⚡ ASHBURNHAM HILL RD

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 214-9-0, Ashburnham Hill Rd, Fitchburg, MA

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project on a property located on Ashburnham Hill Rd (APN 214-9-0) in Fitchburg, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, grid access, environmental constraints, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Ashburnham Hill Road. A preliminary review using satellite imagery indicates this is a two-lane, paved local road. While likely sufficient for standard construction vehicles, its width, shoulder quality, and any potential weight limits require verification with the Fitchburg Department of Public Works.

Topography & Equipment Delivery: The road name, "Ashburnham Hill," strongly suggests challenging topography. A desktop topographic analysis confirms the area is characterized by rolling hills. The specific parcel appears to have a significant grade change, which could substantially increase civil engineering and site preparation costs. The feasibility of delivering oversized/overweight equipment, such as a main power transformer (MPT) or 53-foot battery containers, is a major concern. A detailed route survey would be necessary to assess turn radii from major state routes, bridge weight limits, and overhead line clearances. Access for a crane required for setting the MPT and containers is questionable without significant site grading.

Easement Concerns: A critical ambiguity exists regarding the parcel size, with county records indicating 19.66 acres while GIS data suggests 2.3972 acres. This discrepancy is a major red flag. If the parcel is only the smaller 2.39-acre lot, it may be insufficient for a 5MW BESS project, especially after accounting for setbacks and topographic constraints. If the larger acreage is correct, we must verify that the portion with road frontage provides legal and practical access to the rest of the property. A full title search is immediately required to confirm legal access, parcel size, and identify any existing utility or access easements that could encumber the property.

2. Environmental Constraints

Flood Zone & Wetlands: FEMA flood zone and wetland status are currently Unknown. These are critical data gaps. A preliminary desktop review using the FEMA Map Service Center and National Wetlands Inventory (NWI) is an immediate next step. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act), which mandate significant setbacks (typically 100 feet or more) from any delineated wetland resources. Any presence of Zone A/AE floodplains or significant wetlands on the developable portion of the site would likely render it undevelopable or economically unviable.

Habitat & Protected Species: While no federally designated Critical Habitat is present, a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is required to screen for state-listed rare or endangered species whose presence could trigger lengthy consultations and mitigation requirements.

Brownfield/Superfund Status: The presence of 41 documented brownfield or superfund sites within a two-mile radius is alarming and indicates a history of industrial activity in the vicinity. This elevates the risk of on-site contamination. A Phase I Environmental Site Assessment (ESA) is mandatory to identify any Recognized Environmental Conditions (RECs). While this is a risk, if the site itself were to qualify as a brownfield