⚡ 193 ROCHDALE ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 193 Rochdale St, Auburn, MA (APN: 017 30_37)

This report provides a comprehensive due diligence analysis for the subject property, a 19.53-acre parcel in Auburn, Worcester County, Massachusetts, for its potential as a distribution-scale or utility-scale Battery Energy Storage System (BESS) site. The analysis concludes with a suitability score and a final recommendation.

1. Site Access & Topography

Road Access & Equipment Delivery: The property lacks direct frontage on Rochdale Street or any other public right-of-way. It appears to be a "landlocked" parcel situated behind existing residential homes. Rochdale Street itself is a local, two-lane residential road. While likely capable of supporting standard construction traffic, its suitability for oversized/overweight loads, such as a main power transformer or multiple 53-foot battery containers, is questionable and would require a detailed route survey. The primary and most critical issue is the complete lack of direct physical access to the site from a public road.

Terrain & Buildability: Based on aerial imagery and regional topography, the site is heavily wooded and appears to have undulating to hilly terrain, which is common in central Massachusetts. Significant tree clearing and civil work, including grading and leveling, would be required to create a suitable pad for a BESS facility. The costs associated with this site preparation will be substantial.

Heavy Equipment & Easements: Access for heavy equipment is currently not feasible. A permanent, 30-foot-wide (minimum) access and utility easement would need to be negotiated and purchased from at least one of the abutting residential property owners. This presents a significant project risk in terms of cost, timeline, and negotiation success. There is a high probability that a willing seller for such an easement cannot be found, rendering the site unbuildable. This is considered a potential fatal flaw.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Requires Verification. A preliminary desktop review suggests the majority of the parcel is in Zone X (minimal flood risk), but nearby watercourses could introduce areas of Zone AE (1% annual chance flood). A formal Flood Hazard Determination is a critical next step to confirm that the planned equipment pad is outside any special flood hazard areas.

Wetlands: The presence of wetlands is listed as Requires Verification. Given the undeveloped, forested nature of the site in Massachusetts, the presence of state and federally jurisdictional wetlands is highly probable. The Massachusetts Wetlands Protection Act imposes strict regulations, often including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A formal wetland delineation by a certified professional is mandatory and could significantly reduce the Buildable Acres.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a formal desktop environmental review is still necessary to screen for state-listed species (e.g., via the MA Natural Heritage & Endangered Species Program) whose presence could trigger further consultation or mitigation requirements.

Site Contamination: The property is not a known brownfield. While one Superfund site exists within a two-mile radius, it is unlikely to impact this parcel. This means the project is not eligible for the 10% IRA Brownfield ITC adder, which is a competitive disadvantage. The lack of contamination history is otherwise a positive, reducing potential remediation risks and costs.

Pipeline Proximity: No gas transmission pipelines are located within three miles, eliminating risks associated with pipeline proximity, such as blast zone setbacks or encroachment issues.

3. Grid Infrastructure & Interconnection

Substation & Transmission Assets: The nearest major electrical infrastructure is the TAP136356 substation (1.3 miles away) and a corresponding 115kV transmission line (1.2 miles away). This infrastructure belongs to FITCHBURG GAS AND ELECTRIC LIGHT COMPANY (a Unitil subsidiary, though National Grid is the primary utility in Auburn; this requires clarification). The 115kV voltage class is suitable for a large utility-scale project (20MW+), but it is a severe mismatch for our target distribution-scale (≤5MW) projects.

Interconnection Recommendation & Cost: The likely Point of Interconnection (POI) is the 115kV transmission line. A transmission-level interconnect is a complex, expensive, and lengthy process governed by ISO New England (ISO-NE). The estimated cost for a 1.2-mile 115kV line extension, plus the required substation upgrades (a new bay, breakers, etc.), would likely be in the $4M - $8M+ range. This cost is prohibitive for a ≤5MW project.

Timeline & Process: The ISO-NE interconnection queue is notoriously long and expensive. A transmission-level study process can take 3-4 years to complete before construction can begin. For a distribution-scale project, the appropriate path would be to interconnect to a local 13.8kV (or similar) distribution feeder. The data provided does not identify a suitable three-phase feeder near the site. Identifying a viable distribution POI with sufficient hosting capacity would require a separate, detailed study. Given the site's location behind a residential street, the local feeders may be single-phase or lack capacity for a multi-megawatt injection.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Auburn, Massachusetts.

Zoning Compatibility: The parcel's zoning is listed inconsistently as "Vacant Land - Private Preserve, Open Space" and "RB" (Residence B). Neither of these designations is favorable for energy infrastructure. Development in an Open Space or Preserve district is typically prohibited. In a Residence B zone, a BESS is not a permitted use by-right.

Permitting Pathway: The only conceivable permitting pathway would be to seek a Use Variance from the Auburn Zoning Board of Appeals, followed by a Special Permit from the Planning Board. This is the most difficult and uncertain entitlement path. It requires proving a legal hardship and is subject to significant discretionary review and public opposition, which is highly likely in a residential area. There is a high risk of a BESS moratorium being enacted by the town, a trend seen across Massachusetts municipalities.

Setbacks: Specific BESS setbacks are likely not defined in Auburn's code. The town would likely impose significant setbacks (e.g., 100-200 feet from property lines) and require extensive landscaping, noise mitigation, and safety measures as conditions of any approval.

5. IRA/ITC Incentive Analysis

This site performs poorly on all available ITC adders, making it financially less competitive than alternative locations.

• Opportunity Zone: No. (0% adder)
• Energy Community: No. (0% adder)
• Low-Income Community: No. (0% adder)

Potential Cumulative ITC Adder: 0%. The project would only be eligible for the 30% base ITC, missing out on up to 20% in additional incentives available at more strategically located sites.

6. BESS Score & Rationale

Overall BESS Suitability Score: