⚡ HILL RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – HILL RD, Charlton, MA (APN: 31-D-5.1)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project on an 11.99-acre parcel located on Hill Road in Charlton, Worcester County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives. While the site possesses exceptional proximity to robust grid infrastructure, it is encumbered by significant zoning, environmental, and financial challenges that present substantial development risks.

1. Site Access & Topography

• Road Access & Equipment Delivery: The subject property has frontage on Hill Road, which appears to be a two-lane, paved local road based on aerial imagery. This type of road is generally sufficient for the delivery of construction materials, battery containers, and switchgear. However, a detailed route survey is required to confirm the absence of any low-clearance bridges, sharp turns, or weight-limited infrastructure between major highways (like I-90 or I-84) and the site. The quality of the road surface and shoulder must be verified on-site.
• Terrain Characteristics: As is typical for central Massachusetts, satellite imagery shows the parcel is heavily wooded. The topography appears to be gently rolling to moderately sloped. Significant tree clearing, grubbing, and grading will be required to create a level pad for the BESS equipment, which will add considerable cost and time to the site preparation phase. A topographical survey is essential to quantify the required earthwork.
• Heavy Equipment Feasibility: Access for heavy equipment, including cranes for setting transformers and inverters, appears feasible from Hill Road. The primary challenge will be constructing a stable, all-weather access drive from the public road onto the project site itself, which will require cutting into the existing terrain.
• Easement Concerns: The Point of Interconnection (POI) is approximately 0.5 miles from the parcel. This will necessitate a new gen-tie line. Securing right-of-way (ROW) easements from multiple intervening landowners will be a critical and potentially project-killing task. These parcels appear to be residential, and landowners may be resistant to granting easements, likely requiring significant financial compensation and legal effort. This is a major project risk.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. A review of FEMA Flood Insurance Rate Maps (FIRMs) is an immediate next step. Any designation other than Zone X (minimal flood hazard) would likely require significant civil engineering (e.g., raising the equipment pad) or could render the site undevelopable.
• Wetlands Presence: The presence of wetlands is Unknown. Given the wooded, undeveloped nature of the site in this region, there is a high probability of state- and federally-jurisdictional wetlands and/or vernal pools. The Massachusetts Wetlands Protection Act imposes stringent regulations, often including a 100-foot buffer zone around delineated resources where development is heavily restricted. A formal wetland delineation is mandatory and could severely constrain the buildable area.
• Critical Habitat / Endangered Species: The provided data indicates no critical habitat on site. However, this must be verified through the US Fish & Wildlife Service's IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to screen for state-listed species. While the initial outlook is positive, a formal finding is required.
• Brownfield/Superfund Status: The site has no known brownfield or superfund sites within a 2-mile radius. This is positive from a liability and cleanup-cost perspective, but it means the project is not eligible for the 10% IRA Brownfield ITC adder, which is a commercial disadvantage.
• Pipeline Proximity: No major gas pipelines are located within 3 miles. This is a significant safety and siting advantage, eliminating a common and complex constraint for BESS projects.

3. Grid Infrastructure & Interconnection

• Nearest Substation & Capacity: The site is located just 0.5 miles from substation TAP140738, a 115 kV asset. This proximity is excellent and is the site's single greatest strength. The interconnecting utility is likely National Grid for distribution service. While the substation's available capacity is unknown, its 115 kV class suggests it is a bulk power facility with a higher likelihood of having capacity compared to a smaller distribution-only substation.
• Transmission Line Proximity: A 345 kV transmission line owned by Fitchburg Gas and Electric (Unitil) is also located 0.5 miles away. This provides a second, albeit much more complex and expensive, interconnection option if the 115 kV substation is not viable.
• Recommended Interconnection Voltage: For a distribution-scale project (≤5MW), the standard approach would be to interconnect to a local distribution feeder (e.g., 13.2 kV). However, given the lack of visible distribution lines directly adjacent to the site and the proximity of the 115 kV substation, a direct 115 kV transmission-level