⚡ STICKNEY RD

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 097 S28-29-0 (Stickney Rd, Fitchburg, MA)

This report provides a comprehensive due diligence analysis for a 9.01-acre parcel on Stickney Road in Fitchburg, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The provided data lacks specific information on road access quality. A desktop review using satellite imagery indicates that Stickney Road is a narrow, likely residential road, which may be unpaved or poorly maintained in sections. This presents a significant challenge for construction. Access for standard construction vehicles, let alone oversized and overweight loads, is highly questionable without substantial road improvements.

Terrain Characteristics: The site is in Worcester County, a region characterized by rolling hills, wooded areas, and potentially rocky, shallow-bedrock soil conditions. We anticipate moderate to significant topographical variation across the 9-acre parcel, which would necessitate extensive civil work, including grading and pad preparation, increasing overall project costs. A formal topographical survey is required for confirmation.

Heavy Equipment Access: Access for critical BESS components like multi-ton transformers and prefabricated battery containers (e.g., Tesla Megapacks or similar) is a major risk. The current state of Stickney Road is likely insufficient to support the weight and turning radius of low-boy trailers. Significant investment in road widening, reinforcement, and temporary construction access would be required.

Easement Concerns: It is critical to verify whether Stickney Road is a public or private road. If private, a formal, permanent access easement must be negotiated and secured. Furthermore, given the likely need for road upgrades, temporary construction easements from abutting landowners may also be necessary. These factors add legal complexity, cost, and timeline risk.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any portion of the buildable area falling within a 100-year floodplain (Zone A/AE) would impose severe design constraints, requiring all equipment to be elevated above the Base Flood Elevation, or could render the site entirely un-developable. A FEMA FIRMette must be reviewed immediately.

Wetlands: The presence of wetlands is Unknown. Given the Massachusetts landscape, the probability of jurisdictional wetlands and associated buffer zones on or adjacent to the parcel is high. Massachusetts regulations often require a 100-foot buffer from wetlands, which could severely restrict the buildable envelope of the 9-acre site. A formal wetlands delineation is a mandatory and immediate due diligence step.

Critical Habitat / Endangered Species: The data indicates no critical habitat on site, which is a positive finding. However, this should be verified with a query of the USFWS IPaC system and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to screen for state-listed species whose habitats could be impacted.

Brownfield/Superfund Status: The presence of three brownfield/superfund sites within a two-mile radius is a risk factor. While the subject parcel itself is not listed, its proximity to contaminated sites necessitates a Phase I Environmental Site Assessment (ESA) to rule out any potential soil or groundwater contamination from migrating plumes. This is a risk, not an advantage, as the site itself does not qualify for the 10% IRA brownfield adder.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant benefit, eliminating risks associated with pipeline easements, setbacks, and explosion safety concerns.

3. Grid Infrastructure & Interconnection

Nearest Substation & Utility: The nearest substation is RIVER STREET, located 1.7 miles from the parcel. This is a challenging distance for a distribution-scale project, guaranteeing a high-cost line extension. The utility is almost certainly National Grid, which serves this area. The provided voltage of "-999999 kV" is a data error; the River Street substation likely has standard distribution voltages (e.g., 13.2 kV) available for interconnection. The available capacity on the relevant feeder is a critical unknown and must be determined via a pre-application report.

Transmission Proximity: A 115kV transmission line is 1.9 miles away. Interconnecting a ≤5MW BESS at transmission voltage is economically infeasible; therefore, this line is not a viable Point of Interconnection (POI). The project must interconnect at the distribution level.

Interconnection Cost & Timeline: A 1.7-mile, 3-phase overhead distribution line extension will be a primary cost driver. A preliminary, high-level estimate for this scope would be in the $1.5M - $3.0M range, subject to terrain, rock, pole requirements, and road crossings. The interconnection process with National Grid in the ISO-New England (ISO-NE) territory is notoriously long and complex. We would anticipate a timeline of 24-36 months from application submission to