⚡ 206 E MAIN ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Milford"

PROPERTY: 206 E MAIN ST, Milford, Worcester County, MA (APN: 32-0-14B)

RECOMMENDATION: MAYBE

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) on a 3.5-10.6 acre parcel in Milford, MA. The site possesses exceptional grid infrastructure proximity, a significant advantage. However, this is counterbalanced by substantial risks related to local zoning regulations and a complete lack of eligibility for federal IRA/ITC incentive adders, which severely impacts project economics. The following detailed analysis outlines these factors and recommends a cautious, phased approach to further diligence.

1. Site Access & Topography

• Road Access & Feasibility: The property has direct frontage on East Main Street (Massachusetts Route 16), a major local thoroughfare. Access appears to be excellent for all phases of development, from initial surveying to final commissioning. The existing road infrastructure is well-maintained and capable of supporting heavy haul trucks required for delivering large equipment.
• Terrain Characteristics: Based on aerial imagery and regional topography, the site is relatively flat, particularly the portion fronting the road which is already partially developed with a commercial building and parking lot. This is highly favorable, as it will minimize grading costs and simplify civil engineering design. The rear of the parcel appears to be undeveloped and wooded, with potentially more varied but generally gentle terrain.
• Heavy Equipment Access: Access for critical heavy equipment, including mobile cranes, multi-axle transport for transformers, and delivery of containerized BESS units, is deemed highly feasible. The direct access from MA-16 eliminates concerns about navigating narrow residential or rural roads.
• Easement Concerns: As the parcel has direct public road frontage, a primary access easement is not required. However, an ALTA survey is necessary to confirm the absence of any internal utility or access easements that could encumber the prime development area. The significant discrepancy in listed acreage (10.64 vs. 3.48 acres from Regrid) must be resolved via a survey to understand the true parcel configuration.

2. Environmental Constraints

• FEMA Flood Zone: A preliminary review of FEMA Flood Insurance Rate Maps (FIRM) indicates the parcel is located in Zone X. This is an area of minimal flood hazard, which is a significant advantage. It eliminates the need for costly flood mitigation measures, such as elevating equipment, and simplifies permitting.
• Wetlands: Requires Verification. The provided data is unknown, but a preliminary screen of the USFWS National Wetlands Inventory map suggests the potential presence of freshwater forested/shrub wetlands toward the western (rear) portion of the parcel. This is a material risk. Massachusetts has stringent wetland protection laws, often requiring a 100-foot buffer ("No-Disturb Zone"). A formal wetlands delineation is a critical next step to determine the precise boundaries and calculate the net buildable area, which may be substantially smaller than the gross acreage.
• Critical Habitat / Endangered Species: The data indicates no known critical habitat on site. This is a positive finding, reducing the risk of project delays or costly mitigation requirements from federal (Endangered Species Act) or state agencies. A formal desktop screening (e.g., USFWS IPaC report) is still recommended for formal documentation.
• Brownfield/Superfund Status: The site is not a listed brownfield or superfund site. While this means the project is ineligible for the 10% IRA brownfield tax credit adder, it is a net positive as it avoids potential environmental liability and costly soil remediation efforts.
• Pipeline Proximity: No major gas transmission pipelines are located in the immediate vicinity, mitigating risks related to pipeline safety setbacks, explosion hazards, and coordination with pipeline operators.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The ROCKY HILL substation is located only 0.6 miles from the site. Its maximum voltage of 115 kV indicates it is a robust transmission-level substation, suggesting significant capacity may be available for a new BESS project. This proximity is excellent and dramatically reduces the potential cost of a gen-tie line.
• Transmission Line Proximity: A 115 kV transmission line owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary) is located a mere 0.1 miles from the parcel boundary. This is an outstanding feature and presents the most logical Point of Interconnection (POI).
• Recommended Interconnection Voltage: A 115 kV transmission-level interconnection