⚡ 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 214-9-0 (Ashburnham Hill Rd, Fitchburg, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a property located on Ashburnham Hill Road in Fitchburg, Worcester County, Massachusetts. The analysis identifies several significant challenges, primarily related to zoning, incentives, and buildability, that present substantial risks to project viability.

1. Site Access & Topography

Road Access: The property has frontage on Ashburnham Hill Road, which appears to be a two-lane, paved public road based on aerial imagery. However, the quality, weight limits, and condition of the road surface require on-site verification. The road appears winding and potentially narrow in sections, which could pose challenges for oversized and overweight vehicles.

Terrain Characteristics: The property name, "Ashburnham Hill Rd," strongly suggests hilly and potentially steep terrain. A preliminary review of topographic maps confirms this, indicating significant elevation changes across the parcel. This will likely necessitate substantial civil work, including grading, cut-and-fill operations, and the construction of retaining walls, driving up site preparation costs significantly.

Heavy Equipment Feasibility: Access for heavy equipment is a major concern. The delivery of multi-ton transformers and 40-foot battery containers via lowboy trailers requires wide turning radii, gentle slopes, and roads capable of supporting heavy loads. The combination of winding roads and steep on-site topography may make delivery difficult or require extensive road and site entrance improvements. A detailed logistics and transportation study is required.

Easement Concerns: Requires Verification. While the property has road frontage, a formal, improved access point suitable for heavy construction traffic does not appear to exist. A new curb cut permit from the Fitchburg Department of Public Works will be necessary. Furthermore, an access easement across the property from the public road to the flattest, most buildable portion of the site will need to be established and constructed.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the site located within a 100-year floodplain (Zone A/AE) would be severely constrained, requiring expensive mitigation (e.g., elevating all equipment) or rendering that area unusable. A full FEMA FIRMette analysis is an immediate next step.

Wetlands: Requires Verification. The presence of wetlands is unknown. Given the hilly terrain, there may be downslope collection areas, vernal pools, or streams. Massachusetts has a highly restrictive Wetlands Protection Act, which imposes significant buffer zones (typically 100 feet) where development is prohibited or heavily restricted. A desktop screening followed by a formal wetlands delineation by a certified professional is mandatory.

Critical Habitat / Endangered Species: The data indicates no critical habitat on site. This is a positive finding. However, as a best practice, we must cross-reference the site with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitat maps to confirm no state-listed species are present.

Brownfield/Superfund Status: The property itself is not listed as a brownfield. However, the presence of 41 documented contamination sites within a two-mile radius is a significant risk. This high density raises concerns about potential groundwater or soil contamination migrating onto our target parcel. A Phase I Environmental Site Assessment (ESA) is non-negotiable to assess this risk. This situation is a clear risk, not an advantage, as the site itself does not qualify for the 10% IRA brownfield tax credit adder.

Pipeline Proximity: No gas pipelines are identified within a three-mile radius, which is a positive safety and layout advantage, eliminating the need for pipeline-related setbacks and consultations.

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. However, the provided voltage data (-999999 kV) is erroneous. Requires Verification. We must identify the operating utility (likely Unitil or National Grid) and confirm the substation's distribution voltage, which is likely 13.8kV. The available capacity of the substation and the specific feeder circuit are the most critical unknowns that will determine project feasibility.

Transmission Line Proximity: A 115kV transmission line is 2.8 miles away. This is too distant to be a cost-effective point of interconnection for a project of our target size (≤5MW). Our focus must remain on a distribution-level connection.

Recommended Interconnection: The recommended pathway is a 13.8kV (or other available distribution voltage) connection to a feeder out of the River Street Substation.

Cost & Timeline Estimate: A one-mile, three-phase line extension is a major cost driver. Preliminary estimates would be in the $750,000 to $2,000,000+ range, highly dependent on whether it is overhead or underground, existing pole conditions, rock ledges, and the extent of utility-mandated system upgrades. The ISO-New England interconnection process is notoriously