⚡ WEST ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 10_17700_111B_0 (West St, Ludlow, MA)

This report provides a comprehensive due diligence analysis for the subject 2.47-acre property in Ludlow, Hampden County, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis reveals several significant challenges, primarily related to environmental constraints and grid interconnection feasibility, which present substantial risks to project viability.

1. Site Access & Topography

Road Access: The quality of road access is currently unknown and requires immediate verification. The property is located on "WEST ST," but initial desktop review suggests this may be an unpaved or private road. The ability for multi-axle trucks to deliver heavy equipment, such as battery containers, a power conversion system (PCS) skid, and a main power transformer, is a critical uncertainty. A site visit is required to assess road width, surface condition, turning radii, and any potential weight-limited bridges or culverts.

Topography & Site Conditions: The parcel's land use designation as "Waste Land, Marsh, Swamp, Submerged-Vacant Land" is a major red flag. This strongly indicates that the terrain is likely flat, low-lying, and has a high water table with poor soil-bearing capacity. Development on such land would necessitate extensive and costly civil engineering work, including potential de-watering, significant fill importation, and deep foundation systems (e.g., helical piles) for all equipment pads. These conditions severely impact the "buildability" of the site.

Heavy Equipment Feasibility: Access for heavy equipment is considered high-risk. Even if road access is adequate, the on-site ground conditions described as "swamp" may not support the weight of a heavy-lift crane required for setting the transformer and other components. Extensive ground preparation, including building a temporary construction road and laydown area with geotextile fabric and aggregate, would be mandatory, adding significant cost and time.

Easement Concerns: Requires Verification. A title report and survey are needed to determine if direct access from a public right-of-way exists. If access is via a private road or across adjacent parcels, a formal, permanent access easement must be secured, which introduces negotiation risk and potential cost.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is "Unknown." Given the "Marsh, Swamp" land description, there is a very high probability the site is located within a Special Flood Hazard Area (SFHA), such as Zone A or AE. Development within an SFHA would require all equipment, particularly control systems and battery enclosures, to be elevated above the Base Flood Elevation (BFE), adding substantial structural and civil costs. This is a critical data gap that must be resolved immediately.

Wetlands: The presence of wetlands is "Unknown" but is strongly implied by the land use code. It is highly probable that a significant portion, if not all, of the 2.47-acre parcel consists of jurisdictional wetlands. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act), which include significant buffer zones (typically 100 feet) where development is heavily restricted or prohibited. On a small parcel, these setbacks could render the entire site undevelopable. A formal wetland delineation is a critical, go/no-go diligence item.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive factor. However, a desktop screening using the MA Natural Heritage & Endangered Species Program (NHESP) database is recommended to confirm no state-listed species habitats are present.

Site Contamination: The site is not a known brownfield or superfund site. While this avoids environmental remediation risk, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, which could have helped offset the high anticipated civil costs.

Other Constraints: No pipelines or gas wells were identified nearby, reducing safety and setback concerns from those sources. The site is not in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located 0.9 miles from the STONY BROOK 345 kV substation, a major transmission hub. Additionally, a 115 kV transmission line is only 0.1 miles away. While proximity is excellent, these are high-voltage transmission assets. Interconnecting a small ≤5MW BESS at transmission voltage (e.g., 115 kV) is technically feasible but financially prohibitive due to the requirement for a high-voltage breaker, switches, and a dedicated bay at the substation, likely costing several million dollars.

Recommended Interconnection: For a project of this scale, the only economically viable path is interconnection to a local distribution feeder (e.g., 13.2 kV). The provided data does not identify a suitable three-phase distribution line. Requires Verification. A primary diligence task is to identify the nearest three-phase distribution circuit owned by the local utility (likely Eversource) and assess its proximity and voltage. If a suitable feeder is not adjacent to the site, the cost of a line extension could be substantial.

Cost & Timeline Estimate:

• Distribution IX (Best Case): If a suitable feeder is on West St, costs could be in the $750k - $1.5M range with a 18-24 month timeline through the ISO-NE queue.
• Transmission IX (Worst Case): A 115 kV tap would likely cost $3M - $5M+ and take 36+ months, making the project non-viable.

Utility & Queue: The interconnecting utility is likely Eversource. We would need to follow the ISO New England (ISO-NE) interconnection process, which is known to be congested and lengthy. A pre-application report is essential to get an initial, non-binding assessment of feasibility and cost from the utility.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Ludlow, MA.

Zoning: The provided data is conflicting, listing a land use code ("Waste Land, Marsh, Swamp") and a zoning designation from Regrid ("A"). Assuming "A" stands for an Agricultural or similar rural district, BESS is almost certainly not a by-right use. The "Marsh, Swamp" designation may also place the parcel in a conservation or floodplain overlay district with additional restrictions.

Permitting Pathway: The most likely pathway is a Special Permit from the Ludlow Zoning Board of Appeals or Planning Board. This is a discretionary process that requires public hearings and gives the board significant latitude to impose conditions or deny the project. The process introduces significant uncertainty and timeline risk (6-12 months).