⚡ FLINT RD

MEMORANDUM

TO: Sunland America Corp. Development Team
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 054 60-C-1 (Flint Rd), Charlton, MA

This report provides a comprehensive due diligence analysis for the 10.76-acre property located on Flint Road in Charlton, 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. The overall recommendation is a NO GO due to fundamental, likely insurmountable challenges related to grid interconnection, zoning, and project economics.

1. Site Access & Topography

Road Access: The property is located on Flint Road, which appears to be a secondary, local road. A desktop review using satellite imagery suggests Flint Road is a narrow, paved road. Its suitability for heavy haul trucks carrying multi-ton transformers or 40-foot battery containers is questionable and requires a physical site visit to confirm turning radii, road width, and any potential weight limit restrictions on local bridges or culverts.

Topography & Site Conditions: Worcester County is known for its rolling hills and potentially rocky terrain. While a formal survey is required, initial analysis suggests the site is undeveloped woodland with moderate elevation changes. Significant grading and tree clearing would be necessary, increasing civil construction costs. The presence of bedrock is a moderate risk in this region, which could complicate foundation work.

Equipment Access: The primary concern is whether the parcel has legal and physical frontage on Flint Road. The parcel appears to be set back from the road ("flag lot") or potentially landlocked. Delivering heavy equipment is contingent on securing a permanent, all-weather access easement of sufficient width (minimum 30-40 feet) from an adjacent landowner. Without a deeded, insurable access easement, the site is unbuildable. This is a critical and immediate diligence item.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a major data gap. A review on the FEMA Flood Map Service Center is required immediately. If the buildable area falls within a Zone A or AE, development would be severely complicated, requiring equipment to be elevated above the Base Flood Elevation, significantly increasing costs and potentially making the project infeasible. An ideal site would be entirely within Zone X (minimal flood risk).

Wetlands: The presence of wetlands is Unknown. Given the undeveloped nature of the site in Massachusetts, there is a high probability of state or federally jurisdictional wetlands and associated buffer zones. The Massachusetts Wetlands Protection Act imposes a 100-foot buffer zone around most wetland resources, which would sterilize significant acreage. A desktop screen using the USFWS National Wetlands Inventory (NWI) and MassGIS OLIVER is the first step, but a formal wetland delineation by a certified professional will be required to confirm buildable area.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive. However, it is prudent to cross-reference the location with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm no sensitive species are mapped in the vicinity.

Site Contamination: The site has no known Brownfield or Superfund history. While this prevents contamination-related development risks, it also means the project is ineligible for the 10% IRA Brownfield tax credit adder, a notable disadvantage.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating concerns about pipeline-related setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site is located 1.5 miles from the Carpenter Hill Substation and 1.0 mile from a 345kV transmission line. This proximity is deceptive; while geographically close, the infrastructure is entirely unsuitable for a distribution-scale project.

Interconnection Voltage & Feasibility: The available infrastructure is 345kV, which is a bulk transmission voltage. Interconnecting a small 5MW BESS at this voltage is technically and financially infeasible. It would require constructing a new, multi-million-dollar switching station and would trigger extensive, costly, and time-consuming ISO-New England (ISO-NE) system impact studies. The interconnection cost would likely exceed the entire project budget, potentially in the $10M - $20M+ range, with a timeline of 5-7 years.

Distribution Feasibility: For a ≤5MW project, the only viable interconnection is to a three-phase distribution feeder (typically 13.8kV in this region, operated by National Grid). There is no data indicating the presence, capacity, or route of such a feeder near the site. Given the rural, residential nature of the area, any existing distribution lines are likely to be single-phase or have insufficient capacity to support a 5MW injection. This lack of viable distribution infrastructure is a fatal flaw.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Charlton Planning Board and Zoning Board of Appeals.

Zoning Compatibility: The parcel is zoned "A" (likely Agricultural or Residential). This zoning is fundamentally incompatible with a utility-scale BESS facility, which is an industrial use. Development is not a by-right possibility.

Permitting Pathway: The project would require, at a minimum, a Special Permit from the Planning Board, and more likely, a Use Variance from the Zoning Board of Appeals (ZBA). A Use Variance is exceptionally difficult to secure in Massachusetts, as