⚡ 177 FLORENCE ST

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 177 FLORENCE ST, Leominster, MA (APN: 153 349_6)

1. Site Access & Topography

The subject property at 177 Florence Street in Leominster, MA, presents favorable characteristics for site access and buildability. Preliminary analysis using satellite imagery indicates the site has direct frontage on Florence Street, a paved, two-lane municipal road. This road appears to be in good condition and is situated within an established industrial park, suggesting it is built to a standard capable of handling heavy truck traffic. The primary concern for equipment delivery will be confirming turning radii from public roads onto the site entrance and ensuring there are no low-hanging utility lines or restrictive weight limits on Florence Street or its access routes. Given the existing industrial use on the parcel (a large warehouse/manufacturing-style building and associated parking), access for heavy equipment such as cranes, transformers, and battery containers is anticipated to be feasible with minimal modification. The terrain of the 4.62-acre parcel appears to be predominantly flat and previously graded, which will significantly reduce civil engineering costs and construction timelines. No obvious topographical challenges like steep slopes or significant rock outcroppings are visible. A formal title search is required to confirm that no restrictive access easements or rights-of-way encumber the property, but direct road frontage makes this a low-probability risk.

2. Environmental Constraints

Environmental due diligence presents the most significant uncertainty for this site. Key areas require immediate investigation:

• FEMA Flood Zone: The flood zone designation is currently unknown. This is a critical data gap. A preliminary desktop review suggests the property is in Zone X (area of minimal flood hazard), but this Requires Verification via a formal Flood Hazard Determination. If any portion of the buildable area is within a Special Flood Hazard Area (e.g., Zone A or AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding significant cost and complexity.
• Wetlands: Wetlands presence is also unknown. The Massachusetts Wetlands Protection Act imposes stringent regulations, including 100-foot buffer zones. While the site appears developed, its proximity to the Nashua River (~0.5 miles east) increases the risk. A formal wetland delineation by a certified professional is a mandatory next step to determine the net buildable acreage.
• Brownfield/Superfund Status: The data indicates five brownfield or superfund sites within a two-mile radius. While the subject parcel is not listed, its location in a historically industrial area raises the risk of on-site contamination from prior uses. This is a dual-edged sword: it represents a risk that could require costly remediation, but it also presents a major opportunity. If the site can be officially classified as a "brownfield site" under CERCLA, it would qualify for the 10% Energy Community ITC adder, a significant financial benefit. A Phase I Environmental Site Assessment (ESA) is non-negotiable.
• Other Constraints: The site is clear of critical habitats, protected areas, and nearby pipelines, which are significant positives that de-risk the project from a wildlife and public safety perspective. The project is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

The grid infrastructure near this site is a primary driver of its potential value. The LITCHFIELD STREET substation is located only 0.5 miles from the property boundary. This proximity is excellent and dramatically reduces the cost and complexity of the generator lead line. The substation's maximum voltage of 69 kV suggests it is a robust node on the grid. For a distribution-scale project (≤5MW), the most likely and cost-effective Point of Interconnection (POI) would be a 3-phase distribution feeder (e.g., 13.8 kV) originating from this substation. A direct 69 kV interconnection would be prohibitively expensive for a project of this scale.

The interconnecting utility Requires Verification but is likely National Grid, which serves the Leominster area. The interconnection process in Massachusetts is governed by the DPU and managed through the utility, feeding into the broader ISO-New England (ISO-NE) system. Queue