⚡ ASHBURNHAM HILL RD

MEMORANDUM

TO: Sunland America Corp. Development Team

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 the subject property in Fitchburg, Massachusetts, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis concludes with a BESS Suitability Score and a final recommendation.

1. Site Access & Topography

Road Access: The property has frontage on Ashburnham Hill Road, a two-lane, paved public road. A preliminary review of aerial imagery suggests the road is in fair condition and appears suitable for standard construction traffic. However, its width and turning radii may present challenges for oversized and overweight loads.

Terrain & Equipment Feasibility: The site's topography is a significant concern. The parcel is heavily wooded and appears to have considerable slope, consistent with the terrain of Worcester County. This will necessitate substantial site work, including tree clearing, grubbing, and extensive grading to create a level pad for the BESS containers, transformer, and switchgear. The cost and timeline for this site preparation are likely to be high. Access for heavy equipment, such as a 100-ton crane for setting the main power transformer and low-boy trailers for delivering battery containers, is feasible from the road but will require construction of a robust, graded access drive onto the property itself. The slope may complicate the design of this access road.

Easement Concerns: A significant data discrepancy exists regarding the parcel size (19.66 acres vs. 2.4 acres in different data sources). This must be clarified immediately. Assuming the larger acreage, the buildable area may be set back from the road, requiring a dedicated access easement. A full title report is required to confirm legal access rights from the public right-of-way to the planned project area and to identify any existing utility or conservation easements that could restrict development.

2. Environmental Constraints

Flood & Wetlands: FEMA flood zone and wetlands status are currently unknown and represent critical data gaps. Given the site's topography and location in New England, the presence of streams, vernal pools, or jurisdictional wetlands is highly probable. Development will be subject to the Massachusetts Wetlands Protection Act and potentially the U.S. Army Corps of Engineers, requiring significant setbacks (typically 100-200 feet) that could severely constrain the buildable envelope. Siting equipment within a designated flood zone is a fatal flaw without costly mitigation measures like elevating all equipment above the Base Flood Elevation.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a desktop screening using the USFWS IPaC tool and consultation with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) is a mandatory next step to confirm the absence of state or federally listed species whose habitats could be impacted by clearing and construction.

Brownfield/Superfund Status: The presence of 41 potential brownfield/superfund sites within a two-mile radius is a double-edged sword. It presents a risk that the subject parcel itself could have legacy contamination requiring costly remediation. Conversely, if the site qualifies as a "brownfield site" under federal definitions (e.g., through a Phase I/II Environmental Site Assessment), the project could be eligible for the 10% IRA Brownfield Tax Credit adder. This potential incentive warrants immediate investigation via the EPA's databases.

Other Constraints: The site is not within the Chesapeake Bay Critical Area. No pipelines are located in the immediate vicinity, which eliminates a significant safety and setback concern.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation, River Street, is approximately 1.0 mile away. This is a very favorable distance for a distribution-scale project, minimizing the potential cost of a new feeder line. The provided voltage data (-999999 kV) is an error; this is almost certainly a standard distribution substation, likely operating at 13.8 kV. This voltage is ideal for a ≤5MW BESS interconnection. The critical unknown is whether the substation and the specific distribution feeders have available capacity to accommodate a 5MW injection of power without requiring major, cost-prohibitive upgrades.

Interconnection Recommendation & Cost: The recommended Point of Interconnection (POI) is a new 3-phase overhead distribution line extension from an existing feeder connected to the River Street substation. A 1-mile line extension is a significant undertaking. A preliminary cost estimate for this scope would be in the range of $1,000,000 - $2,500,