⚡ MARSHALL ST

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 228 6_4 (MARSHALL ST, Paxton, MA)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project on a 19.47-acre parcel located on Marshall Street in Paxton, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property appears to have frontage on Marshall Street, a paved, two-lane local road. Based on satellite imagery, access appears adequate for standard construction vehicles. However, the road is relatively narrow and winding, which could present logistical challenges for oversized and overweight loads.

Equipment Delivery: The primary concern is the delivery of the main power transformer and multi-ton BESS container enclosures. A detailed route survey is mandatory to assess turning radii, bridge weight limits, and overhead line clearances from the nearest state highway to the site. While likely feasible, it may require temporary road closures and coordination with local authorities, adding cost and complexity.

Terrain & Buildability: The site is undeveloped woodland. Topography in this region of Worcester County is typically characterized by rolling hills, significant ledge outcroppings, and rocky soil. A geotechnical survey will be critical to determine the extent of rock removal and grading required, which can be a major cost driver. The presence of "Babbling Brook Properties LLC" as the owner strongly suggests a water feature, which could impact the usable acreage and site layout.

Easements: Requires Verification. A title search and ALTA survey are needed to confirm that the property has unencumbered legal access directly from Marshall Street and to identify any existing utility or access easements that may cross the property and constrain the developable area.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown and represents a critical data gap. A review of FEMA's Flood Insurance Rate Maps (FIRMs) is an immediate next step. If any portion of the developable area falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment above the Base Flood Elevation, significantly increasing civil engineering costs and potentially rendering the site economically unviable.

Wetlands: Requires Verification. This is the most significant environmental risk. Given the landowner's name and the site's undeveloped nature, the presence of state and federally protected wetlands, streams, and vernal pools is highly probable. Massachusetts has stringent wetland protection laws, including the Wetlands Protection Act and often local bylaws with 100-foot or greater buffer zones where development is heavily restricted. A formal wetland delineation by a certified professional is a non-negotiable, early-stage diligence item.

Habitat & Species: The initial screening shows no designated critical habitat or protected areas on site, which is a positive initial finding. However, a Phase I Environmental Site Assessment (ESA) is still required to confirm the absence of endangered species and to provide a comprehensive environmental overview.

Brownfield/Superfund Status: The site is not a brownfield. This eliminates the potential for the 10% IRA Brownfield Adder but also significantly de-risks the project from a contamination and remediation liability standpoint. This is considered a neutral factor.

Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and permitting advantage, simplifying site layout and eliminating the need for specialized pipeline impact studies.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's primary asset is its proximity to a 115kV transmission line owned by Fitchburg Gas and Electric (Unitil), located just 0.1 miles away. This presents a prime opportunity for a utility-scale BESS project. The provided substation data (UNKNOWN157941, -999999 kV) is erroneous and must be disregarded. The focus should be on the 115kV line as the Point of Interconnection (POI).

Recommended Interconnection: A transmission-level interconnection at 115kV is the recommended pathway. This allows for a larger project size (likely the full 5MW or greater) and direct participation in ISO New England (ISO-NE) wholesale markets. A distribution-level interconnection is a potential but less attractive alternative, pending identification of a nearby feeder with sufficient capacity.

Cost & Timeline: Interconnecting at 115kV is capital-intensive. A new switching station or "three-breaker ring bus" configuration would be required. Estimated interconnection costs are in the $3M - $6M range. The interconnection process itself is governed by ISO-NE, which has a notoriously long, complex, and expensive queue process. The timeline from application submission to commercial operation can easily exceed 36 months.

Utility & Process: The interconnecting utility would be Unitil, but the study process is managed by the regional grid operator, ISO-NE. Securing a position in the ISO-NE queue is a critical early milestone but requires a significant financial deposit and detailed engineering studies.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (