⚡ ASHBURNHAM HILL RD

MEMORANDUM

TO: Sunland America Corp. Investment 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, for its potential as a distribution-scale Battery Energy Storage System (BESS) site. The analysis covers key evaluation criteria from grid access to regulatory hurdles and provides a final recommendation.

1. Site Access & Topography

Road Access: The property is located on Ashburnham Hill Road. A preliminary desktop review indicates this is a two-lane, paved local road. However, its width, shoulder quality, and weight limits are unknown and require verification. The "Hill" in the name strongly suggests significant grade changes, which could complicate the transport of heavy equipment.

Equipment Delivery: The primary concern is delivering oversized and overweight loads, such as a 50-ton main power transformer and 30-ton BESS containers. The feasibility depends on the grade of Ashburnham Hill Rd, any sharp turns, and the presence of any low-clearance bridges or overhead lines between the site and major state highways. A formal route survey is mandatory.

Terrain & Buildability: The site's topography is a major unknown and a significant risk. Hilly terrain will substantially increase civil engineering and site preparation costs due to the need for extensive grading to create a level pad for the BESS equipment. A preliminary topographical survey is essential. There is a critical discrepancy in the provided data regarding parcel size (19.66 acres vs. 2.4 acres). If the parcel is only 2.4 acres, the combination of steep slopes and potential environmental setbacks could render the site unbuildable for a 5MW project, which typically requires 1-2 flat, usable acres.

Easement Concerns: Requires Verification. The parcel's configuration and frontage on Ashburnham Hill Road are unclear. We must verify through a title search and survey that the property has direct, legal, and sufficient physical access to the public road. If access is through an easement over an adjacent property, its terms must be reviewed to ensure it allows for heavy industrial traffic and utility construction.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. A review of FEMA's Flood Insurance Rate Maps (FIRMs) is a critical next step. If the buildable area falls within a Special Flood Hazard Area (e.g., Zone A or AE), development will be severely restricted and may require elevating all equipment above the Base Flood Elevation, adding significant cost and complexity.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with typical 100-foot buffer zones ("Riverfront Area"). Given the hilly terrain, vernal pools and intermittent streams are common. A desktop screening using the National Wetlands Inventory (NWI) is the first step, likely to be followed by a formal field delineation by a certified wetland scientist. Any wetlands on-site would significantly reduce the buildable acreage.

Brownfield/Superfund Status: The data indicates 41 brownfield or superfund sites within a two-mile radius. This high concentration suggests a history of industrial activity in the area and elevates the risk of on-site contamination. A Phase I Environmental Site Assessment (ESA) is non-negotiable. This presents a dual-edged sword: while it poses a risk of costly remediation and liability, if the site itself qualifies as a brownfield (as determined by an ASTM E1903-19 Phase II ESA), it could be eligible for the 10% IRA Energy Community tax credit adder.

Other Considerations: The site has no identified critical habitats, protected areas, or nearby pipelines, which are positive factors that de-risk the project from those specific environmental perspectives. The site is not within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & POI: The proximity to the RIVER STREET substation, at just 1.0 mile, is the single most attractive feature of this site. This distance is ideal for a cost-effective distribution-level interconnection. The provided voltage data (-999999 kV) is an error; this is likely a National Grid substation with standard distribution voltages such as 13.8 kV.

Interconnection Voltage & Cost: For a ≤5MW BESS, the recommended interconnection path is via a 13.8 kV (or similar) distribution feeder from the River Street substation. A transmission-level interconnection to the 115kV line 2.8 miles away would be economically unviable. The estimated cost for a 1.0-mile, 3-phase distribution line extension could range from $750,000 to $2,000,000, highly dependent on terrain, pole ownership, and whether it is overhead or