⚡ BARRE PAXTON RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for APN 12_A_5.02, Barre Paxton Rd, Rutland, MA

This report provides a comprehensive due diligence analysis for a prospective 4.4-acre site in Rutland, Worcester County, Massachusetts for the development of a distribution or utility-scale Battery Energy Storage System (BESS). The analysis covers critical site attributes, constraints, and opportunities to inform a final investment decision.

1. Site Access & Topography

Road Access: The property has frontage on Barre Paxton Road, a two-lane, paved county road. Based on satellite imagery review, the road appears to be in good condition and capable of supporting heavy truck traffic, including flatbeds for battery containers and heavy-haul trucks for the main power transformer.

Topography & Site Preparation: The site is currently undeveloped and appears to be heavily wooded. The general topography of Worcester County is characterized by rolling hills. It is highly likely the parcel has moderate slopes, which will require significant clearing, grubbing, and grading to create a level pad for the BESS equipment. This will increase site preparation costs compared to a flat, clear parcel.

Equipment Access: Direct access from Barre Paxton Road onto the site is feasible. However, a new crushed-stone or paved access road, approximately 100-300 feet long, will need to be constructed from the main road to the project pad. A culvert may be required if a drainage ditch runs parallel to the road.

Easements: Requires Verification. A standard access easement will need to be secured as part of the land acquisition or lease agreement. A preliminary title report is required to identify any existing utility or access easements that may encumber the property and conflict with the proposed layout.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently listed as "Unknown." This represents a critical data gap and a potential fatal flaw. A desktop review using the FEMA Flood Map Service Center is an immediate next step. If any portion of the buildable area is within a Special Flood Hazard Area (e.g., Zone A, AE), development costs will rise substantially due to requirements for elevating equipment, or development may be prohibited entirely if located in a floodway.

Wetlands: The presence of wetlands is "Unknown." This is another major risk. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act (WPA). Development is typically prohibited within wetlands, and a 100-foot buffer zone ("Riverfront Area") is often enforced. Given the wooded and undeveloped nature of the site, the probability of wetlands or vernal pools being present is moderate to high. A formal wetlands delineation by a certified professional is essential.

Critical Habitat / Species: The data indicates no critical habitats on site, which is a significant advantage, reducing the risk of lengthy and complex consultations under the Endangered Species Act. This should be confirmed via the MassGIS Natural Heritage & Endangered Species Program (NHESP) database.

Brownfield/Superfund Status: The site is not a brownfield, which means it does not qualify for the 10% IRA Brownfield ITC adder. However, this is also a positive, as it indicates a clean site with no legacy contamination issues, avoiding potential remediation costs and liabilities.

Pipeline Proximity: No gas pipelines are located within three miles. This eliminates a significant safety, permitting, and setback constraint common to many sites.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation is National Grid’s PAXTON substation, located 1.5 miles away with a maximum voltage of 115 kV. The likely Point of Interconnection (POI) would be a tap on the 115kV transmission line running 1.2 miles from the site. This distance is substantial and presents a major cost challenge.

Interconnection Voltage & Cost: A 115 kV transmission-level interconnection is the most probable path. A 1.2-mile overhead gen-tie at this voltage is a major capital expense, likely in the $1.5M - $3.0M range, excluding any required upgrades at the PAXTON substation. This cost could make a ≤5MW project economically un