⚡ MONSON TURNPIKE RD

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 309 26-2-1, Ware, MA

This report provides a comprehensive due diligence analysis for the 16.54-acre property located on Monson Turnpike Rd in Ware, Hampshire County, Massachusetts (APN 309 26-2-1). The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Monson Turnpike Road. A preliminary desktop review suggests this is a secondary, rural road. The quality of the road surface (paved vs. gravel), width, and load-bearing capacity are unknown and require immediate verification via a site visit. The primary concern is whether the road can support the transport of heavy and oversized equipment, including a 150-ton crane, concrete trucks, and 40-foot, 80,000-pound battery containers on a lowboy trailer. Any tight turns, low-clearance bridges, or residential density along the route could render delivery infeasible or prohibitively expensive.

Terrain & Buildability: The current land use is designated as "Timberland, Forest, Trees." This indicates the site is undeveloped and heavily wooded. Significant tree clearing, grubbing, and grading will be required, adding considerable cost and time to the site preparation phase. The natural topography is likely uneven, potentially requiring extensive cut-and-fill operations to create a level pad for the BESS equipment. A formal topographic survey is essential to quantify these civil engineering costs.

Easement Concerns: This is a critical unknown. The provided data does not specify if the parcel has direct, legal frontage on Monson Turnpike Rd or if access is provided via an easement across an adjacent property. If access relies on an easement, its terms must be reviewed to ensure it allows for heavy commercial and construction traffic. If no legal access exists, the site is effectively landlocked and non-viable without negotiating and purchasing a new, permanent access easement.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a high-priority data gap. If any portion of the planned equipment pad falls within a 100-year floodplain (e.g., Zone A, AE), it could be a fatal flaw. Mitigation would require elevating all equipment above the Base Flood Elevation (BFE), a costly and complex engineering task that may not be permissible by the local AHJ.

Wetlands: The presence of wetlands is unknown but highly probable given the forested, undeveloped nature of the site in Massachusetts. A desktop screening using National Wetlands Inventory (NWI) maps is the first step, but a formal wetland delineation by a certified professional will be required. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), which include significant buffer zones (typically 100 feet) where development is heavily restricted. The presence of wetlands could severely constrain the buildable area.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this must be formally verified by cross-referencing the project location with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or their habitats are impacted.

Site Contamination: The site has no known brownfield or superfund sites within a 2-mile radius. This minimizes the risk of encountering soil or groundwater contamination, which would trigger costly remediation. However, this also means the project is ineligible for the 10% IRA Brownfield Adder ITC bonus.

Pipeline Proximity: No gas pipelines are located within 3 miles, which is a significant safety and layout advantage, eliminating concerns about pipeline-related setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation, TAP140744, is approximately 2.0 miles away. This is a substantial distance for a distribution-scale project. The substation's maximum voltage is 69 kV, which is a sub-transmission level. While this voltage suggests significant capacity may be available, the cost to interconnect at this distance is a major project risk.

Interconnection Strategy & Cost: A 2-mile line extension is likely to be prohibitively expensive. A new 3-phase distribution line could cost between $750k - $2M per mile, depending on terrain, pole ownership (new vs. existing), and road crossings. Therefore, the estimated interconnection cost could range from $1.5M to $4.0M+. This cost alone could make a ≤5MW project economically unviable. The most critical immediate task is to identify the route and voltage of the nearest 3-phase distribution feeder coming from this substation. If a feeder runs closer to the property, it could drastically reduce costs, but a 2-mile tap from the substation is a worst-case scenario.

Utility & Timeline: The interconnecting utility is not specified but is likely National Grid or Eversource in this region. Identifying the correct utility is paramount. The interconnection process in Massachusetts, governed by ISO New England (ISO-NE), is notoriously slow and complex. Even for a distribution-level project, the timeline from application to commercial operation can easily exceed 3-5 years due to study queues and construction backlogs.

4. Regulatory & Zoning Analysis

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

Zoning Compatibility: The parcel is zoned RR (Agricultural/Rural). BESS facilities are a modern industrial use and are almost never permitted "by-right" in a rural or agricultural zone. The land use code "Timberland, Forest, Trees" further reinforces the non-industrial nature of the current zoning.

Permitting Pathway: The most likely permitting pathway will be a Special Permit from the Ware Planning Board or Zoning Board of Appeals (ZBA). This is a discretionary process that requires public hearings and gives the board significant latitude to deny the project or impose costly conditions of approval. This pathway introduces significant timeline risk and the potential for organized community opposition.

Regulations & Risks: We must conduct a detailed review of the Town of Ware's zoning bylaws to see if they have specific ordinances for battery storage or renewable energy. If not, the project will be treated as a generic "utility" or "industrial" use, creating ambiguity. Key considerations will be setback requirements (from property lines and residences), noise limits, landscaping/screening, and, critically, fire safety. A comprehensive fire safety and emergency response plan compliant with NFPA 855 will be required and must be approved by the Ware Fire Department, which can be a major permitting hurdle.

5. IRA/ITC Incentive Analysis

This site has a weak incentive profile, which challenges its financial viability.

• Opportunity Zone: No. (0% adder)
• Energy Community: No. (0% adder)
• Low-Income Community: No. (0% adder)

Potential Cumulative ITC: The project is only eligible for the base 30% Investment Tax Credit. The lack of any 10% or 20% adders puts this site at a significant financial disadvantage compared to projects located in designated incentive zones.

6. BESS