⚡ 10 MILLBURY ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 10 Millbury St, Auburn, MA (APN: 41_11)

This report provides a comprehensive due diligence analysis for the property located at 10 Millbury Street in Auburn, Massachusetts. The site presents a compelling opportunity due to its exceptional grid proximity and favorable industrial zoning. However, significant risks related to environmental unknowns, regulatory uncertainty, and limited buildable area must be addressed before committing further capital. The following sections detail the findings of this initial evaluation.

1. Site Access & Topography

Road Access & Feasibility: The site has direct frontage on Millbury Street (Route 12), a major state-numbered highway. Preliminary review via satellite imagery confirms this is a multi-lane, paved road suitable for heavy commercial traffic. Access appears to be excellent for the delivery of oversized and overweight equipment, including battery containers, medium-voltage transformers, and construction machinery. The property's location just off Interstate 290 further enhances logistical feasibility for equipment transport from major ports or manufacturing hubs.

Terrain & Site Conditions: Located in an established industrial corridor, the parcel appears to be previously developed and graded relatively flat. This is a significant advantage, as it will likely minimize civil engineering and site preparation costs. The current land use appears to be an industrial storage yard, suggesting the ground is compacted and may already have a gravel or paved surface, which is ideal for a BESS facility.

Heavy Equipment Access: Given the direct access from a state highway and the likely flat topography, there are no immediate red flags concerning access for heavy equipment like a 100-ton crane (for transformer setting) or flatbed trucks carrying 40-foot battery enclosures. A detailed route survey would be required to confirm bridge weight limits and the absence of low-hanging overhead obstructions, but this is considered a low-risk item.

Easement Concerns: As the property has direct road frontage, a primary access easement is not anticipated to be a concern. However, a full title report is required to identify any potential utility easements (for existing power, water, or sewer lines) that could cross the property and constrain the final site layout.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs could increase substantially due to requirements for elevating all critical equipment above the Base Flood Elevation (BFE). This would necessitate raised concrete pads or steel structures, impacting project economics. Immediate verification using the FEMA Map Service Center is a top priority.

Wetlands: The presence of wetlands is Unknown. Given the site's proximity to the Blackstone River, there is a moderate risk of jurisdictional wetlands or buffer zones impacting the parcel. Massachusetts has stringent wetland protection regulations. The presence of wetlands could significantly reduce the 2.31-acre parcel's buildable area, potentially rendering it unsuitable for a 5MW project. A desktop screening followed by a formal wetland delineation by a certified professional is a critical next step.

Critical Habitat / Endangered Species: The data indicates no known critical habitat or protected areas on site, which is a significant positive. This should be verified with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database, but the risk is considered low due to the site's developed, industrial nature.

Brownfield/Superfund Status: The presence of three brownfield/superfund sites within a two-mile radius, combined with the site's industrial zoning and history, suggests a moderate potential for on-site contamination. This presents both a risk and an opportunity.

• Risk: Potential for soil or groundwater contamination could lead to costly remediation requirements and project delays. A Phase I Environmental Site Assessment (ESA) is mandatory.
• Opportunity: If the site qualifies as a "brownfield site" under federal guidelines, the project could be eligible for the 10% IRA brownfield tax credit adder, significantly improving project returns.

Pipeline Proximity: No major gas transmission pipelines are identified within a 3-mile radius. This is a major safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid access is its strongest attribute. The PONDVILLE 69kV substation is located only 0.5 miles away. This proximity is exceptional and dramatically reduces the cost and complexity of interconnection. A 115kV transmission line is also nearby (0.6 miles), providing future optionality, though it is not relevant for an initial distribution-scale project.

Recommended Interconnection: For a ≤5MW BESS, the clear and most cost-effective path is a distribution-level interconnection. This would involve tapping into a 3-phase distribution feeder originating from the Pondville substation. Visual inspection confirms the presence of 3-phase overhead lines running along Millbury Street, which is the likely Point of Interconnection (POI).