⚡ 543 N LIBERTY 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 276-16.03 (543 N LIBERTY ST, Belchertown, MA)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis identifies several significant challenges, primarily related to grid infrastructure distance and a lack of available IRA incentives, which temper the initial appeal of a vacant land parcel.

1. Site Access & Topography

The 6.11-acre parcel is located on North Liberty Street, which appears to be a two-lane, paved county road in adequate condition for standard construction traffic. However, the delivery of oversized and overweight equipment, such as a main power transformer (MPT) and fully-loaded battery containers, requires further evaluation. A formal road study would be necessary to confirm bridge weight limits, turning radii, and any overhead line clearance issues between major highways and the site.

Based on aerial imagery and regional topography, the site is likely wooded with moderately rolling terrain, characteristic of Hampshire County. Significant tree clearing and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. The current parcel does not have an established entrance from North Liberty Street, so a new commercial-grade access road will need to be constructed. The feasibility of heavy equipment access is therefore contingent on securing permits for a new curb cut and constructing an internal road capable of supporting crane and delivery vehicle loads. An access easement directly from the public right-of-way will need to be confirmed via a title search.

2. Environmental Constraints

The environmental profile presents several critical unknowns that must be resolved immediately.

• FEMA Flood Zone: The designation is currently Unknown. This is a primary risk. If the buildable area is within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase substantially due to the need to elevate all equipment above the Base Flood Elevation, or the site may be rendered undevelopable. Verification via the FEMA Map Service Center is a critical next step.
• Wetlands: The presence of wetlands is Unknown. Given the wooded nature of the site in this region, there is a moderate to high probability of state or federally jurisdictional wetlands and/or buffer zones being present. The Massachusetts Wetlands Protection Act imposes significant regulations, including potential 100-foot buffer zones, which could severely constrain the buildable area. A desktop screening using the National Wetlands Inventory (NWI) is required, likely followed by a formal field delineation.
• Habitat & Species: The data indicates no critical habitat on site, which is a positive initial finding. However, this should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are impacted by development.
• Brownfield/Superfund: The absence of nearby brownfield or superfund sites is positive from a liability and cleanup perspective, but it is a disadvantage from a financial standpoint, as the project is ineligible for the 10% IRA brownfield tax credit adder.

No pipeline proximity issues were identified, which is a minor positive.

3. Grid Infrastructure & Interconnection

Grid access is the most significant challenge for this site. The nearest substation, THORNDIKE, is 1.8 miles away. This is a considerable distance for a distribution-scale project and suggests that interconnection costs will be very high.

• Point of Interconnection (POI): The most likely POI would not be at the substation itself, but on a 3-phase distribution feeder originating from it. The interconnecting utility is likely National Grid. We must assume a distribution feeder runs along North Liberty Street, but its capacity, phase, and condition are unknown. The 345kV transmission line 1.6 miles away is not a viable POI for a project of this scale (≤5MW).
• Recommended Voltage: Interconnection will be at the local distribution voltage, likely 13.2 kV or a similar class.
• Estimated Cost & Timeline: A 1.8-mile distance to the substation often indicates a weak or fully subscribed feeder. A line extension of this length, along with necessary substation upgrades (e.g., a new breaker, reclosers), could easily place interconnection costs in the $2.0M - $4.0M+ range. The ISO New England (ISO-NE) interconnection queue, managed by National Grid, can be lengthy. The full study process (Feasibility, System Impact, Facilities) can take 24-36 months or longer to complete before construction can begin.

The high probability of exorbitant interconnection costs and a protracted timeline makes the grid access for this site a potential fatal flaw.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is the Town of Belchertown. The parcel's zoning is listed as AG-A (Agricultural), which is unlikely to permit a BESS project "by-right." Energy infrastructure is typically a conditional or specially permitted use in agricultural zones.

The likely permitting pathway