⚡ ASHBY RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 011 22_45 (Ashby Rd, Ashburnham, MA)

This report provides a comprehensive due diligence analysis for the 9.71-acre property located on Ashby Road in Ashburnham, Worcester County, MA. 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 Ashby Road, which appears to be a two-lane, paved, public road. While sufficient for standard vehicles, a formal survey and assessment are required to confirm its width, weight limits, and turning radii are adequate for heavy-haul trucks delivering multi-ton equipment like transformers and battery containers.

Terrain & Equipment Feasibility: The topography in this region of Worcester County is typically characterized by rolling hills and dense woodlands. Satellite imagery suggests the parcel is heavily wooded and may have moderate elevation changes. Significant tree clearing, grading, and civil work will be required to create a level pad for the BESS equipment. A geotechnical study is essential to assess soil stability and foundation requirements. Access for heavy equipment is feasible from Ashby Road, but a new, robust access road will need to be constructed onto the site itself.

Easement Concerns: A formal access easement from the public right-of-way (Ashby Road) to the project footprint will need to be secured if the ideal site location is set back from the road. Additionally, a utility easement will be required for the 2.0-mile interconnection route to the substation, which will involve negotiations with multiple landowners and potentially the municipality, adding complexity and cost.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any location within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable for critical infrastructure like a BESS or require significant and costly elevation and mitigation measures. Verification via the FEMA Map Service Center is a top priority.

Wetlands: The presence of wetlands is Unknown but highly probable given the New England landscape. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. A desktop screening using MassGIS OLIVER is the immediate first step, but a formal wetland delineation by a certified professional will be required. Any identified wetlands will necessitate significant setbacks (typically 100 feet or more), which could severely constrain the buildable area on the 9.71-acre parcel.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this must be verified through a query of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or their habitats are present.

Brownfield/Superfund Status: There are three brownfield/superfund sites within a two-mile radius, but the subject parcel itself is not listed. This proximity necessitates a Phase I Environmental Site Assessment (ESA) to rule out any contamination risk. While the data indicates the site is not in an Energy Community, we should verify if the parcel itself could be designated as a "brownfield site" under federal definitions, which could potentially unlock the 10% IRA brownfield tax credit adder. This represents a minor potential upside but is unlikely.

Pipeline Proximity: No gas pipelines are located within a three-mile radius, eliminating this as a safety or setback concern.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is ASHBURNHAM, located approximately 2.0 miles from the parcel. This is a significant distance for a distribution-scale project. The substation and the nearest transmission line (1.9 miles away) operate at 115 kV, which is transmission-level voltage.

Interconnection Recommendation: Interconnecting a ≤5MW BESS at 115 kV is financially and technically infeasible. The required equipment (high-voltage breakers, transformers) and studies are prohibitively expensive. The only viable path is to interconnect to a local distribution feeder (e.g., 13.8 kV). The presence and route of a suitable three-phase distribution feeder along Ashby Road is Unknown and represents a potential fatal flaw. We must assume the interconnecting utility is Unitil (based on the transmission line owner, Fitchburg Gas and Electric Light Company), but this requires verification.

Cost & Timeline Estimate: Assuming a viable distribution feeder is available, the 2.0-mile line extension would be extremely costly. A rough estimate for this scope would be $2.5M - $4.0M+, including utility extension costs, required upgrades