⚡ HENSHAW ST

CONFIDENTIAL - BESS SITE DILIGENCE ANALYSIS

To: Sunland America Corp. Development Committee

From: Senior BESS Site Evaluation Analyst

Date: October 26, 2023

Subject: Comprehensive Site Analysis for APN 017 29_11 (Henshaw St, Auburn, MA)

This report provides a comprehensive due diligence analysis for the 4.29-acre property located on Henshaw Street in Auburn, Worcester County, Massachusetts. 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 & Feasibility: Initial desktop review indicates that the property is located on Henshaw Street, which appears to be a minor local road. Satellite imagery suggests it may be narrow, unpaved, or have a low weight-bearing capacity. This presents a significant risk for the delivery of heavy equipment. A standard BESS project requires multiple deliveries via low-boy trailers (for battery containers, typically 80,000 lbs) and a heavy-haul truck for the main power transformer (often exceeding 100,000 lbs). The current access appears insufficient and would likely require substantial road improvements, adding significant cost and permitting complexity.

Terrain & Buildability: The site is in central Massachusetts, a region characterized by rolling hills and dense tree cover. It is highly probable that the parcel is wooded and possesses moderate to significant topographic relief. This will necessitate extensive tree clearing, grubbing, and grading to create a level pad for the BESS equipment, switchgear, and access roads. The provided data lacks specific buildable acreage, but these factors will reduce the usable area and increase civil engineering costs substantially.

Easement Concerns: The parcel's configuration and limited frontage on a minor road raise immediate concerns about legal and physical access. We must verify that the property has direct, deeded access to a public right-of-way. If access is through an existing easement over neighboring properties, its terms must be reviewed to ensure it allows for heavy industrial traffic and utility construction, which is highly unlikely. A new, wider easement may need to be negotiated and purchased, introducing risk and cost. This is a potential fatal flaw requiring immediate title review.

2. Environmental Constraints

Flood & Wetlands: The FEMA Flood Zone and wetlands status are listed as "Unknown." These are critical data gaps. A desktop review using MassMapper (the state's official GIS data viewer) and the FEMA Map Service Center is the immediate next step. Any presence of FEMA-designated floodplains (e.g., Zone A, AE) would severely restrict development or require costly mitigation like elevating all equipment. Similarly, Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with 100-foot buffer zones. The likely presence of wetlands on a wooded, undeveloped parcel in this region is high and could render a significant portion of the site undevelopable.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a formal Phase I Environmental Site Assessment (ESA) will be required to confirm this and to satisfy financing and permitting requirements.

Contamination Status: The presence of a brownfield/superfund site within two miles is noted. This is primarily a risk of potential migrating contamination, which should be assessed in the Phase I ESA. It is important to clarify that this does not qualify the project for the 10% IRA Brownfield ITC adder. To qualify, the project must be sited on a property that meets the federal definition of a brownfield, which is not the case here.

Other Constraints: No pipelines or gas wells are identified nearby, which mitigates safety and setback risks associated with such infrastructure.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The nearest substation (TAP136356) and 115 kV transmission line are 1.5 miles away. For a distribution-scale project (≤5MW), a 115 kV interconnection is financially and technically infeasible. The project must interconnect to a local distribution feeder, typically operating at 13.8 kV.

Interconnection Feasibility & Cost: The 1.5-mile distance to the substation is a major barrier. We would need to construct a new 3-phase distribution line extension for this entire distance. The cost for such a line extension is substantial, conservatively estimated at $1M - $2M per mile, placing the interconnection cost in the $1.5M - $3.0M+ range. This cost would likely make a ≤5MW project economically non-viable. The immediate priority is to determine if a suitable 3-phase distribution feeder from National Grid (the likely utility, Requires Verification) already exists along Henshaw Street or a nearby road. If not, the site is likely a fatal flaw from a grid perspective.

Utility & Queue: Assuming the utility is National Grid, the Massachusetts interconnection process is complex and the queue is notoriously congested. Even for a small generator application, the timeline from application submission to commercial operation can easily exceed 24-36 months. The high cost and long timeline present significant development risks.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Auburn. The property is zoned RR (Rural Residence). A BESS is an industrial utility use and is fundamentally incompatible with residential zoning.

Permitting Pathway: Development is not possible by-right. The project would require, at a minimum, a Use Variance from the Auburn Zoning Board of Appeals (ZBA). A Use Variance is the most difficult zoning relief to obtain, as it requires proving a legal hardship unique to the property. The likelihood of success is extremely low, especially given the high potential for significant local opposition ("NIMBYism") from neighboring residential property owners.

Regulatory Risk: This represents the single greatest non-financial risk for the project. The entitlement process would be long, expensive, and uncertain. The Town of Auburn may not have specific BESS ordinances, which could lead them to impose a development moratorium while they study the issue. We must assume a highly contentious and high-risk permitting process.

5. IRA/ITC Incentive Analysis

ITC Adders: The site's location provides no eligibility for the 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: The project would only be eligible for the base 30% ITC (assuming prevailing wage and apprenticeship requirements are met). The lack of any 10% adders places this site at a significant financial disadvantage compared to competing projects that qualify for a 40% or 50% ITC, severely impacting its market competitiveness and potential profitability.

6. BESS Score & Rationale