⚡ 94 ASHLAND AVE

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 94 Ashland Ave, Southbridge, MA (APN: 057_004_00001)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 94 Ashland Ave, Southbridge, MA. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

The subject property is a 3.94-acre parcel located directly on Ashland Avenue, a two-lane, paved public road. Based on aerial and street-level imagery, access appears to be excellent. The road is straight and appears sufficiently wide to accommodate lowboy trailers for delivering large equipment such as battery containers, inverters, and the main power transformer. The site has direct frontage, allowing for the construction of a wide construction entrance without significant issue. The terrain of the parcel itself appears to be predominantly flat and cleared, which is ideal for minimizing civil engineering and earthwork costs. The prior use appears to be industrial or commercial, suggesting the ground is likely compacted and stable. However, a formal geotechnical study is required to confirm soil bearing capacity and rule out subsurface issues. No obvious access easement concerns are present for entering the site from the public right-of-way, but a title search is necessary to identify any utility or other easements crossing the property itself that could constrain the BESS layout.

2. Environmental Constraints

The environmental profile of this site presents both opportunities and risks that require immediate investigation.

• FEMA Flood Zone: A preliminary check of the FEMA Flood Map Service Center indicates the property is located in Zone X, an area of minimal flood hazard. This is a significant advantage, as it avoids costly mitigation measures like building up the equipment pad or constructing floodwalls.
• Wetlands: The provided data is "Unknown." A review of the US Fish & Wildlife Service National Wetlands Inventory mapper suggests the parcel itself is free of mapped wetlands, though riverine wetlands associated with the Quinebaug River are present to the south. A formal wetland delineation by a certified professional is a critical next step to confirm the absence of jurisdictional wetlands and determine any required setbacks.
• Critical Habitat / Species: The data indicates no critical habitat or protected areas on site, which is favorable. This should be confirmed during a Phase I Environmental Site Assessment (ESA).
• Brownfield/Superfund Status: The presence of three Superfund/brownfield sites within a two-mile radius is a notable concern. A Phase I ESA is mandatory to determine if there is any risk of migrating contamination onto our subject parcel. Conversely, this proximity raises the possibility that our site itself could qualify as a "brownfield site" under federal definitions. If so, this would make the project eligible for the 10% Brownfield ITC Adder under the Inflation Reduction Act (IRA), a potentially significant economic benefit. This dual nature of risk and opportunity must be a top diligence priority.
• Pipeline Proximity: No high-pressure gas pipelines are located in the immediate vicinity, mitigating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents the single greatest risk to this project's viability. The data indicates the nearest substation is 1.6 miles away with a voltage of 115 kV. Interconnecting a small (≤5MW) distribution-scale project at transmission voltage (115 kV) is almost always cost-prohibitive due to the high cost of protection and substation equipment. Furthermore, a 1.6-mile line extension at any voltage would likely exceed $3-5 million, rendering the project uneconomical.

However, street-level imagery clearly shows three-phase distribution lines running along the site's frontage on Ashland Avenue. The project's survival is entirely dependent on the viability of interconnecting to this local distribution feeder.

• Likely Interconnecting Utility: National Grid.
• Recommended Interconnection Voltage: Distribution-level, likely 13.2 kV. This requires immediate verification.
• Feeder Configuration: Requires Verification. The feeder's capacity, current loading, and protection scheme must be determined via a pre-application report with National Grid.
• Estimated Cost & Timeline: If a viable distribution feeder with sufficient capacity is available at the road, interconnection costs could be in the $750,000 to $2,000,000 range. If not, the project is not feasible. The National Grid interconnection queue in Massachusetts is notoriously congested, and a timeline of 24-36 months from application to commercial operation should be anticipated.

4. Regulatory & Zoning Analysis

The regulatory pathway appears manageable but requires careful navigation.

• Authority Having Jurisdiction (AHJ): Town of Southbridge.
• Zoning: The parcel is zoned OR (Office/Research District), not "Industrial (General)" as initially listed. This is a critical distinction.
* Permitting Pathway: A review of