⚡ ASHBURNHAM HILL RD

MEMORANDUM

TO: Sunland America Corp. Development Team

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, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis identifies several significant challenges, primarily related to zoning and a lack of financial incentives, which present substantial risks to project viability.

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 the main power transformer. However, a detailed route survey is required to confirm the absence of low-clearance bridges, tight turning radii, or weight-limited infrastructure between the site and major state highways. Overhead utility lines along the road could also pose a clearance challenge for tall equipment like transformers.

Terrain Characteristics: As a vacant, undeveloped parcel in Worcester County, the site is presumed to be wooded with moderately rolling topography, characteristic of the region. Significant site work, including tree clearing, grading, and leveling, will be required to create a suitable pad for the BESS compound. A topographical survey is a critical next step to quantify the extent of earthwork needed, which will be a major driver of construction costs.

Heavy Equipment Feasibility: Access for standard heavy equipment (excavators, cranes, delivery trucks) appears feasible from Ashburnham Hill Road. The primary buildability concern is not road access itself, but the on-site conditions (slope, soil stability, presence of ledge/rock) which are currently unknown.

Easement Concerns: A significant easement will be required for the 1.0-mile gen-tie line to the River Street substation. This will likely involve negotiations with multiple private landowners and potentially require crossing public roads. Securing these easements can be a time-consuming and costly process, representing a material project risk.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap. Any portion of the buildable area falling within a 100-year floodplain (Zone A or AE) would likely render the site unsuitable or require costly mitigation, such as elevating all equipment on platforms. A FEMA FIRMette must be reviewed immediately.

Wetlands: The presence of wetlands is Unknown but highly probable in this part of Massachusetts. Under the Massachusetts Wetlands Protection Act, significant buffer zones (typically 100 feet) are required from any delineated wetlands, which could severely constrain the buildable area. A formal wetland delineation is a mandatory, high-priority diligence item.

Critical Habitat / Endangered Species: The initial screen shows no designated critical habitat on the parcel, which is a positive finding. 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 red flag. While this could potentially qualify the site for the 10% IRA brownfield tax credit adder, it more immediately raises the risk of on-site contamination from neighboring sources. A Phase I Environmental Site Assessment (ESA) is non-negotiable to assess liability. The risk of discovering contamination currently outweighs the potential incentive benefit.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive safety and siting factor, eliminating the need for pipeline-related setback and impact studies.

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-scale project. The provided voltage data (-999999 kV) is an error; this is almost certainly a distribution substation, likely operating at a standard voltage like 13.8kV. The interconnecting utility is Fitchburg Gas and Electric, a subsidiary of Unitil. The available capacity of the substation and, more importantly, the specific distribution feeder circuit serving this area, is the single most critical unknown for grid access.

Transmission Proximity: A 115kV transmission line is 2.8 miles away. This distance is too great to be economically viable for a ≤5MW project, making a transmission-level interconnection infeasible.

Recommended Interconnection: The only viable path is a distribution-level interconnection at the River Street substation, likely via a new 1.0-mile overhead feeder extension. An underground line would be prohibitively expensive unless required by the municipality.

Cost & Timeline Estimate: A 1.0-mile overhead distribution gen-tie could range from $750,000 to $1,500,000, including utility