⚡ 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 – Ashburnham Hill Rd, Fitchburg, MA (APN: 214-9-0)

This report provides a comprehensive due diligence analysis for the property located on Ashburnham Hill Rd, Fitchburg, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis identifies significant challenges, particularly concerning zoning and financial incentives, that present substantial risk to project viability.

1. Site Access & Topography

Road Access: The site is located on Ashburnham Hill Road, which appears to be a two-lane, paved public road. This level of access is generally sufficient for the delivery of construction materials and operational personnel. However, direct frontage and the presence of an existing curb cut or driveway onto the parcel are unknown and require verification.

Terrain & Equipment Feasibility: The property is situated in Worcester County, an area characterized by rolling hills and wooded terrain. A desktop topographic review is required, but it is likely the site is not flat. Significant grading may be necessary to create a level pad for the BESS containers, switchgear, and transformer, which could substantially increase civil engineering and construction costs. The ability for heavy-haul trucks carrying multi-ton transformers and battery enclosures to navigate the final approach and enter the site is a critical unknown. The internal site path from the public road to the BESS pad must be assessed for grade, turning radii, and soil stability.

Easement Concerns: A significant discrepancy exists in the reported acreage (19.66 acres vs. 2.4 acres). It is imperative to immediately pull the property deed and survey to confirm the legal boundaries, configuration, and road frontage. If the parcel is landlocked or set back from the road, a formal, permanent access easement from the property owner and potentially abutters will be required, adding legal complexity and cost.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The flood zone and wetlands status are currently unknown. These are critical, potentially fatal-flaw data gaps. Given the New England landscape, the presence of wetlands, streams, or vernal pools is highly probable. The Massachusetts Wetlands Protection Act imposes stringent regulations, including 100-foot buffer zones where development is heavily restricted. Siting equipment within a Special Flood Hazard Area (SFHA) would trigger significant design changes, such as elevating all equipment above the Base Flood Elevation, rendering a project economically unfeasible. A desktop screening using FEMA and National Wetlands Inventory (NWI) maps is the immediate next step.

Habitat & Protected Species: Initial data indicates no critical habitats on site. This is a positive finding but must be verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present, which could trigger lengthy consultations and mitigation requirements.

Brownfield/Superfund Status: The presence of 41 registered brownfield or superfund sites within a two-mile radius is a major concern. This suggests a history of industrial activity in the area and elevates the risk that the subject parcel itself may have unrecognized contamination. A Phase I Environmental Site Assessment (ESA) would be essential. Conversely, if the site *is* a designated brownfield, it could be eligible for the 10% IRA Brownfield Tax Credit Adder. This represents a dual-risk/opportunity scenario that requires immediate investigation via MassDEP and EPA databases.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive safety and siting factor.

3. Grid Infrastructure & Interconnection

Substation & Feeder: The proximity to the RIVER STREET substation (1.0 mile) is the site's strongest attribute. This distance is highly favorable for a distribution-level interconnection. The provided voltage data is erroneous; however, this is likely a standard 13.8 kV distribution substation operated by Unitil (Fitchburg Gas and Electric). The key unknown is the available capacity on the substation transformers and the specific distribution feeder that would serve the site. We must verify that a 3-phase circuit runs along Ashburnham Hill Rd with sufficient thermal and voltage headroom to accommodate a 5MW BESS.

Interconnection Voltage & Cost: The recommended interconnection point is the local 13.8 kV distribution system. A transmission-level interconnection (115kV line at 2.8 miles) is not economically viable for a project of this scale. The estimated cost for a one-mile, 3-phase overhead distribution line extension could range from $750,000 to $2,000,000, highly dependent on terrain, existing pole conditions, and any required utility system upgrades identified in the interconnection study.

Utility Process: The interconnecting utility is Unitil, and the project would fall under the ISO-New England (ISO-NE) tariff. The Massachusetts interconnection process can be protracted. A full study process (Feasibility, System Impact, Facilities) can take 18-24 months, with another 12-1