⚡ 273 WASHINGTON ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 273 WASHINGTON ST, AUBURN, MA

This report provides a comprehensive due diligence analysis for the property located at 273 Washington Street in Auburn, Worcester County, Massachusetts (APN: 42_41). The 2.03-acre parcel presents a compelling redevelopment opportunity due to its exceptional grid proximity and favorable industrial zoning. However, significant risks related to environmental constraints, buildable area, and a lack of federal incentives require careful consideration and mitigation.

1. Site Access & Topography

Road Access: The site exhibits excellent road access, with direct frontage on Washington Street (U.S. Route 20), a major four-lane divided highway. This provides multiple points of ingress/egress and can easily accommodate heavy truck traffic for equipment delivery.

Equipment Delivery: The high-quality road infrastructure is fully capable of supporting the delivery of all necessary BESS components, including oversized loads like transformers, switchgear, and 53-foot battery containers. A preliminary review of satellite imagery shows no immediate overhead line or bridge clearance issues along the primary access route.

Terrain & Topography: The parcel is located in a developed commercial/industrial corridor and appears to be graded and relatively flat. An existing industrial building currently occupies a significant portion of the site. The flat topography is highly advantageous, minimizing the need for extensive civil work and associated costs.

Easement Concerns: Access to the site itself is unencumbered. However, an access easement for the generator tie-in line (gen-tie) will be required to reach the target substation (0.4 miles away) or transmission line (0.5 miles away). This will likely involve crossing U.S. Route 20 and potentially other commercial properties. Securing these easements represents a potential cost and timeline risk that must be investigated.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown and represents a critical data gap. Any designation within a Special Flood Hazard Area (e.g., Zone A, AE) would impose significant design constraints, requiring elevated foundations for all equipment, and could potentially render the site economically unviable. This must be a top priority for desktop analysis.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). Given the small parcel size (2.03 acres), the presence of any jurisdictional wetlands could severely restrict the buildable area and make a 5MW BESS layout impossible. A desktop screening using MassGIS OLIVER followed by a formal wetland delineation is essential.

Critical Habitat / Endangered Species: The initial screen indicates no critical habitat or protected areas on or immediately adjacent to the site, which is a positive finding. A formal review using the USFWS IPaC tool should be conducted to confirm.

Brownfield/Superfund Status: The property is not a listed Superfund site, but two listed sites are within a two-mile radius. More importantly, the site's current use as an industrial/warehouse facility suggests a history that could qualify it as a "brownfield" under IRA guidelines. This presents both a risk (potential for on-site contamination requiring remediation) and a significant opportunity (eligibility for the 10% ITC Brownfield Adder). A Phase I Environmental Site Assessment (ESA) is mandatory to assess contamination risk and determine eligibility for the tax credit.

Pipeline Proximity: No major gas transmission pipelines are located within a three-mile radius, mitigating risks associated with pipeline-related setbacks and safety protocols.