⚡ 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 097 214-9-0 (Ashburnham Hill Rd, Fitchburg, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 19.66-acre property located on Ashburnham Hill Road in Fitchburg, Worcester County, Massachusetts. The analysis identifies significant opportunities related to grid proximity but also flags several critical risks, primarily concerning zoning and environmental conditions, that must be addressed before committing further development capital.

1. Site Access & Topography

• Road Access Quality: The site has frontage on Ashburnham Hill Road, which appears to be a two-lane, paved public road. A preliminary review of satellite imagery suggests the road is in reasonable condition and suitable for standard construction traffic. However, a physical site visit is required to assess road width, shoulder conditions, and any weight-limited bridges or culverts between the site and major state highways.
• Terrain Characteristics: As is typical for Worcester County, the parcel appears to be heavily wooded with moderately rolling terrain. Significant tree clearing and civil work, including grading, will be required to create a level pad for the BESS equipment. The costs associated with this site preparation could be substantial and must be factored into the project pro-forma. A topographic survey is a critical next step.
• Heavy Equipment Feasibility: Access for heavy equipment, such as a 100-ton crane for setting the main power transformer and lowboy trailers for delivering battery containers, appears feasible from Ashburnham Hill Road. The primary challenge will be constructing a suitable temporary and permanent access road from the public right-of-way onto the project site itself, which will require grading and a stable road base.
• Easement Concerns: A new access easement will need to be formally established and permitted by the City of Fitchburg to connect the project site to Ashburnham Hill Road. No other access easement concerns are immediately apparent, but a title search is required to confirm there are no existing easements (e.g., for conservation or third-party access) that would encumber the property.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any location within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable or require costly mitigation measures like elevating all equipment, which is often prohibitive for BESS projects. A desktop flood analysis is an immediate priority.
• Wetlands Presence: The presence of wetlands is Unknown. Given the wooded nature of the site in Massachusetts, it is highly probable that state or federally jurisdictional wetlands and associated buffer zones exist. Massachusetts has stringent wetland protection laws, and a full wetland delineation by a certified professional will be required. The presence of significant wetlands could severely restrict the buildable area.
• Critical Habitat / Endangered Species: Initial data indicates no critical habitat on site. This is a positive finding. However, it is standard practice to run a report through the U.S. Fish and Wildlife Service's IPaC (Information for Planning and Consultation) tool to screen for any potential federally listed species or habitats that could trigger consultation requirements.
• Brownfield/Superfund Status: The data indicates an alarming 41 brownfield or superfund sites within a two-mile radius. This presents both a risk and a potential opportunity.
  • Risk: The high density of contaminated sites increases the risk that this specific parcel may have historical contamination (e.g., from illegal dumping or groundwater migration). A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
  • Opportunity: If the site itself qualifies as a "brownfield site" under IRA guidelines, the project could be eligible for a 10% ITC adder. However, this would require a Phase II ESA to confirm contamination and potentially a remediation plan, adding significant cost and complexity. This is a high-risk, high-reward scenario.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a significant safety and layout advantage, eliminating concerns about pipeline-related setbacks and potential blast zones.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The RIVER STREET substation is located approximately 1.0 mile from the parcel. This is an excellent distance for a distribution-scale project, minimizing the cost and complexity of the generator lead line. The provided voltage data is erroneous (-999999 kV), but this is almost certainly a standard distribution substation, likely operating at 13.8kV. Verification of the substation's actual voltage and available capacity with the utility is a top priority.
• Transmission Line Proximity: A 115kV transmission line is 2.8 miles away. This is not a viable Point of Interconnection (POI) for a ≤5MW project due to the excessive cost of a 2.8-mile transmission-level extension and the high cost of a dedicated high-voltage substation.
• Recommended Interconnection: The clear strategy is to interconnect at the distribution level, targeting a 13.8kV (or similar) feeder out of the RIVER STREET substation.
• Estimated Cost & Timeline: A one-mile, 3-phase overhead distribution line extension could range from $1.5M to $3.0M. This cost is highly dependent on terrain, the number of poles required, road crossings, and utility make-