⚡ FISHER RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for FISHER RD, Fitchburg, MA (APN: 097 S11-4-A)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 2.97-acre parcel located on Fisher Road in Fitchburg, Worcester County, Massachusetts. The analysis identifies several significant, potentially fatal flaws related to grid access, zoning, and site buildability. The overall recommendation is NO GO pending extraordinary positive outcomes from initial, low-cost diligence steps.

1. Site Access & Topography

Evaluation: The subject property presents substantial access and buildability challenges. Initial desktop analysis indicates the parcel is likely a "flag lot" or rear lot with limited or no direct frontage on Fisher Road, which itself is a local, relatively narrow residential street.

• Road Access Quality: Fisher Road appears to be a paved, two-lane residential road. Its suitability for oversized and overweight loads, such as a main power transformer on a low-boy trailer or 40-foot battery containers, is highly questionable. A formal route survey would be required to assess turning radii, bridge weight limits, and overhead line clearances.
• Terrain Characteristics: The site is located in Worcester County, an area known for rolling hills and rocky terrain. The parcel appears to be undeveloped, heavily wooded, and likely possesses significant slope. This will necessitate extensive tree clearing, grubbing, and civil work (grading, retaining walls), substantially increasing site development costs.
• Heavy Equipment Feasibility: Access for construction equipment is a primary risk. If legal access is only available via a narrow easement across a neighboring residential property, it may be physically impossible to maneuver cranes, drill rigs, and delivery trucks onto the site. This is a critical constructability risk.
• Easement Concerns: This is a potential fatal flaw. A title search and ALTA survey are immediately required to confirm the existence, width, and legal standing of any access easement. Without a clearly defined, legally defensible, and physically viable access route, the project cannot proceed. Securing a new easement from an unwilling neighbor is often impossible or prohibitively expensive.

2. Environmental Constraints

Evaluation: The site carries a medium-to-high environmental risk profile due to numerous unknowns and concerning proximity data. A Phase I Environmental Site Assessment (ESA) is mandatory.

• FEMA Flood Zone: The flood zone designation is unknown. This is a critical data gap. Any portion of the buildable area falling within a 100-year floodplain (Zone A or AE) would require significant mitigation (e.g., elevating all equipment pads above the Base Flood Elevation) or could render the site unusable.
• Wetlands: The presence of wetlands is unknown. Given the New England landscape, wetlands are highly probable. A National Wetlands Inventory (NWI) screening must be performed, followed by a formal field delineation if potential wetlands are identified. Massachusetts has stringent wetland protection laws, and required setbacks would significantly constrain the usable area on this small 2.97-acre parcel.
• Critical Habitat: No critical habitats are indicated in the initial data, which is a positive. However, this should be verified via the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species are present.
• Brownfield/Superfund Status: The presence of 43 brownfield or superfund sites within a two-mile radius is alarming. While this does not mean the subject parcel is contaminated, it indicates a high potential for area-wide soil or groundwater issues. A Phase I ESA is critical to assess this risk. This could also be a strategic opportunity: if the site itself is determined to be a brownfield, the project could qualify for the 10% IRA Brownfield tax credit adder. However, the risk of cleanup liability and cost likely outweighs the potential incentive benefit.
• Pipeline Proximity: No major pipelines nearby is a positive, eliminating a common safety and setback constraint.

3. Grid Infrastructure & Interconnection

Evaluation: The grid infrastructure is poorly suited for a cost-effective BESS project. The interconnection distance is the most significant challenge and represents a likely fatal flaw.

• Nearest Substation: The nearest identified point of interconnection (POI) is an unknown substation 1.9 miles away. The provided voltage data is erroneous. The utility for this area is likely National Grid. A 1.9-mile distribution line extension is financially crippling for a ≤5MW project.
• Transmission Access: The nearest transmission line (115kV) is 4.2 miles away, making it economically and technically infeasible for a project of this scale. Interconnection must be to the distribution system.
• Recommended Interconnection: The project would