⚡ ASHBURNHAM HILL RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Ashburnham Hill Rd, Fitchburg, MA (APN: 214-9-0)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a parcel located at Ashburnham Hill Road in Fitchburg, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Ashburnham Hill Road, which appears to be a two-lane, paved public road. This provides a strong baseline for access. However, the data provided does not specify the quality, weight limits, or presence of any low bridges on the likely transportation route. A physical site visit and route survey are required to confirm that the access route can support heavy haul trucks carrying multi-ton transformers and 40-foot battery containers.

Terrain & Equipment Access: The road name, "Ashburnham Hill," and the general topography of Worcester County suggest the site is likely situated on rolling or hilly terrain. This could necessitate significant civil work, including grading and soil stabilization, which would increase site preparation costs. The ability for heavy equipment to access the buildable area from the main road is a critical unknown. An existing curb cut or access drive is not confirmed. Creating a new access point will require a permit from the Fitchburg Department of Public Works and must be designed to accommodate the turning radii of lowboy trailers.

Easement Concerns: While the parcel appears to have direct road frontage, a title search is mandatory to identify any existing utility easements, right-of-ways, or access restrictions that could encumber the property and limit the buildable envelope. It is crucial to confirm that legal access is not dependent on an easement across an adjacent parcel.

2. Environmental Constraints

Flood & Wetlands: The FEMA flood zone and wetlands status are currently unknown. These are critical, potentially fatal-flaw risks. A desktop screening using FEMA's Map Service Center and the National Wetlands Inventory (NWI) must be conducted immediately. Given the site's potential topography, it may be near streams or low-lying areas prone to wetland formation. Massachusetts has a robust Wetlands Protection Act, and any jurisdictional wetlands would require significant setbacks (typically 100 feet or more), severely constraining the usable acreage.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be verified through the U.S. Fish and Wildlife Service's IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or sensitive habitats are present.

Brownfield/Superfund Status: The presence of 41 brownfield or superfund sites within a two-mile radius is a significant concern. This indicates a history of industrial activity in the area and elevates the risk that this specific parcel may have legacy contamination. A Phase I Environmental Site Assessment (ESA) is non-negotiable. Conversely, this presents a potential opportunity. If the site itself can be classified as a "brownfield site" under the specific definitions provided by the IRS for the Inflation Reduction Act (IRA), it could qualify for a 10% ITC adder. This is a key diligence item that requires expert environmental consultation.

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