⚡ 8 BLUFF ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – 8 Bluff St, Plainfield, MA (APN: 237 020.0-0000-0007.0)

This report provides a comprehensive preliminary diligence analysis for a potential Battery Energy Storage System (BESS) project on a 14.85-acre parcel in Plainfield, Hampshire County, Massachusetts. The analysis concludes that the site presents numerous significant challenges across regulatory, grid infrastructure, and buildability categories, making it a high-risk development opportunity.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Bluff Street, which appears to be a minor, potentially unpaved rural road based on aerial imagery of the area. The quality and load-bearing capacity of this road are significant unknowns and present a major risk. Access for standard construction vehicles, let alone oversized and overweight vehicles required for delivering BESS containers, power conversion systems (PCS), and main power transformers, is highly questionable. Significant road upgrades, potentially including widening, grading, and reinforcement, would likely be required at the developer's expense.

Terrain & Buildability: Plainfield is situated in the Berkshire highlands of Western Massachusetts, a region characterized by hilly and often steep terrain. The parcel itself is forested. It is highly probable that the site has considerable topographic relief, which would necessitate extensive and costly civil work, including clearing, grubbing, and grading, to create a level pad for the BESS facility. The "Buildable Acres" are currently unknown and could be substantially less than the total 14.85 acres after accounting for slopes, setbacks, and environmental constraints.

Easement Concerns: Requires Verification. The legal status of access from the nearest public thoroughfare to the parcel via Bluff Street must be confirmed through a title search. A dedicated, permanent access easement capable of supporting heavy industrial traffic will be required. The current access rights are unknown and may be insufficient for our purposes.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone designation and the presence of jurisdictional wetlands are both listed as "Unknown." These are critical, potentially fatal-flaw data gaps. A preliminary screen using FEMA's Map Service Center and the U.S. Fish & Wildlife Service's National Wetlands Inventory (NWI) is an immediate next step. Massachusetts has a robust Wetlands Protection Act, and any development within buffer zones (typically 100 feet) of wetlands would be subject to a rigorous review by the local Conservation Commission. The presence of significant wetlands or location within a Special Flood Hazard Area would severely constrain the developable area and increase costs.

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

Brownfield/Superfund Status: The site is not a brownfield, meaning it does not qualify for the 10% IRA brownfield tax credit adder. While this simplifies the environmental liability assessment, it represents a missed incentive opportunity.

Pipeline Proximity: The absence of pipelines within a 3-mile radius is a significant safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments.

3. Grid Infrastructure & Interconnection

Substation & Point of Interconnection (POI): The nearest substation, PLAINFIELD, is 1.5 miles away. For a distribution-scale project (≤5MW), this is a considerable distance that suggests a costly line extension will be necessary. The substation's 115 kV maximum voltage indicates it is a transmission node, but it almost certainly steps down to a local distribution voltage (e.g., 13.2 kV or 23 kV). The key unknown is the route and availability of a 3-phase distribution feeder between the substation and the site.

Recommended Interconnection: The most viable path for a ≤5MW BESS is a distribution-level interconnection. The nearby 0.2-mile 115kV transmission line is noted as "NOT AVAILABLE," effectively ruling out a more expensive, complex, and lengthy transmission-level interconnection process. Our focus must be on identifying an adequate 3-phase distribution feeder.

Cost & Timeline Estimate: Requires Verification. A 1.5-mile overhead distribution line extension in hilly, forested terrain could easily exceed $1.5 million. The interconnecting utility is not identified but is likely Eversource. The interconnection process in Massachusetts is governed by ISO-New England (ISO-NE) rules, which are known for being complex, costly, and slow. A realistic timeline from application submission to commercial operation can be 36 months or more, with significant study costs and potential for expensive network upgrade requirements.

Feeder Configuration: The availability, phasing (must be 3-phase), and capacity of a distribution circuit near the site is the single most important technical question. Without a viable feeder, this site is not developable.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Plainfield is the primary AHJ for all local zoning and land use permits.

Zoning Compatibility: The provided zoning information is conflicting: "Vacant Land - Private Preserve, Open Space-Vacant Land" and "AR" (Agricultural-Residential). Neither of these designations would typically permit an energy storage facility "by-right." The "Private Preserve" and "Open Space" classifications are particularly concerning, suggesting the land is intended for conservation or minimal development. This represents a very high barrier to entry.

Permitting Pathway: Development will undoubtedly require a discretionary permit, such as a Special Permit from the Planning Board or a Use Variance from the Zoning Board of Appeals. This process involves public hearings and is subject to local opposition. Given the rural character of Plainfield, community acceptance is a major risk.

Moratorium Risk: High. Small, rural towns across