⚡ 196-R BRIGHAM HILL 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 110 044.0-0000-0029.D (196-R Brigham Hill Rd, Grafton, MA)

This report provides a comprehensive due diligence analysis for the subject 10-acre property in Grafton, Massachusetts, for its potential as a distribution-scale or utility-scale Battery Energy Storage System (BESS) project. The analysis concludes that while the site possesses strong grid proximity, it faces significant, potentially fatal flaws related to zoning, site access, environmental uncertainty, and a lack of financial incentives.

1. Site Access & Topography

The property's access presents a primary and immediate concern. The address "196-R" designates a rear lot, indicating it does not have direct frontage on Brigham Hill Road. Initial desktop review of satellite imagery confirms this is a landlocked, wooded parcel situated behind developed residential properties.

• Road Access Quality: Requires Verification. Access appears to be via a long, unimproved or gravel driveway that likely crosses at least one other privately-owned parcel. The quality, width, and legal status of this access are unknown and represent a major risk. A formal title search and survey are required to confirm the existence, terms, and physical suitability of a deeded access easement.
• Terrain Characteristics: The site is undeveloped timberland. Topography in this part of Worcester County is characterized by rolling hills. A detailed topographical survey will be necessary to determine grading requirements, which are expected to be moderate to significant given the forested nature of the site. Extensive tree clearing will be required.
• Heavy Equipment Feasibility: Access for heavy equipment is currently considered unfeasible without significant investment. The likely access route appears narrow and unpaved, unsuitable for lowboy trailers carrying multi-ton transformers or battery containers. The cost to construct an all-weather road capable of supporting this equipment, including any necessary culverts or grading, could be substantial.
• Easement Concerns: This is a critical risk. A formal, legally defensible, and insurable access and utility easement must be secured. The existing easement, if any, may not be sufficient for commercial industrial use and may need to be renegotiated with the servient estate owner(s), which can be costly and time-consuming, or altogether impossible.

2. Environmental Constraints

The environmental profile of the site is defined by major data gaps that represent significant potential project costs and schedule delays. Massachusetts has stringent environmental regulations, particularly concerning wetlands.

• FEMA Flood Zone: Requires Verification. The FEMA designation is unknown. Any presence of a Special Flood Hazard Area (e.g., Zone A, AE) would severely restrict development, requiring elevated foundations and potentially rendering large portions of the 10-acre site unusable for critical equipment.
• Wetlands: Requires Verification. The presence of wetlands is considered highly probable on a forested, undeveloped parcel in this region. Under the Massachusetts Wetlands Protection Act and local Grafton bylaws, significant setbacks (typically 100 feet or more) from any delineated wetland resource area would be required, which could dramatically reduce the buildable acreage. A formal wetland delineation by a certified professional is an essential and immediate next step.
• Critical Habitat / Endangered Species: The initial screening shows no critical habitat on site, which is a positive factor. However, a state-level review for any state-listed species will still be required during permitting.
• Brownfield/Superfund Status: The site is not a brownfield. While this indicates a lower risk of soil contamination, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable financial disadvantage.
• Pipeline Proximity: No major gas pipelines are located near the site, mitigating risks associated with pipeline-related safety setbacks and consultations.

3. Grid Infrastructure & Interconnection

The site's primary strength is its proximity to high-capacity grid infrastructure. This presents a clear opportunity for a utility-scale project, though at a significant cost.

• Nearest Substation: The WYMAN-GORDON substation is 1.0 mile away and operates at 115 kV. This is a transmission-level substation, likely with significant capacity, but a direct feeder run of this distance would be expensive.
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• Nearest Transmission Line: A 115 kV transmission line owned by Fitchburg Gas and Electric (now part of National Grid) is located approximately 0.7 miles from the parcel. This line represents the most logical Point of Interconnection (POI) for a utility-scale project (>5MW).
• Recommended Interconnection Voltage: 115 kV (Transmission). The most viable path for a project of scale is to tap the nearby 115 kV line. A distribution-level