⚡ 41A BACON ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 41A Bacon St, Westminster, MA (APN: 99_22)

This report provides a comprehensive due diligence analysis for the property located at 41A Bacon Street in Westminster, Worcester County, Massachusetts. The 5.61-acre parcel presents a compelling grid-proximity opportunity but is burdened by significant environmental unknowns and a lack of federal incentive adders. The following sections detail the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has frontage on Bacon Street, a two-lane, paved local road. Initial desktop review suggests this road is sufficient for standard construction traffic. However, its suitability for oversized and overweight loads, such as a main power transformer or 53-foot battery containers on a low-boy trailer, Requires Verification. A route survey would be necessary to assess turning radii from major arteries like Route 2, as well as to check for any low-clearance bridges or weight-restricted roads in the vicinity. The quality of the road appears adequate, but a physical site visit is needed to confirm.

Terrain & Site Preparation: Located in Central Massachusetts, the parcel's topography is likely to be rolling to hilly, consistent with the region. The "Land Use" and "Buildability" fields are unpopulated, indicating a critical data gap. A topographical survey is essential. Significant grading could be required to create a level pad for the BESS equipment, potentially increasing civil construction costs. The current state of the parcel (wooded, cleared, etc.) is unknown and will heavily influence site preparation expenses.

Access Easements: The parcel appears to have direct frontage, but the exact location of the proposed BESS compound within the 5.61 acres is undetermined. A title search is required to confirm that no access easements are needed across neighboring properties and to ensure there are no existing utility or access easements encumbering the most logical buildable area of the site.

2. Environmental Constraints

The environmental profile of this site is characterized by critical unknowns that represent a potential fatal flaw.

• FEMA Flood Zone: The flood zone designation is "Unknown." This is a high-priority risk. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development would be severely restricted or require costly mitigation measures, such as elevating all equipment above the Base Flood Elevation, likely rendering the project economically unviable. An immediate FEMA FIRMette review is required.
• Wetlands: The presence of wetlands is "Unknown." Massachusetts has highly restrictive wetland regulations under the Massachusetts Wetlands Protection Act, which includes a 100-foot buffer zone around delineated resources where activity is limited. On a small 5.61-acre parcel, the presence of wetlands could drastically reduce or even eliminate the buildable area. A desktop National Wetlands Inventory (NWI) screening is the first step, likely to be followed by a full field delineation by a certified wetland scientist.
• Critical Habitat / Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be confirmed via a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-level concerns exist.
• Brownfield/Superfund Status: The site itself is not listed as a brownfield. However, the presence of one Superfund/brownfield site within two miles suggests a history of industrial use in the area. This presents both a risk and a potential (though unlikely) opportunity. The risk is potential contaminant migration, which must be assessed via a Phase I Environmental Site Assessment (ESA). The opportunity is that if the Phase I ESA were to identify Recognized Environmental Conditions (RECs) qualifying the