⚡ N SULLIVAN RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 054 28-A-3, N Sullivan Rd, Charlton, MA

This report provides a comprehensive due diligence analysis for the property located at N Sullivan Rd, Charlton, MA (APN 054 28-A-3) for its suitability as a distribution or utility-scale Battery Energy Storage System (BESS) project. The analysis identifies significant challenges related to grid interconnection costs, regulatory hurdles, and a lack of federal incentives, resulting in a low suitability score.

1. Site Access & Topography

Road Access: The subject parcel is located on N Sullivan Road, a secondary road in a rural part of Charlton. Initial desktop review using aerial imagery suggests N Sullivan Road is a narrow, potentially unpaved or poorly maintained local road. This presents a significant risk for the delivery of heavy and oversized equipment.

Equipment Delivery: The delivery of multi-ton battery containers, pad-mount transformers, and switchgear requires roads capable of supporting 80,000-lb tractor-trailers, with adequate turning radii and overhead clearance. The current condition of N Sullivan Road is unlikely to meet these requirements without substantial upgrades, which would add considerable cost and require permits from the Town of Charlton.

Topography & Buildability: The terrain in this region of Worcester County is characterized by rolling hills, wooded areas, and potentially rocky soil conditions. This suggests that significant site grading and civil work will be necessary to create a level pad for the BESS equipment. The provided data shows a major discrepancy in parcel size (14.55 acres vs. 3.46 acres from Regrid). This must be clarified immediately, as 3.46 acres is marginal for a 5MW BESS project once setbacks and environmental buffers are applied.

Easements: The parcel appears to have limited frontage on N Sullivan Rd. A formal access easement will need to be secured and recorded. Furthermore, the 1.6-mile interconnection route to the substation will require extensive easements from multiple landowners for a new pole line, which can be a time-consuming and expensive process.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is listed as "Unknown." This is a critical data gap. Any designation within a 100-year floodplain (Zone A or AE) would severely restrict development or require that all equipment be elevated above the Base Flood Elevation, adding significant cost and complexity. A FEMA FIRMette review is an immediate next step.

Wetlands: The wetlands status is "Unknown." Massachusetts has some of the most stringent wetlands regulations in the country under the Massachusetts Wetlands Protection Act. Given the site's wooded and undeveloped nature, the presence of jurisdictional wetlands is highly probable. A desktop screening using MassGIS OLIVER is required, to be followed by a formal field delineation. The presence of wetlands would trigger, at a minimum, 100-foot buffer zones, which could consume a large portion of the buildable area, especially on the smaller 3.46-acre parcel.

Habitat & Other Factors: The site is clear of designated critical habitats, protected areas, and nearby brownfield/superfund sites. The lack of a brownfield designation means the project is ineligible for the 10% IRA Brownfield Adder, which is a missed opportunity. The absence of nearby pipelines is a positive safety factor.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation is West Charlton, located 1.6 miles from the site. This is a considerable distance for a new line build. The substation has a maximum voltage of 115 kV, indicating it supports both transmission and distribution assets. The nearest transmission line is also 1.6 miles away and is a 115 kV line owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary).

Interconnection Strategy & Cost: For a ≤5MW BESS, a distribution-level interconnection (e.g., 13.8 kV) is strongly preferred to minimize cost and complexity. However, a 1.6-mile distribution line extension is a major cost driver, likely in the $1.5M - $3.0M range, and subject to utility cost estimates from a formal study. A transmission-level (115 kV) interconnection would be prohibitively expensive (likely >$5M) for a project of this scale. The interconnecting distribution utility is likely National Grid, but this Requires Verification.

Utility Process: Interconnection in Massachusetts is governed by the state's DPU