⚡ 1077 CENTER ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Project "Ludlow Grid" (1077 Center St, Ludlow, MA)

This report provides a comprehensive due diligence analysis for the property located at 1077 Center Street, Ludlow, MA (APN: 24_3550_60E_0) for its suitability as a distribution-scale Battery Energy Storage System (BESS) project. The analysis concludes with a suitability score, a summary of key risks, and a recommended path forward.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has excellent frontage on Center Street (MA-21), a two-lane state highway. Based on aerial imagery review, access appears direct and unobstructed, which is highly favorable for construction. The road is paved and appears well-maintained, suitable for heavy truck traffic, including low-boy trailers required for delivering battery containers, switchgear, and the main power transformer. The industrial nature of the area suggests no weight or height restrictions are likely, though this Requires Verification with the Town of Ludlow and MassDOT.

Terrain & Buildability: The parcel appears to be relatively flat and cleared, consistent with its "Industrial (General)" zoning and likely prior use. This topography is ideal for BESS development, as it will significantly minimize earthwork and civil engineering costs. Minimal grading would be required for the equipment pads, access roads, and stormwater management systems. The 19.27-acre parcel size provides ample space for a ≤5MW BESS footprint, including required electrical infrastructure, safety setbacks, and potential future expansion.

Easement Concerns: While direct road frontage is a major advantage, a full title search is a critical next step. We must verify that there are no restrictive access easements, utility right-of-ways, or other encumbrances that could limit the placement of equipment or access routes within the parcel. The proximity of transmission lines suggests a utility easement may already exist on a portion of the property.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The status of FEMA flood zones and on-site wetlands is currently Unknown. This represents the single greatest environmental risk to the project. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design challenges, dramatically increase insurance costs, and could be a fatal flaw for permitting. Similarly, the presence of state-jurisdictional wetlands under the Massachusetts Wetlands Protection Act could impose substantial setbacks (typically 100-foot buffer zones), severely constraining the buildable area. Immediate desktop analysis using FEMA and MassGIS data is required, likely followed by a formal wetlands delineation by a certified professional.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a positive finding that simplifies permitting. However, a formal confirmation through the MA Natural Heritage & Endangered Species Program (NHESP) database is a standard due diligence step.

Site Contamination: The site is not listed as a brownfield or superfund site, and none are located within a 2-mile radius. This reduces the risk of encountering soil or groundwater contamination, which would create liability and increase remediation costs. The trade-off is that the project is ineligible for the 10% IRA Brownfield tax credit adder.

Other Constraints: The site is not within the Chesapeake Bay Critical Area (not applicable to MA). The absence of pipelines within a 3-mile radius is a significant safety and permitting benefit, eliminating the need for specialized impact studies or crossing agreements.

3. Grid Infrastructure & Interconnection

Substation & Point of Interconnection (POI): The site's proximity to the LUDLOW substation, located just 0.3 miles away, is its most compelling feature. This is an exceptionally short distance, which will drastically reduce the cost and complexity of the generator lead line. The substation's 345 kV maximum voltage indicates it is a major node in the regional transmission system, which almost certainly means it also contains lower-voltage distribution busses (e.g., 13.8 kV) suitable for a project of our target size (≤5MW).

Recommended Interconnection: The recommended pathway is a distribution-level interconnection to a 13.8 kV (Requires Verification) feeder originating from the LUDLOW substation. A transmission-level interconnection (e.g., 115 kV) would be prohibitively expensive and complex for a 5MW project. The nearby 115kV line being marked as "NOT AVAILABLE" further supports focusing all efforts on a distribution-level tap.

Cost & Timeline Estimate: The physical interconnection cost should be on the lower end of the spectrum, potentially in the $