⚡ 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 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 & Equipment Delivery: The property has frontage 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, battery containers, and medium-power transformers. However, the quality of the road surface, weight limits, and any potential turning radius constraints for large tractor-trailers must be verified with a site visit and consultation with the local Department of Public Works.

Terrain & Buildability: Based on aerial imagery, the site is heavily wooded and appears to have rolling topography, which is characteristic of the region. Significant tree clearing and grading will be required, adding considerable cost and potential permitting complexity. The exact buildable area is unknown and is a critical data gap. There is a major discrepancy between the listed 19.66 acres and the Regrid parcel data of 2.4 acres. This must be resolved immediately, as 2.4 acres is barely sufficient for a 5MW BESS project after accounting for setbacks and environmental buffers.

Heavy Equipment Access: While the public road is likely adequate, creating a suitable construction entrance and an on-site access road capable of supporting a 100-ton crane (for transformer placement) will be a primary challenge. The entrance design must provide for safe sight lines and manage stormwater runoff. The feasibility depends heavily on the slope of the land directly adjacent to the road.

Easement Concerns: Requires Verification. A title search is required to determine if the property has clear, unencumbered legal access to Ashburnham Hill Road or if an access easement across an adjacent parcel is needed. The parcel's shape and exact frontage are currently unknown.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the site within a 100-year floodplain (Zone A/AE) would be undevelopable for critical infrastructure like a BESS, severely restricting the potential project footprint. A FEMA FIRMette analysis is a mandatory next step.

Wetlands: The presence of wetlands is unknown but highly likely given the site's undeveloped, wooded nature in Massachusetts. The Massachusetts Wetlands Protection Act (WPA) and local Fitchburg conservation bylaws impose strict regulations, including significant buffer zones (typically 100 feet) from any delineated wetlands, streams, or vernal pools. A desktop screening followed by a formal field delineation by a wetland scientist will be required.

Critical Habitat / Endangered Species: The initial data indicates no critical habitat or protected areas on site, which is a positive finding. However, this must be confirmed through a formal review of the MA Natural Heritage & Endangered Species Program (NHESP) database as part of the permitting process.

Brownfield/Superfund Status: The presence of 41 known contaminated sites within a 2-mile radius is a significant risk. While this could theoretically open the door for the 10% IRA Brownfield tax credit adder if the subject property itself is a qualified brownfield, it is far more likely to be a liability. The risk of migrating contaminants from nearby sites could trigger extensive and costly environmental remediation requirements. A Phase I Environmental Site Assessment (ESA) is non-negotiable for this site.

Pipeline Proximity: No gas transmission pipelines are located within 3 miles, mitigating risks associated with pipeline proximity and easement restrictions.

3. Grid Infrastructure & Interconnection

Nearest Substation: The River Street Substation is located approximately 1.0 mile from the site. This is a favorable distance for a distribution-level interconnection, minimizing the potential cost of a line extension. However, the provided voltage data (-999999 kV) is an error. Requires Verification. We must assume it is a standard distribution voltage (e.g., 13.8 kV) pending confirmation from the utility. The available capacity of the substation and the specific circuit feeders are the most critical unknowns.

Transmission Lines: A 115kV transmission line is 2.8 miles away. This distance makes a transmission-level interconnection economically unfeasible for a project of this scale (≤5MW).

Recommended Interconnection: The only viable path is a distribution-level interconnection to a 3-phase feeder originating from the River Street Substation. The interconnecting utility is likely Fitchburg Gas and Electric (a Unitil subsidiary).

Cost & Timeline Estimate: Assuming a 1-mile overhead line extension is required, the interconnection cost is estimated to be in the $1.5M - $3.0M range. The interconnection process in ISO-New England is notoriously slow and complex. The timeline from application submission to commercial operation can realistically be 24-48 months, representing a significant project risk.

Feeder Configuration: Requires Verification. A detailed feeder map from the utility is needed to identify the nearest 3-phase circuit and assess its current loading and protection scheme. The project's viability is entirely dependent on a viable feeder being accessible from the site.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Fitchburg is the primary AHJ for zoning and building permits.

Zoning Compatibility: The property is zoned RR (Rural Residential). This is a major, potentially fatal, flaw. BESS facilities are typically considered an industrial or utility use and are not permitted by-right in residential zones. The use is fundamentally incompatible with the intent of the RR district.

Permitting Pathway: A by-right pathway is not possible. The project would require, at a minimum, a Special Permit or, more likely