⚡ DEVILS LN # 5

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 311 12-0-8 (Devils Ln), Warren, MA

This report provides a comprehensive due diligence analysis for the property located at Devils Ln # 5 in Warren, 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 & Equipment Delivery: The property's listed access is via "Devils Ln," which, based on preliminary mapping, appears to be a minor, potentially unpaved or poorly maintained rural road. This presents a significant logistical challenge and risk. The feasibility of delivering heavy and oversized equipment, such as 53-foot battery containers, a main power transformer (potentially exceeding 100,000 lbs), and construction cranes, is highly questionable without substantial road improvements. A detailed civil engineering assessment, including a turning radius analysis and road structural capacity review, would be required.

Terrain Characteristics: As is typical for Worcester County, the site is likely to feature rolling hills and extensive tree cover. The "Vacant Land" use designation suggests the parcel is undeveloped and heavily wooded. This will necessitate significant site work, including clearing, grading, and the creation of a level pad for the BESS equipment. The costs associated with this site work could be substantial. Requires Verification: A site visit and topographical survey are essential to confirm conditions.

Heavy Equipment Access: The current access via Devils Ln is presumed to be inadequate for heavy haul trucks and cranes. The project budget must include a significant contingency for road upgrades, which could involve widening, grading, and laying new gravel or pavement. The cost and permitting for these off-site improvements could be prohibitive.

Easement Concerns: A title search is required to confirm that legal, insurable access exists from a public right-of-way to the parcel via Devils Ln. If Devils Ln is a private road, a formal access easement agreement with all relevant landowners would be necessary. Furthermore, an easement will be required for the generator lead line running from the project to the point of interconnection (POI).

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the site located within a 100-year floodplain (Zone A/AE) would be severely constrained, requiring all equipment to be elevated above the Base Flood Elevation (BFE), adding significant cost and complexity. Development within a floodway is typically prohibited. A FEMA FIRMette review is an immediate next step.

Wetlands: The presence of wetlands is unknown but highly probable given the site's location in a rural, wooded area of Massachusetts. The Massachusetts Wetlands Protection Act (WPA) and local bylaws impose strict regulations, often including 100-foot buffer zones ("Riverfront Area") around perennial streams and 50-100 foot "No-Disturb" zones around delineated wetlands. The presence of significant wetlands could drastically reduce the buildable area and potentially render the site undevelopable. Requires Verification: A desktop NWI screen followed by a formal wetland delineation is critical.

Critical Habitat / Endangered Species: The initial screen shows no critical habitat on site. This is a positive finding. However, it is prudent to cross-