⚡ 397 LOCUST ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 397 Locust St, Swansea, MA (APN: 292 028.0_0000_0002.A)

This report provides a comprehensive due diligence analysis for the subject property in Swansea, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key evaluation criteria from site access to incentive eligibility, concluding with a suitability score and actionable next steps.

1. Site Access & Topography

Road Access & Delivery Feasibility: The 6.64-acre parcel has direct frontage on Locust Street, which appears to be a two-lane, paved public road. Based on aerial imagery, this road seems adequate for standard construction traffic. However, a detailed route survey would be required to confirm its suitability for oversized and overweight loads, such as a main power transformer and containerized BESS units. We must verify the absence of low-clearance bridges, sharp turns, or weight-limited infrastructure on the likely delivery route from major highways (e.g., I-195).

Terrain & Equipment Access: The property is currently undeveloped and appears to be fully wooded with moderate tree density. The regional topography is generally flat to gently rolling, suggesting that extensive grading may not be required. However, significant tree clearing and grubbing will be necessary to create a level pad for the BESS compound and a new site access road from Locust Street. The feasibility of moving heavy equipment, including cranes for transformer placement, is high, provided a properly engineered gravel access road and laydown area are constructed.

Easement Concerns: As the property is undeveloped, a new curb cut and access driveway from Locust Street will be required, subject to approval from the Swansea Department of Public Works or MassDOT. No immediate access easement concerns from neighboring properties are apparent, given the direct road frontage. A title search is necessary to confirm no restrictive easements (e.g., conservation, utility) encumber the property's buildable area.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This represents a critical data gap and a potential fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, elevated construction costs (e.g., raising equipment above Base Flood Elevation), and potentially insurmountable permitting hurdles. Action: Immediate review of FEMA Flood Insurance Rate Maps (FIRMs) is required.

Wetlands: The presence of wetlands is Unknown. For a wooded, undeveloped parcel in Massachusetts, there is a high probability of state or federally jurisdictional wetlands, vernal pools, or bordering vegetated wetlands. The Massachusetts Wetlands Protection Act imposes stringent regulations, including 100-foot buffer zones where development is heavily restricted. The presence of significant wetlands could severely limit the buildable acreage. Action: A formal Wetlands Delineation by a certified professional is a critical and immediate next step.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a desktop screening using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is recommended to confirm the absence of priority habitats for rare species, which could trigger further review.

Brownfield/Superfund Status: The site is not located near any known brownfield or superfund sites. While this eliminates environmental liability risk, it also means the project is ineligible for the 10% IRA brownfield tax credit adder.

Pipeline Proximity: No gas transmission pipelines are located within a 3-mile radius, mitigating risks associated with pipeline-related setbacks, safety protocols, and potential easement conflicts.

3. Grid Infrastructure & Interconnection

Substation & Grid Proximity: The nearest substation is the SWANSEA substation, located 1.9 miles from the site, with a maximum voltage of 115 kV. This indicates a robust transmission-connected substation that almost certainly steps down to multiple distribution voltage levels. The 1.9-mile distance makes a direct tie to the substation economically challenging for a ≤5MW project.

Transmission & Recommended Voltage: A 115 kV transmission line is noted as being on-site but "NOT AVAILABLE" for interconnection. This strongly suggests our strategy must be a distribution-level interconnection. The most likely Point of Interconnection (POI) would be a 3-phase overhead distribution feeder running along Locust Street. The interconnecting utility is Unknown but is likely National Grid for this service territory. Action: We must immediately identify the utility and request distribution circuit maps.

Interconnection Cost & Timeline: Interconnecting to a local distribution feeder is far more cost-effective than a 1.9-mile line build. A standard feeder tap could range from $250,000 to $750,000, depending on required protection upgrades and whether the feeder is on the correct side of the road. However, the primary risk is the available hosting capacity of the local circuit. If the feeder is capacity-constrained, utility-mandated upgrades (e.g., reconductoring, substation breaker upgrades) could escalate costs to well over $1.5 million and add 12-24 months to the project timeline. The Massachusetts interconnection process is notoriously slow, and queue times can be extensive.

Feeder Configuration: It is presumed that a 3-phase, 13.8 kV class distribution feeder runs along Locust Street. This is a critical assumption that Requires Verification through utility maps.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Swansea is the primary AHJ for all zoning and building permits.

Zoning Compatibility: There is a significant conflict in the provided data. One source lists the zoning as "Commercial (Retail) - Commercial (General) (Code: R1)," while another lists it as "R-R" (likely Rural Residential). This discrepancy is a major red flag.

• If Commercial, BESS may be permissible via a Special Use