⚡ MAPLE ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for Maple St, Sterling, MA (APN: 107_21)

This report provides a comprehensive due diligence analysis for the property located on Maple Street in Sterling, Worcester County, Massachusetts (APN 107_21). The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria. There are significant data discrepancies and high-risk factors associated with this site that require immediate investigation.

1. Site Access & Topography

• Road Access Quality: The provided data does not specify the quality of road access. Maple Street appears to be a local, two-lane road. A desktop review using satellite imagery and a physical site visit are required to verify if the road is paved, its width, and its overall condition. We must confirm it can support heavy truck traffic during construction.
• Terrain Characteristics: Worcester County is characterized by rolling hills, mixed hardwood forests, and rocky soil. We should assume moderately challenging terrain that may require significant grading and civil work, increasing site preparation costs. A formal topographic survey will be essential to determine the precise buildable area and associated civil engineering costs.
• Heavy Equipment Feasibility: Access for large, heavy equipment such as a 100-ton crane, transformers, and prefabricated battery enclosures is a major concern. Delivery routes from major highways to Maple Street must be analyzed for low-clearance bridges, sharp turns, and weight-limited infrastructure. The entrance from Maple Street onto the parcel will require the construction of a new, robust access road capable of handling these loads.
• Easement Concerns: The parcel does not appear to have existing, dedicated access from Maple Street. A new access road will need to be constructed entirely within the parcel boundaries. We must confirm that no portion of the required access path crosses neighboring properties, which would necessitate a difficult and costly access easement negotiation. The parcel's shape and frontage on Maple Street must be carefully reviewed.

2. Environmental Constraints

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical, potentially fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would require all equipment to be elevated above the Base Flood Elevation, adding substantial cost and complexity. If a significant portion of the site is in a floodway, it may be entirely undevelopable. Immediate action: Review FEMA Flood Insurance Rate Maps (FIRMs) for this parcel.
• Wetlands Presence: Wetlands status is "Unknown." Massachusetts has some of the most stringent wetlands protection regulations in the country. The presence of state or federally jurisdictional wetlands would trigger significant setbacks (typically 50-100 feet or more) and a lengthy, complex permitting process with the Sterling Conservation Commission and MassDEP. This could severely constrain or eliminate the buildable area. A desktop NWI screening followed by a formal wetland delineation by a certified professional is a mandatory next step.
• Critical Habitat / Endangered Species: The data indicates no critical habitat on site, which is a positive initial finding. However, this must be verified through the official USFWS IPaC (Information for Planning and Consultation) tool and a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no sensitive species or habitats are present.
• Brownfield/Superfund Status: The presence of a superfund site within two miles is noted. This does not automatically qualify our parcel for the 10% IRA brownfield tax credit adder. To qualify, our specific parcel must meet the federal definition of a brownfield, which typically involves prior contamination. A Phase I Environmental Site Assessment (ESA) is required to determine the site's history and potential eligibility. This is a potential opportunity but should be treated as a risk of nearby contamination until proven otherwise.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius. This is a significant advantage, as it removes risks associated with pipeline-related setbacks, safety protocols