⚡ JOSLIN RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis – Joslin Rd, Winchendon, MA (APN 11-0-12)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 7.53-acre parcel located on Joslin Rd in Winchendon, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives. While the site possesses strong grid infrastructure proximity, significant and potentially fatal flaws in its regulatory and zoning profile present substantial development risk.

1. Site Access & Topography

• Road Access & Feasibility: The property is located on Joslin Road. Initial desktop analysis suggests this is a local, two-lane road, likely with residential characteristics. Requires Verification: A site visit is mandatory to confirm the road's width, surface type (paved/gravel), weight limits, and presence of any low-hanging utility lines. The suitability for heavy haul trucks delivering multi-ton transformers and battery enclosures is a significant concern. A formal route survey will be necessary to clear a path from the nearest state highway.
• Terrain Characteristics: As vacant land in Worcester County, the site is presumed to be wooded with rolling topography, characteristic of central New England. This could necessitate significant clearing, grading, and civil engineering work, increasing site preparation costs. A topographical survey is a critical next step to determine the extent of earthwork required and to identify optimal, level locations for equipment pads.
• Heavy Equipment Access: Access from Joslin Road onto the parcel itself is undefined. There is no visible existing curb cut or access drive. The ability to construct a suitable access road for a lowboy trailer and a 100-ton crane is a major unknown.
• Easement Concerns: A preliminary title report is required to confirm that the property has legal, insurable access directly from Joslin Road and is not landlocked or dependent on an easement across neighboring properties. Any shared access agreement could introduce unacceptable project risk.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. If any portion of the buildable area falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would require elevating all equipment above the Base Flood Elevation, adding significant cost and complexity. Any development within a floodway would be prohibited.
• Wetlands: The presence of wetlands is unknown but highly probable in this region of Massachusetts. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A wetland delineation by a certified professional is essential, as the presence of wetlands could severely reduce the 7.53-acre parcel's buildable area.
• Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. A Phase I Environmental Site Assessment (ESA) will be required to formally document this and satisfy financing and permitting requirements.
• Brownfield/Superfund Status: The site is not in proximity to a brownfield or superfund site. While this mitigates environmental liability risk, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, a notable disadvantage compared to other sites.
• Pipeline Proximity: No gas transmission pipelines are located within three miles, eliminating a significant safety, setback, and co-location risk.

3. Grid Infrastructure & Interconnection

• Substation Proximity: The site's strongest attribute is its proximity to substation "UNKNOWN133567," located just 0.8 miles away. This substation has a maximum voltage of 69 kV, indicating it is a significant node on the local grid. This short distance makes a new line extension (gen-tie) technically and financially feasible.
• Transmission Proximity: A 115 kV transmission line is 2.9 miles away. For a ≤5MW project, interconnecting at transmission voltage would be cost-prohibitive and unnecessarily complex. The focus must remain on the nearby substation.
• Recommended Interconnection: The most viable path is a distribution-level interconnection to a feeder (likely 13.8 kV or similar) originating from the 69 kV substation. Requires Verification: The interconnecting utility must be identified (likely National Grid for this area) to confirm available distribution feeders and their capacity. A direct 69 kV tap is a less likely, higher-cost alternative.
• Cost & Timeline Estimate: A 0.8-mile overhead distribution line extension could range from $800,000 to $2,000,000, contingent on terrain, pole requirements, and road crossings. The interconnection process in the ISO-New England territory is notoriously long and complex. From application submission to Commercial Operation, a timeline of 24-48