⚡ 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 located on Ashburnham Hill Road in Fitchburg, Worcester County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access: The property appears to have direct frontage on Ashburnham Hill Road, which is a paved, two-lane public road. However, the quality of the road for heavy haul transport is unconfirmed. A formal road study would be required to assess weight limits, turning radii, and overall suitability for transporting heavy equipment such as transformers, switchgear, and battery containers (typically 80,000+ lbs).

Terrain & Equipment Access: Satellite imagery reveals the parcel is heavily wooded with significant and challenging topography, including steep slopes. This is characteristic of the region. Developing this site would require substantial tree clearing, grading, and the construction of a new, engineered access road from Ashburnham Hill Road to a prepared BESS pad. The costs associated with this level of site work are expected to be very high and could significantly impact the project pro-forma. Access for a crane, concrete trucks, and delivery vehicles will be a major logistical and financial challenge.

Easement Concerns: While direct frontage appears likely, a title search is required to confirm legal access and identify any existing utility or access easements that could encumber the property. Given the need to construct a new access drive, a temporary construction easement on neighboring parcels might also be necessary.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. A review of FEMA's Flood Insurance Rate Maps (FIRMs) is an immediate next step. Any designation other than Zone X would likely render the site undevelopable or require costly mitigation measures like elevating all equipment above the Base Flood Elevation.

Wetlands: The presence of wetlands is Unknown. The site's undeveloped, wooded, and sloped nature creates a high probability of state- and federally-jurisdictional wetlands, vernal pools, or intermittent streams. Massachusetts has a very stringent Wetlands Protection Act. A formal wetland delineation will be required, and the presence of wetlands could severely restrict the buildable area due to mandatory buffer zones, potentially making a 5MW BESS layout impossible.

Brownfield/Superfund Status: The data indicates 41 brownfield or superfund sites within a two-mile radius. This is an alarmingly high number and suggests a history of industrial activity in the vicinity. While this could theoretically open the door to the 10% IRA Brownfield ITC adder, it is far more likely to be a major risk. There is a heightened potential for on-site contamination (soil or groundwater) from historic use or migration from nearby sites. A Phase I Environmental Site Assessment (ESA) is a mandatory, high-priority due diligence item.

Other Considerations: The site has no identified critical habitat or protected areas, and no pipelines are in close proximity, which are minor positives. The site is not within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Interconnection Point (POI): The nearest substation is National Grid's RIVER STREET substation, located approximately 1.0 mile from the parcel. This is a favorable distance for a distribution-scale project. The provided voltage data (-999999 kV) is an error and Requires Verification. It is presumed this substation supports distribution circuits, likely at 13.8kV, which would be the target interconnection voltage.

Interconnection Feasibility & Cost: A 1.0-mile, 3-phase line extension would be required to connect the project to the nearest feeder from the River Street substation. The route would likely follow public rights-of-way, but the hilly terrain and potential for rock ledge could make construction difficult and expensive. A preliminary cost estimate for this scope would be in the $1.5M - $3.0M range, subject to a formal utility study. The nearest transmission line (115kV at 2.8 miles) is not a viable POI for a project of this scale due to prohibitive costs.

Utility Process: The interconnecting utility is National Grid. The interconnection process in Massachusetts is governed by the state's Department of Public Utilities (DPU) and is known to be lengthy and complex. From application submission to receiving Permission to Operate (PTO), timelines of 24-36 months are common for projects requiring system modifications. Queue position and feeder capacity are major unknowns that must be investigated via a pre-application report.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Fitchburg.

Zoning & Compatibility: The parcel is zoned RR (Rural Residential). This zoning is fundamentally incompatible with a BESS, which is considered a utility or industrial use. Development is not possible "by-right."

Permitting Pathway: The only viable, albeit extremely high-risk, pathway would be to obtain a Use Variance or a Special Permit from the Fitchburg Zoning Board of Appeals (ZBA). This process is discretionary, costly, time-consuming (9-18+ months), and carries a very high risk of denial. It would require extensive public hearings and is likely to face significant opposition from neighboring residential property owners ("NIMBYism").

Regulations & Risks: We must research the Fitchburg Zoning Ordinance for any specific BESS regulations or, more likely, prohibitions. Many municipalities in Massachusetts have enacted or are considering moratoriums on BESS development. Verifying the absence of such a moratorium is a critical first step. All development would also need to comply with Massachusetts state fire code based on NFPA 855.

Note on Acreage: There is a major discrepancy between two data sources (19.66 acres vs. 2.40 acres). A 2.4-acre site would be extremely constrained for a 5MW BESS after accounting for RR zoning setbacks, wetland buffers,