⚡ 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 19.66-acre parcel located on Ashburnham Hill Road in Fitchburg, Worcester County, Massachusetts. The analysis identifies several critical risks, primarily concerning zoning and environmental factors, that must be addressed before committing significant development capital.

1. Site Access & Topography

Road Access: The property appears to have frontage on Ashburnham Hill Road, which is a two-lane, paved public road. Based on satellite imagery, the road quality seems adequate for standard construction traffic. However, a formal road survey is required to confirm weight limits and the condition of any bridges or culverts on the likely transport route.

Equipment Delivery: The primary challenge will be creating a suitable construction entrance. The parcel is currently undeveloped and heavily wooded. A new, wide-mouthed access road with an appropriate turning radius will need to be constructed from Ashburnham Hill Road onto the site. This will be critical for the delivery of oversized and overweight equipment, such as the main power transformer (MPT) and prefabricated battery enclosures, which are typically transported via lowboy trailers. The feasibility of these deliveries depends on the road's geometry and any overhead utility line clearances.

Terrain & Topography: The site is located in a region of central Massachusetts known for rolling hills. Satellite imagery suggests the parcel is forested with potentially significant topographic relief. A detailed topographic survey is an immediate requirement to determine the extent of grading and civil work needed to create a level pad for the BESS equipment. The cost of earthwork could be substantial if the slopes are steep.

Easement Concerns: Requires Verification. While the parcel appears to have direct road frontage, the exact legal access point is unknown. We must verify through a title search that there are no access restrictions. Furthermore, an access easement may need to be formally established with the City of Fitchburg for the construction entrance.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any location within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable for critical infrastructure like a BESS or impose prohibitive mitigation costs (e.g., elevating all equipment). A FEMA map review is a priority next step.

Wetlands: The presence of wetlands is unknown. Given the site's undeveloped and forested nature in Massachusetts, there is a high probability of state or federally jurisdictional wetlands, streams, or vernal pools. The Massachusetts Wetlands Protection Act imposes significant buffer zones (typically 100 feet) and a complex, often lengthy, permitting process through the local Conservation Commission. A desktop screening using the National Wetlands Inventory (NWI) is an immediate first step, to be followed by a formal field delineation by a certified wetland scientist if the site progresses.

Critical Habitat / Species: The initial screening indicates no critical habitats or protected areas on the parcel itself, which is a positive finding. However, this should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species habitats are present.

Brownfield/Superfund Status: The data indicates 41 brownfield or superfund sites within a two-mile radius. This is a significant concern for potential area-wide soil or groundwater contamination that could impact our site. A Phase I Environmental Site Assessment (ESA) is mandatory. Conversely, if the subject parcel itself qualifies as a brownfield (e.g., due to historical dumping or other contamination), it could be eligible for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This presents a high-risk, high-reward scenario that requires careful investigation.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a significant safety and layout advantage, eliminating the need for pipeline-related setback and mitigation measures.

3. Grid Infrastructure & Interconnection

Substation & Feeder: The nearest substation, River Street, is approximately 1.0 mile away. This is an excellent distance for a distribution-scale project, minimizing the cost and complexity of the generator lead line. The provided voltage data (-999999 kV) is clearly an error. Requires Verification. We must identify the interconnecting utility (likely Unitil or National Grid) and confirm the substation's distribution voltage, which is expected to be in the 13.8kV class. The most critical unknown is the available hosting capacity on the feeders exiting this substation. A formal pre-application inquiry with the utility is essential. The likely feeder configuration will be a 3-phase overhead line running along local roads.

Transmission Access: The nearest transmission line (115kV) is 2.8 miles away. For a project of this scale (≤5MW), interconnecting at transmission voltage would be economically unviable due to the high costs of a new substation and long line extension.

Interconnection Recommendation: The only viable path is