⚡ CITY DEPOT 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 17-B-13.5 (City Depot Rd, Charlton, MA)

This report provides a comprehensive due diligence analysis for the subject property located on City Depot Rd 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.

1. Site Access & Topography

Road Access: The property has frontage on City Depot Road, which appears to be a two-lane, paved local road. While suitable for standard construction vehicles, a formal turning radius analysis is required to confirm it can accommodate low-boy trailers for delivering large transformers and battery containers. The quality of the road appears sufficient, but its width and shoulder conditions must be field-verified.

Terrain & Equipment Access: Based on aerial imagery, the 5.48-acre parcel is heavily wooded and appears to have moderately rolling terrain, which is characteristic of Central Massachusetts. Significant tree clearing and grading will be required to create a level pad for the BESS compound. This will increase site preparation costs and may trigger additional environmental or stormwater management permits. A detailed topographical survey is essential to quantify the necessary earthwork and identify the most suitable, flattest area for development. Access from City Depot Road onto the property itself will require the construction of a new, robust access drive capable of supporting heavy equipment loads.

Easement Concerns: A full title report is a critical next step. We must verify that there are no existing access, utility, or conservation easements that would encumber the property and restrict the placement of the BESS facility or its access road. We must also confirm that legal access is granted directly from the public right-of-way.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently listed as Unknown. This represents a significant project risk. A desktop screening using FEMA maps and the National Wetlands Inventory (NWI) must be conducted immediately. Any presence of a designated floodplain (e.g., Zone A, AE) would likely require elevating all equipment above the Base Flood Elevation, adding substantial cost. The likely presence of wetlands in this region of Massachusetts necessitates a formal wetland delineation by a certified professional. The Massachusetts Wetlands Protection Act and local Charlton conservation bylaws impose strict regulations, including significant buffer zones (typically 100 feet or more), which could severely constrain the buildable area.

Habitat & Contamination: The site shows no known critical habitat, protected areas, or nearby superfund sites. This is a positive, reducing the risk of complex endangered species consultations. The absence of a brownfield designation means the project is not eligible for the 10% IRA brownfield tax credit adder, which is a missed financial opportunity but avoids the complexities of developing a contaminated site.

Pipeline Proximity: The absence of any major gas pipelines within a three-mile radius is a significant safety and design advantage, eliminating the need for specialized setback studies and safety protocols related to pipeline hazards.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site is 1.9 miles from the Carpenter Hill substation and 1.8 miles from a 115kV transmission line. For a distribution-scale (≤5MW) project, interconnecting at these high voltages (345kV or 115kV) is technically and financially infeasible. The cost of a dedicated line and substation bay at this voltage would far exceed the project's total budget.

Likely Interconnection: The only viable path for this project is an interconnection to a local 3-phase distribution feeder. The interconnecting utility is likely National Grid (as Fitchburg Gas and Electric is a National Grid company). The primary challenge is that the capacity of distribution feeders often decreases with distance from the substation. At 1.9 miles away, the local feeder may lack the thermal capacity or voltage stability to accommodate a 5MW injection/withdrawal without extensive and costly upgrades (e.g., reconductoring, new reclosers). This is the single greatest technical risk for the project.

Cost & Timeline: Interconnection cost is highly uncertain and depends entirely on the condition of the local distribution feeder. A best-case scenario (POI directly adjacent with ample capacity) might be under $500,000. However, a more likely scenario requiring several miles of reconductoring could easily exceed $2,000,000. A formal interconnection application with National Grid is the only way to determine feasibility and cost. The ISO-NE interconnection queue, even for distribution-connected assets, can be lengthy, with study processes often taking 12-18 months before an Interconnection Service Agreement (ISA) is issued.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Charlton. There is a critical discrepancy in the provided zoning data: "Recreational" vs. "R-40" (Residential). Both are highly problematic for a BESS project. Neither zoning designation typically permits utility-scale energy facilities "by-right." R-40