⚡ 161-163 CLINTON RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for "Project Sterling" (161-163 Clinton Rd, Sterling, MA)

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) project on the 2.61-acre parcel located at 161-163 Clinton Rd, Sterling, MA (APN: 69_7). The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Clinton Road (MA-62), a paved, two-lane state-maintained road. Based on satellite imagery review, access appears to be excellent for both construction and operational phases. The road seems capable of handling heavy truck traffic typical for BESS component delivery.

Terrain & Equipment Access: The parcel appears to be relatively flat and cleared, consistent with its industrial zoning. This is highly advantageous, as it will likely minimize civil engineering and site preparation costs. The flat topography and direct road access strongly suggest that heavy equipment, including mobile cranes, transformers, and containerized BESS units, can be delivered and maneuvered on-site without significant issue. A formal topographical survey is required for confirmation.

Easement Concerns: As the property fronts a public road, a dedicated access easement is not anticipated to be necessary. However, a title search is required to identify any existing utility easements (e.g., for gas, water, or existing electrical lines) that may cross the property and constrain the buildable area. The proximity to high-voltage transmission lines increases the likelihood of such easements being present.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap and a potential fatal flaw. Immediate verification using the FEMA Flood Map Service Center is required. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs would increase substantially due to the need for elevated foundations, and permitting could become infeasible.

Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), typically requiring a 100-foot buffer from delineated wetland boundaries. Given the site's location, a desktop screening using the National Wetlands Inventory (NWI) is the immediate next step, to be followed by a formal field delineation by a certified professional if any risk is identified. The presence of significant wetlands could severely restrict the 2.61-acre parcel's buildable area.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a significant positive, de-risking the project from a wildlife permitting perspective. A final check with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is recommended as part of formal diligence.

Brownfield/Superfund Status: While there are no known superfund sites on the parcel, the presence of one within a two-mile radius and the site's "Heavy Industrial" zoning history suggest a moderate risk of on-site contamination. This presents both a risk and an opportunity. Risk: Potential for costly remediation. Opportunity: If the site can be officially classified as a brownfield, the project could qualify for the 10% Brownfield ITC Adder under the Inflation Reduction Act