⚡ 375 HARVARD ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 375 Harvard St, Leominster, MA (APN: 153 370_19)

This report provides a comprehensive due diligence analysis for the property located at 375 Harvard Street in Leominster, MA. The analysis evaluates the site's suitability for a distribution-scale or utility-scale Battery Energy Storage System (BESS) project. The findings are based on the provided property data and preliminary desktop research.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has excellent road access, fronting directly onto Harvard Street (Route 2A), a major, paved, multi-lane state highway. This provides straightforward access for all phases of construction, from initial surveying to the delivery of heavy equipment. Standard semi-trucks transporting battery containers, switchgear, and large power transformers should have no issue accessing the property entrance.

Terrain Characteristics: Based on topographical maps and satellite imagery, the parcel appears relatively flat and cleared, consistent with its industrial zoning and prior use. The area in Leominster is characterized by rolling hills, but this specific parcel seems to have been graded for industrial development, which significantly reduces initial civil work costs. A formal survey is required to confirm precise elevations and grading requirements.

Heavy Equipment Feasibility: Access for heavy equipment is considered low-risk. The proximity to a major highway and the likely industrial-grade entrance can accommodate cranes for setting transformers and container handling equipment. The primary consideration will be the on-site road and pad preparation to support the weight of fully loaded delivery vehicles and cranes.

Easement Concerns: While on-site access is strong, a key consideration will be the easement for the generator lead line to the Point of Interconnection (POI) at the substation 0.3 miles away. The most likely path would be along the public right-of-way of Harvard Street, which would require permits from the municipality and/or MassDOT. If a direct, cross-country route is necessary, it would require negotiating easements with intervening landowners, adding complexity and cost. This requires immediate verification.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), all equipment pads and control houses would need to be elevated above the Base Flood Elevation (BFE), substantially increasing civil engineering and construction costs. A review of the FEMA Flood Map Service Center is a top priority.

Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws, including the Massachusetts Wetlands Protection Act, which establishes a 100-foot buffer zone around delineated wetland resources. The presence of wetlands could significantly reduce the 10-12 acre parcel's buildable area and trigger a lengthy review process with the Leominster Conservation Commission. A desktop screening followed by a formal wetland delineation is essential.

Critical Habitat / Endangered Species: The initial screening shows no designated critical habitats or protected areas on or immediately adjacent to the site. This is a significant advantage, as it greatly reduces the risk of encountering state or federally listed threatened and endangered (T&E) species that could delay or halt development.

Brownfield/Superfund Status: The data indicates two superfund/brownfield sites within a two-mile radius, but not on the subject parcel itself. This presents both a risk and an opportunity.

• Risk: A Phase I Environmental Site Assessment (ESA) is required to determine if past industrial uses on or near the property have resulted in a Recognized Environmental Condition (REC), which could necessitate costly remediation.
• Opportunity: If the Phase I ESA determines the subject parcel itself qualifies as a brownfield site under IRA guidelines (due to the presence of a contaminant or controlled substance), the project could be eligible for the 10% ITC brownfield adder. This is a significant potential financial upside.

Pipeline Proximity: The absence of major gas transmission pipelines within a three-mile radius is a positive finding, eliminating risks associated with pipeline-related safety setbacks, explosion hazards, and easement conflicts.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The site's strongest attribute is its proximity to grid infrastructure. Substation TAP139731 is only 0.3 miles away and has a maximum voltage of 69 kV. This sub-transmission voltage is suitable for a utility-scale project. A