⚡ ASHBURNHAM HILL RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Ashburnham Hill Rd, Fitchburg, MA (APN: 214-9-0)

1. Site Access & Topography

Road Access & Equipment Delivery: The subject parcel has frontage on Ashburnham Hill Road, which is a paved, two-lane public road. Initial desktop review suggests the road is suitable for standard construction traffic. However, the delivery of oversized and overweight equipment, specifically a main power transformer on a lowboy trailer and 40-foot battery containers, requires further analysis. The road appears to have some curves and grade changes, characteristic of its "Hill Road" name. A formal route survey and turning radius analysis would be necessary to confirm that a 13-axle trailer can safely navigate from the nearest highway to the site entrance.

Terrain Characteristics: The site's location in Worcester County and its road name strongly suggest rolling to hilly terrain. This is a significant buildability concern. Extensive civil work, including cutting, filling, and grading, would likely be required to create a level pad for the BESS compound. This will increase site preparation costs and could trigger more stringent stormwater management regulations. A detailed topographic survey is an essential next step to quantify the required earthwork.

Heavy Equipment Access: Assuming the delivery route is confirmed feasible, access onto the parcel itself is undefined. A new curb cut and a heavy-duty access road (likely gravel, 20-24 feet wide) would need to be constructed from Ashburnham Hill Road to the BESS pad. The cost and permitting for this access road must be factored into the project budget.

Easement Concerns: While the parcel appears to have direct road frontage, the exact width and location of any road right-of-way is unknown. An ALTA survey is required to confirm that a suitable access point can be constructed without encroaching on neighboring properties or violating municipal right-of-way. No other access easements appear necessary, but this must be confirmed via a title search.

A critical discrepancy exists regarding parcel size: the initial data sheet notes 19.66 acres, while Regrid data indicates 2.39 acres. This must be resolved immediately, as 2.4 acres is extremely tight for a 5MW BESS project once setbacks, access, and environmental buffers are considered.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical and potentially fatal flaw. Any portion of the buildable area located within a 100-year floodplain (Zone A or AE) would render the site undevelopable for critical infrastructure like a BESS, or require cost-prohibitive mitigation measures such as elevating all equipment on platforms. A FEMA FIRMette must be generated immediately as a first-pass screening.

Wetlands: The presence of wetlands is Unknown. Massachusetts has some of the most stringent wetlands protection laws in the country (Massachusetts Wetlands Protection Act, M.G.L. c. 131, § 40). The likely hilly terrain increases the probability of streams, vernal pools, and bordering vegetated wetlands. Any identified wetlands will have significant buffer zones (typically 100 feet or more) where development is prohibited, which could severely constrain the buildable area. A desktop screening using MassGIS Oliver and the National Wetlands Inventory (NWI) is a mandatory first step, to be followed by a formal field delineation by a certified wetland scientist if the site passes initial screening.

Critical Habitat / Endangered Species: The initial data indicates no critical habitat. This is a positive finding. However, this should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitat maps to ensure no state-listed species or habitats are present.

Brownfield/Superfund Status: The data notes 41 contaminated sites within a 2-mile radius. This presents both a risk and a potential opportunity. The risk is that the subject parcel itself could have unrecognized contamination from historic use or migration from nearby sites, which would require costly remediation. The opportunity is that this high density of sites may qualify the census tract for the 10% IRA Brownfield tax credit adder. A Phase I Environmental Site Assessment (ESA) is required to assess contamination risk and determine if the site meets the definition of a brownfield under CERCLA § 10