⚡ HARRINGTON RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for HARRINGTON RD, Charlton, MA (APN: 64-C-5.8)

This report provides a comprehensive due diligence analysis for a potential distribution or utility-scale Battery Energy Storage System (BESS) project at the subject property on Harrington Road in Charlton, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including physical characteristics, grid access, environmental and regulatory constraints, and financial incentives.

1. Site Access & Topography

Road Access: The property is located on Harrington Road, which appears to be a local, two-lane paved road based on satellite imagery. The quality seems sufficient for standard construction traffic. However, a detailed route survey is required to confirm its suitability for oversized and overweight vehicles, such as a lowboy trailer carrying a main power transformer (often exceeding 90,000 lbs) or a 53-foot containerized BESS unit. We must verify bridge weight limits, turning radii at intersections between the site and major state highways, and the absence of low-hanging utility lines.

Terrain & Equipment Access: Located in Worcester County, the site is expected to have rolling terrain and potentially rocky, glacial till soil, which is common in central Massachusetts. This could increase civil work costs for grading and foundation construction. A formal topographical survey is a critical next step. Direct access from Harrington Road to a suitable pad-ready location on the parcel appears feasible, but there is a notable discrepancy in listed acreage (4.63 vs. 2.34 acres) that must be resolved via a survey to confirm sufficient space.

Easement Concerns: Requires Verification. It is currently unknown if the property has direct, sufficient frontage on Harrington Road or if an access easement across an adjacent parcel would be required. The parcel configuration must be confirmed via a title search and survey to ensure legal, insurable access is available for construction and long-term operations and maintenance.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown and represents a significant risk. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development could be prohibited or require costly mitigation, such as elevating all equipment above the Base Flood Elevation, severely impacting project economics. This must be determined immediately via the FEMA Map Service Center.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Massachusetts has highly restrictive wetland regulations under the Wetlands Protection Act, which mandates a 100-foot buffer zone from wetland resource areas where activity is limited. The presence of wetlands could drastically reduce the buildable acreage. A wetland delineation by a certified professional is a mandatory, high-priority due diligence item.

Habitat & Protected Species: Initial data indicates no critical habitats or protected areas on site, which is a positive finding. However, a Phase I Environmental Site Assessment (ESA) is necessary to confirm this and screen for any state-listed species of concern that could trigger further consultation with the Massachusetts Natural Heritage & Endangered Species Program (NHESP).

Brownfield/Superfund Status: The property itself is not listed as a brownfield. The presence of three superfund/brownfield sites within a two-mile radius is a potential risk, suggesting possible area-wide contamination. This increases the importance of a Phase I ESA to identify any Recognized Environmental Conditions (RECs) on our parcel. Currently, the site does not qualify for the 10% IRA brownfield tax credit adder; this status is a risk, not an advantage.

Other Constraints: The site is not within the Chesapeake Bay Critical Area (N/A for MA). No pipelines or gas wells are in the immediate vicinity, reducing safety and setback concerns.

3. Grid Infrastructure & Interconnection

Proximity to Infrastructure: The site's primary strength is its exceptional proximity to high-voltage grid infrastructure. It is located just 0.6 miles from the Millennium Power 115 kV substation and 0.4 miles from a 115 kV transmission line owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary). This proximity significantly de-risks the feasibility of interconnection.

Interconnection Recommendation: For a project of 5 MW, a transmission-level interconnection at 115 kV is the most probable pathway. This would involve a new tap on the existing transmission line and a short radial line to a new project-owned substation. While a distribution-level interconnection (e.g., 13.8 kV) with the local utility (likely National Grid) might be technically possible, finding a feeder with sufficient capacity and 3-phase power this close to a major transmission hub is unlikely. The transmission path is more direct and certain.