⚡ 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 for APN 097 214-9-0 (ASHBURNHAM HILL RD, Fitchburg, MA)

This report provides a comprehensive due diligence analysis for the subject property in Fitchburg, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

The property is located on Ashburnham Hill Road. The name itself suggests potentially challenging topography, a common characteristic of Worcester County. This implies a high likelihood of moderate to steep slopes across the parcel, which could significantly increase civil engineering and site preparation costs for grading and establishing level pads for battery containers and substation equipment. A formal topographical survey is required to quantify these costs.

Road access quality is a critical unknown. While Ashburnham Hill Road is a public road, its classification (local, collector), pavement quality, width, and any potential weight-limit bridges are unconfirmed. Feasibility for delivering heavy equipment, including 80,000-lb transformers and 53-foot containerized BESS units via lowboy trailers, is questionable without a physical site visit and route survey. Turning radii from main thoroughfares onto Ashburnham Hill Road and into the site itself must be assessed. Furthermore, a title search is immediately required to confirm legal access rights and identify any existing easements (e.g., for other utilities or neighboring properties) that could encumber the site layout and reduce the buildable area.

2. Environmental Constraints

The environmental profile of this site presents several significant risks. Both FEMA flood zone and wetlands status are unknown. Given Massachusetts' strict Wetlands Protection Act, the potential presence of regulated wetlands and their associated 100-foot buffer zones could severely restrict or eliminate the buildable area. A desktop screening using MassGIS and NWI layers, followed by a formal wetland delineation, is a mandatory next step.

A major red flag is the identification of 41 brownfield or superfund sites within a two-mile radius. While an on-site brownfield designation can unlock a 10% IRA tax credit adder, the proximity to so many contaminated sites is a significant liability risk. There is a heightened potential for soil or groundwater contamination on the subject parcel from off-site migration. A Phase I Environmental Site Assessment (ESA) is non-negotiable and should be commissioned immediately to assess this risk. On the positive side, the data indicates no critical habitats, protected areas, or major pipelines nearby, which eliminates several common environmental hurdles.

3. Grid Infrastructure & Interconnection

The site's proximity to grid infrastructure is its strongest attribute, though it comes with uncertainty. The RIVER STREET substation is located an advantageous 1.0 mile from the parcel. This distance is feasible for a distribution-level interconnection. However, the provided voltage data (-999999 kV) is erroneous and requires immediate verification. The interconnecting utility is likely Unitil, and their distribution voltages are typically in the 13.8 kV class. The available capacity at the substation is unknown and is a primary driver of project viability; this can only be determined by submitting a formal interconnection application.

The recommended interconnection pathway is a new 3-phase distribution feeder line to the RIVER STREET substation. A 1.0-mile gen-tie is a material project cost