⚡ BARRETT 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 102 0041 (Barrett St, New Bedford, MA)

This report provides a comprehensive due diligence analysis for a potential distribution or utility-scale Battery Energy Storage System (BESS) project on a 4.88-acre parcel located on Barrett Street in New Bedford, 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 & Equipment Delivery: Initial desktop review indicates that direct access is from Barrett Street, which appears to be an unpaved or minimally improved road extending from Braley Road. The quality of this access is a significant concern and is currently unsuitable for heavy haul trucks required for delivering multi-ton battery containers, power conversion systems (PCS), and the main power transformer. A full geotechnical survey and civil engineering plan will be required to design and permit a new or heavily upgraded access road capable of supporting construction traffic. The cost for this road improvement could be substantial.

Terrain & Buildability: The parcel is located in a coastal region of Massachusetts, suggesting the topography is likely flat to gently rolling. However, satellite imagery shows the parcel is heavily wooded. This will necessitate significant clearing and grading, adding to site preparation costs. The total parcel size of 4.88 acres is compact for a 5MW BESS, especially after accounting for zoning setbacks, environmental buffers, and the access road itself. The net buildable area is a critical unknown.

Heavy Equipment Feasibility: Access for cranes, concrete trucks, and delivery vehicles is currently infeasible without major road construction. The feasibility hinges on the cost and permittability of upgrading Barrett Street from Braley Road to the site entrance.

Easement Concerns: A title search is immediately required to determine the ownership status of Barrett Street. If it is a private road, a formal, permanent access easement from all relevant landowners will be necessary. Securing this easement could be a time-consuming and costly negotiation, representing a potential fatal flaw.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap. The site's proximity to the Acushnet River and other local water bodies elevates the risk of it being within a Special Flood Hazard Area (e.g., Zone A or AE). Any development within such zones would require significant civil work (e.g., raising equipment pads above the Base Flood Elevation) and could face permitting challenges. Verification via the FEMA Flood Map Service Center is a top priority.

Wetlands: The presence of wetlands is Unknown but highly probable given the undeveloped, wooded nature of the site in this region. A wetland delineation study will be required to identify any jurisdictional wetlands and associated buffer zones as mandated by the New Bedford Conservation Commission and the Massachusetts Department of Environmental Protection (MassDEP). The presence of significant wetlands could severely restrict the buildable area and potentially render the site unusable.

Critical Habitat / Endangered Species: The data indicates no critical habitat on site, which is a positive initial finding. However, this must be formally verified through a query of the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or their habitats are present.

Brownfield/Superfund Status: The presence of 30 known contaminated sites within a two-mile radius suggests a history of industrial activity in the area. While this presents a risk of potential on-site contamination (requiring a Phase I Environmental Site Assessment), it also presents a significant opportunity. If the subject parcel can be classified as a "brownfield site" under IRA guidelines, the project could be eligible for a 10% ITC adder. This potential financial upside warrants immediate investigation via a Phase I ESA.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive safety and siting attribute, reducing the risk of co-location hazards and complex setback requirements.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The nearest major infrastructure is the ACUSHNET TAP substation, located 1.4 miles from the parcel. This is a 115 kV transmission-level facility owned by NSTAR (Eversource). The 1.4-mile distance is significant and presents the single largest challenge for this site.

Recommended Interconnection: A 115 kV transmission-level interconnection is the most direct, albeit most expensive, path. A distribution-level interconnection (e.g., at 13.8 kV) would be preferable for a ≤5MW project due to lower costs and simpler studies. However, the location and available capacity of a suitable three-phase distribution feeder are