⚡ 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 property located on Ashburnham Hill Road in Fitchburg, MA. 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

The subject property is located on Ashburnham Hill Road. The name itself implies potentially significant topographical challenges. Worcester County is characterized by rolling hills, and development on sloped terrain can substantially increase civil engineering and construction costs due to the need for extensive grading and retaining walls. A full topographical survey is a critical next step.

• Road Access Quality: Requires Verification. Ashburnham Hill Road is likely a local, two-lane road. A site visit or detailed satellite imagery review is required to assess its condition (paved/unpaved), width, and any potential weight limit restrictions that could impede the delivery of heavy equipment.
• Equipment Delivery Feasibility: The primary concern is the combination of road quality and site topography. Delivery of multi-ton transformers and prefabricated battery containers requires wide, stable access roads with gentle turning radii and minimal grades. The "Hill" location presents a material risk that access may be difficult or require costly road improvements.
• Easement Concerns: Assuming the parcel has direct frontage on Ashburnham Hill Road, a dedicated access easement may not be required. However, an ALTA survey is necessary to confirm legal access and identify if the optimal entry point for construction is indeed from the public right-of-way or would require negotiation with an adjacent landowner.

2. Environmental Constraints

The site presents several significant environmental unknowns that must be resolved immediately. Massachusetts has stringent environmental protection laws, and any one of these factors could represent a fatal flaw.

• FEMA Flood Zone: Status is Unknown. This is a critical data gap. A review of FEMA Flood Insurance Rate Maps (FIRMs) is a top priority. If any portion of the buildable area is within a Special Flood Hazard Area (e.g., Zone A, AE), it would likely render the site unsuitable or require elevating all equipment above the Base Flood Elevation, adding significant cost.
• Wetlands: Status is Unknown. Another critical data gap. A desktop review using the National Wetlands Inventory (NWI) is the first step, but a formal wetland delineation by a certified professional will be required. The Massachusetts Wetlands Protection Act imposes substantial buffer zones (typically 100 feet) from delineated wetlands, which could severely constrain the buildable area.
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• Critical Habitat / Endangered Species: The initial screen shows no critical habitat on site, which is a positive. However, this should be verified with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed species or priority habitats are present.
• Brownfield/Superfund Status: The presence of 41 brownfield or superfund sites within a two-mile radius is a significant concern. While this does not mean the subject parcel is contaminated, it elevates the risk. A Phase I Environmental Site Assessment (ESA) is mandatory. Conversely, if the site itself could be classified as a brownfield (e.g., through historical use), it could qualify for the 10% IRA Brownfield ITC Adder, turning a potential liability into a financial advantage. This requires careful investigation.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive finding that mitigates safety and setback concerns related to pipeline infrastructure.

3. Grid Infrastructure & Interconnection

The site's proximity to existing grid infrastructure is its strongest attribute, though key information is missing.

• Nearest Substation: The RIVER STREET substation is located approximately 1.0 mile from the parcel. This is an excellent distance for a distribution-level project, minimizing the cost and complexity of the generator lead line. The provided voltage of "-999999 kV" is a data error; this is likely a standard distribution substation operating at a voltage such as 13.2kV or 13.8kV. Available capacity at the substation and on the associated feeders is the most critical unknown.
• Nearest Transmission Line: A 115kV transmission line is 2.8 miles away. This is too distant to be a viable Point of Interconnection (POI) for a ≤5MW project, as the interconnection costs would be prohibitive.
• Recommended Interconnection: The clear strategy is a distribution-level interconnection at 13