⚡ ROUTE 56

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 151 37 A2 0 (2.72 Acres), Leicester, MA

This report provides a comprehensive due diligence analysis for the subject property located on Route 56 in Leicester, Worcester County, Massachusetts, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis identifies several critical risks, primarily concerning zoning and regulatory approval, that must be addressed before committing further resources.

1. Site Access & Topography

Road Access: The property has frontage along Route 56 (Huntoon Memorial Highway), a two-lane state-maintained road. A preliminary review of aerial imagery suggests the road is paved and in reasonable condition, suitable for standard construction traffic. However, the presence of shoulders, turn-out lanes, and specific curb-cut access points is unclear. A formal site visit is required to confirm the road's width and condition can support oversized and overweight loads.

Equipment Delivery: Delivery of heavy equipment, such as a 50-ton main power transformer and 40-foot, 35-ton battery containers via lowboy trailers, appears feasible from a high level. The primary concern will be creating a suitable construction entrance off Route 56 that meets Massachusetts Department of Transportation (MassDOT) standards. The turning radius from the highway onto the site must be evaluated by a civil engineer.

Topography: While a formal survey is needed, topographical maps of Worcester County indicate the region is characterized by rolling hills. The parcel itself appears relatively flat near the road frontage, but may slope downwards away from the road. A detailed topographical survey is essential to determine grading requirements, which could significantly impact site preparation costs. A flat, pre-disturbed pad is ideal for minimizing civil work.

Easement Concerns: A title search is required to identify any existing access, utility, or conservation easements that may encumber the property. A new access easement will need to be formally granted and recorded for ingress/egress from Route 56.

2. Environmental Constraints

FEMA Flood Zone: The property's FEMA flood zone designation is listed as Unknown. This is a critical data gap. Any designation within a Special Flood Hazard Area (e.g., Zone A, AE) would introduce significant design challenges, requiring equipment to be elevated above the Base Flood Elevation. This would substantially increase foundation costs and could trigger more intensive environmental reviews. Verification via FEMA's Flood Insurance Rate Maps (FIRMs) is a top priority.

Wetlands: The presence of wetlands is Unknown. Massachusetts has one of the nation's most stringent wetlands protection frameworks under the Massachusetts Wetlands Protection Act (WPA). Any development within 100 feet of a designated wetland (the "Buffer Zone") requires a Notice of Intent (NOI) filing with the Leicester Conservation Commission. A formal wetland delineation by a certified professional is a mandatory next step to determine the buildable area envelope.

Habitat & Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. This is a significant positive, reducing the risk of project delays or mitigation requirements related to the Endangered Species Act. This should be confirmed with a desktop review of MassGIS Natural Heritage & Endangered Species Program (NHESP) data.

Brownfield/Superfund Status: The site is not located near any known brownfield or superfund sites. While this is positive from a liability and remediation standpoint, it means the project is ineligible for the 10% ITC adder for projects on brownfield sites, a notable disadvantage for project economics.

Pipeline Proximity: The absence of major gas transmission pipelines within a three-mile radius is a key safety and de-risking factor, eliminating concerns related to pipeline setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Nearest Substation & POI: The nearest major electrical infrastructure is "TAP136359" at a distance of 0.8 miles, with a maximum voltage of 69 kV. This is a sub-transmission voltage. While the proximity is excellent, a 69 kV interconnection for a ≤5MW BESS is typically cost-prohibitive due to the high cost of sub-transmission-class switchgear, protection, and substation work.

Recommended Interconnection: The most economically viable Point of Interconnection (POI) would be a 3-phase overhead distribution feeder, likely operating at 13.8 kV. It is highly probable that such a feeder runs along Route 56. The immediate priority is to obtain distribution system maps from the interconnecting utility (presumed to be National Grid, but Requires Verification) to identify the nearest 3-phase circuit and its available capacity.

Cost & Timeline Estimate: Assuming a viable