⚡ BURNETT ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for Burnett St, Granby, MA (APN: 111 2_B_23)

This report provides a comprehensive due diligence analysis for a potential distribution-scale BESS project on a 10-acre parcel located on Burnett Street in Granby, Hampshire County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives. The findings indicate significant challenges that present a high-risk profile for this site.

1. Site Access & Topography

Initial desktop review indicates that Burnett Street is a paved, two-lane local road. While seemingly adequate for standard vehicles, a formal road survey is required to confirm its suitability for heavy haul trucks carrying multi-ton battery containers, transformers, and cranes. The analysis must confirm weight limits, turning radii at intersections, and the condition of any bridges or culverts along the delivery route. The parcel appears to be undeveloped woodland, and topography in this region of Massachusetts is typically characterized by rolling hills and potential rock outcroppings, which could significantly increase site preparation and grading costs.

• Equipment Delivery: Feasibility is questionable without a route survey. The primary concern is whether large delivery vehicles can navigate local roads and access the site entrance without major temporary modifications.
• Site Access: Requires Verification. The exact point of access from Burnett Street to the parcel is not defined. A title search and survey are critical to determine if a legal, physical access point exists or if an access easement must be negotiated with an abutting landowner. The lack of a defined access point is a potential fatal flaw.
• Terrain: A topographical survey is necessary to assess slope gradients. Steep slopes would reduce the buildable area and increase civil engineering costs.

2. Environmental Constraints

The site presents several critical environmental unknowns that must be resolved before committing further resources. While some initial data points are favorable, the data gaps represent significant risk.

• FEMA Flood Zone: Requires Verification. The flood zone designation is unknown. Any portion of the site within a Special Flood Hazard Area (e.g., Zone A, AE) would be severely constrained, requiring elevated equipment platforms and potentially making the project uninsurable or un-financeable. A FEMA FIRMette map must be generated immediately.
• Wetlands: Requires Verification. The presence of wetlands is unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). A desktop screening using the National Wetlands Inventory (NWI) is the first step, followed by a formal field delineation by a certified wetland scientist if the screen indicates potential resources. The presence of wetlands could dramatically reduce the 10-acre site's buildable area.
• Critical Habitat: The initial screen shows no critical habitat, which is a positive indicator. However, this should be confirmed via the USFWS IPaC tool and consultation with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed species or sensitive habitats are present.
• Brownfield/Superfund Status: The absence of nearby brownfield or superfund sites is a double-edged sword. It reduces the risk of legacy contamination issues and associated cleanup liabilities. However, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a significant financial disadvantage.
• Pipeline Proximity: No major pipelines within three miles is a strong positive, eliminating risks related to pipeline easements, setbacks, and explosion safety concerns.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents a mixed but challenging picture. Proximity is reasonable, but the nature of the available infrastructure is poorly suited for a distribution-scale project. The interconnecting utility is presumed to be Eversource, but this requires confirmation.

• Substation Proximity: The nearest substation (TAP140793) is 1.1 miles away. This is a manageable distance, but the substation's maximum voltage of 115 kV indicates it is a transmission-level facility. Interconnecting a ≤5MW BESS at transmission voltage is exceptionally expensive and complex, often reserved for much larger projects.
• Transmission Line: A 115kV line is only 0.5 miles away but is flagged as "NOT AVAILABLE." This is a major red flag that requires immediate investigation with the utility. It could imply a lack of capacity, planned retirement, or that it belongs to a different entity.
- Recommended Interconnection: The primary goal should be to identify a viable 3-phase distribution feeder (e.g., 13.8 kV) for interconnection. A transmission-level interconnection is likely financially unviable. A search for nearby distribution lines originating from the substation or another source is the highest priority.
• Estimated Costs & Timeline: If a distribution feeder is available within 0.5 miles, interconnection costs could be in the range of $500k - $1.5M with a 18-24 month timeline. However, if a 1.1-mile line extension to the 115kV substation is the only option, costs would escalate dramatically to $3M - $7M+, with a timeline of 3-5 years, rendering the project infeasible.
• Utility Process: Interconnecting in Massachusetts with a utility like Eversource involves a formal, often congested, queue process. Timelines for study and approval can be lengthy and unpredictable.

4. Regulatory & Zoning Analysis

The regulatory landscape is the most significant barrier to development for this site. The residential zoning classification creates a substantial, and potentially insurmountable, permitting challenge.

• Authority Having Jurisdiction (AHJ): The Town of Granby.
• Zoning Compatibility: The parcel is zoned RS (Residential Single Family). BESS is an industrial/utility use and is fundamentally incompatible with this zoning. It is not a permitted use by-right.
• Permitting Pathway: The project would require, at a minimum, a Special Permit from the Planning Board and likely a Use Variance from the Zoning Board of Appeals (ZBA). A Use Variance is extremely difficult to obtain in Massachusetts, as it requires proving a unique hardship related to the land itself. This discretionary process is lengthy, expensive, and highly susceptible to public opposition ("NIMBYism"), especially in a residential area.
• Regulatory Risk: High. We must immediately review Granby's zoning bylaws to see if BESS is addressed at all. Many Massachusetts towns, wary of this new technology, have enacted moratoriums or highly restrictive bylaws. The absence of a specific BESS bylaw creates profound uncertainty.

5. IRA/ITC Incentive Analysis

The project's financial viability is severely hampered by its ineligibility for key Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA).

• Opportunity Zone: No. (0% adder)
• Energy Community: No. (0% adder)
• Low-Income Community: No. (0% adder)
• Cumulative ITC Adder: 0%. The project would only be eligible for the 30% base ITC (assuming prevailing wage and apprenticeship requirements are met). The lack of any 10% adders makes the project's economics significantly less competitive compared to sites that qualify for one or