⚡ HART ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for HART ST, Dighton, MA (APN: 076/021.0-0014-0000.0)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 3.82-acre parcel located on Hart Street in Dighton, Bristol County, Massachusetts. The analysis covers key site attributes, constraints, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access: The property is located on Hart Street, which appears to be a two-lane, local residential road. The quality of this road is a critical unknown and requires immediate verification. We must confirm if it is paved and engineered to support heavy truck traffic, including multi-axle vehicles for delivering battery containers, switchgear, and a main power transformer. A site visit and consultation with the Dighton Department of Public Works is necessary to confirm weight limits and road conditions.

Topography & Equipment Delivery: As "Vacant Land" in this region of Massachusetts, the terrain is likely gently rolling and potentially wooded. A desktop topographic review is required, but significant grading will likely be necessary to create a level pad for the BESS equipment. The primary concern is the "last mile" delivery. Access from major state routes (like Route 138 or Route 24) to Hart Street must be surveyed for any potential obstructions such as low-clearance bridges, sharp turns, or residential obstacles that would prevent the delivery of oversized and overweight loads.

Easement Concerns: The parcel does not appear to have a pre-defined, improved access point from Hart Street. A new access driveway and an associated access easement will need to be engineered and permitted by the town. This will require negotiation with the landowner and approval from the Dighton Planning Board, adding time and cost to the pre-construction phase.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is currently Unknown. This is a major data gap and a potential fatal flaw. Verification via the FEMA Flood Map Service Center is the highest priority. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development will require elevating all equipment above the Base Flood Elevation, significantly increasing civil engineering costs and potentially impacting project economics to an unviable degree.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has extremely stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. A desktop screening using MassGIS OLIVER is required immediately. Given the small 3.82-acre size of the parcel, the presence of regulated wetlands and their associated 100-foot buffer zones could severely restrict the buildable area, potentially leaving insufficient space for a 5MW BESS project. A formal wetlands delineation by a certified professional will be required if the desktop screening indicates a risk.

Other Constraints:

• Critical Habitat: The data indicates no critical habitat, which is a positive. This should be cross-referenced with the MA Natural Heritage & Endangered Species Program (NHESP) database.
• Brownfield/Superfund: The site is not a brownfield. While this avoids environmental liability, it also means the project is ineligible for the 10% IRA Brownfield Tax Credit Adder, a notable economic disadvantage.
• Pipeline Proximity: No major pipelines are nearby, which is a significant safety and layout advantage, eliminating setback and co-location risks.

3. Grid Infrastructure & Interconnection

Substation & Grid Proximity: The DIGHTON substation is located 1.2 miles from the site. This is a feasible, but not ideal, distance for a distribution-level interconnection. The substation's 115 kV maximum voltage indicates it is a transmission node, but it will certainly have distribution-level feeders (likely 13.8 kV) that would serve as the Point of Interconnection (POI). The interconnecting utility is expected to be National Grid.

Recommended Interconnection: A distribution-level interconnection to a 13.8 kV feeder from the DIGHTON substation is the recommended pathway. A transmission-level (115 kV) interconnection is noted as "NOT AVAILABLE" and would be cost-prohibitive for a ≤5MW project regardless. The likely feeder configuration is a 3-phase overhead line running along public rights-of-way between the substation and the site.

Estimated Cost & Timeline: The 1.2-mile distance will require a new distribution line extension. A preliminary cost estimate for this scope is in the range of $1.2M to $2.5M, exclusive of any required upgrades at the Dighton substation, which could add several hundred thousand to over a million dollars. The Massachusetts interconnection process, managed through the Department of Public Utilities (DPU), is notoriously slow and complex. The timeline from application submission to achieving Permission to Operate (PTO) can realistically be 24-36 months. A formal interconnection application is required to get a binding cost estimate and a queue position.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Dighton.