⚡ 248 BEMIS RD

MEMORANDUM

TO: Sunland America Corp. Development Team
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 248 Bemis Rd, Fitchburg, MA (APN: 122-27-0)

1. Site Access & Topography

Road Access & Feasibility: The subject property is located at 248 Bemis Road in Fitchburg, MA. Based on aerial and street-level imagery, Bemis Road is a two-lane, paved commercial/industrial thoroughfare. Access appears to be direct and straightforward from this road. The quality seems sufficient for heavy truck traffic, including flatbeds for battery containers and heavy-haul vehicles for the main power transformer.

Terrain Characteristics: The site's current use as an auto repair facility strongly suggests that the parcel is predominantly flat, graded, and largely impervious (paved or compacted gravel). This is a significant advantage, as it will likely minimize the need for extensive civil work and site grading, thereby reducing construction costs and timelines. The 2.06-acre lot size is compact but potentially sufficient for a distribution-scale project (e.g., 5MW / 20MWh) if unencumbered.

Heavy Equipment Access: Given the industrial nature of the area and the direct frontage on Bemis Road, access for critical heavy equipment is anticipated to be feasible. However, a detailed logistics review is required to confirm turning radii from Bemis Road into the site entrance and to identify any potential overhead utility line conflicts that could impede crane operations or delivery of tall components like transformers.

Easement Concerns: As a small, developed parcel, there is a risk of existing utility easements (power, water, sewer, communications) crossing the property that could constrain the final BESS layout. A full ALTA survey and title report are essential to identify any such encumbrances. We must ensure that our primary access from Bemis Road is not restricted.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This represents a critical data gap and a potential fatal flaw. A priority action is to review the relevant FEMA Flood Insurance Rate Map (FIRM) for Worcester County Panel. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development costs could increase substantially due to requirements for elevated foundations, or the site could be rendered undevelopable.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. A desktop screening using the National Wetlands Inventory (NWI) is an immediate first step. Given the developed nature of the site, the risk may be lower, but any potential wetlands or vernal pools on or near the property would trigger significant setback requirements (typically 100-foot buffer zones) that would severely restrict the buildable area on this 2.06-acre parcel. A formal wetlands delineation will be required if screening indicates a risk.

Critical Habitat / Endangered Species: Initial data indicates no critical habitat or protected areas on site, which is a positive finding. This should be confirmed via the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no project nexus with state or federally listed species.

Brownfield/Superfund Status: The data indicates 44 contamination sites within a 2-mile radius, and the property's historical use as an auto repair garage presents a high risk of on-site contamination (e.g., hydrocarbons, solvents from hydraulic lifts, waste oil). This is both a major risk and a potential advantage.

• Risk: Potential for significant soil and/or groundwater contamination could necessitate costly and time-consuming remediation, potentially making the project economically unviable.
• Advantage: If contamination is confirmed, the site may qualify as a "brownfield site" under IRA guidelines. This would unlock a valuable 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is a mandatory and immediate next step to assess this risk and opportunity.

Pipeline Proximity: No major gas transmission pipelines are identified within 3 miles, mitigating risks associated with pipeline safety setbacks and explosion hazards.

3. Grid Infrastructure & Interconnection

Nearest Substation: The site's most compelling attribute is its proximity to the SUMMER STREET substation, located just 0.1 miles away. This extremely short distance dramatically reduces the cost and complexity of the generator lead line. The substation voltage is listed as an error code, but its name and location strongly imply it is a distribution-level facility, likely operating at a standard voltage like 13.8kV. The interconnecting utility is almost certainly Unitil (operating as Fitchburg Gas and Electric Light Company).

Transmission Proximity: The nearest transmission line (115kV) is 2.5 miles away. This is not a viable Point of Interconnection (POI) for