⚡ 111 CEDAR ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 111 Cedar St, Milford, MA (APN: 19-0-6C)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 111 Cedar Street in Milford, Worcester County, Massachusetts. The 2.95-acre parcel presents a compelling, yet complex, development opportunity. The primary asset is the immediate proximity to high-voltage transmission infrastructure, a critical and often costly component of BESS development. However, this significant advantage is offset by a complete lack of eligibility for IRA tax credit adders and several critical unknowns regarding environmental constraints and buildability. The following analysis details these factors to inform a go/no-go decision.

1. Site Access & Topography

Road Access: The property has direct frontage on Cedar Street, which is also Massachusetts Route 85. This is a major, well-maintained state road providing excellent and straightforward access for all phases of development, from initial surveying to final equipment delivery. It connects directly to major regional highways, including I-495, which is less than a mile away.

Equipment Delivery: Access via Route 85 is more than sufficient for heavy-haul trucks carrying large equipment such as transformers, switchgear, and containerized battery systems. The entrance to the existing office park on the parcel appears wide enough to accommodate this traffic, though minor temporary modifications might be necessary.

Terrain & Topography: Based on aerial imagery, the front portion of the parcel is developed with an office building and a large, paved parking lot, indicating a flat, graded, and stable surface ideal for construction staging and potentially siting the BESS array. The rear (eastern) portion of the parcel appears undeveloped, wooded, and may have a gentle slope. A formal topographical survey is required to confirm gradients and determine the extent of earthwork needed if the BESS is sited in this rear section.

Easement Concerns: As the on-site transmission line is a primary asset, securing access rights for the utility (Fitchburg Gas and Electric Light Company / Unitil) will be a standard part of the interconnection agreement. No immediate third-party access easement concerns are apparent for the parcel itself, as access is direct from a public right-of-way. Internal site circulation will need to be planned to not interfere with the existing office park tenants.

2. Environmental Constraints

This section contains significant data gaps that represent a primary risk to the project.

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. Any designation within a 100-year or 500-year floodplain (e.g., Zone A, AE) would introduce significant design challenges and costs, potentially requiring the entire BESS facility to be built on an elevated platform. If a significant portion of the buildable area is in a floodway, it could render the site undevelopable. This is a critical, potentially fatal flaw that must be investigated immediately.
• Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) which include significant buffer zones (typically 100 feet) where development is heavily restricted. Given the undeveloped, wooded area on the parcel, there is a moderate to high risk of wetlands being present. A desktop screening using MassGIS OLIVER is the immediate next step, to be followed by a formal wetland delineation by a certified professional if the project moves forward.
• Critical Habitat / Species Risk: The provided data indicates no critical habitat or protected areas on site, which is a significant positive. This lowers the risk of encountering endangered species issues that could delay or halt a project. A desktop review of the MA Natural Heritage & Endangered Species Program (NHESP) database is still recommended as a final check.
• Brownfield/Superfund Status: The site is not a brownfield, which means it is not eligible for the 10% IRA Brownfield Adder. While this is a missed financial opportunity, it is also a positive from a risk perspective, as it avoids potential environmental liability and costly remediation efforts associated with contaminated sites.
• Pipeline Proximity: No major gas transmission pipelines are located in the immediate vicinity, mitigating risks associated with pipeline-related safety setbacks and potential co-location conflicts.

3. Grid Infrastructure & Interconnection

The grid infrastructure is this site's premier asset.

• Substation & Transmission: A 115kV transmission line owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary) is located directly on the property (0.0 miles distance). The nearest substation, ROCKY HILL, is 1.3 miles away and operates at the same 115kV voltage, strongly suggesting the on-site line is a direct path to this substation. This co-location eliminates the need for a costly and time-consuming line extension.
• Interconnection Voltage Recommendation: For a ≤5MW BESS, a distribution-level interconnection (e.g., 13.8kV) is typical. There is likely a 3-phase distribution feeder running along Cedar Street that could be evaluated. However, the presence of the on-site 115kV line presents a unique opportunity. A transmission-level interconnection at 115kV would