proximity to the substation increases the likelihood of finding a feeder with sufficient capacity.

4. Regulatory & Zoning Analysis

Authority Having