⚡ CHARLTON RD

BESS SITE DILIGENCE ANALYSIS REPORT

Prepared For: Sunland America Corp. Development Committee

Prepared By: Senior BESS Site Evaluation Analyst

Date: October 26, 2023

Site Name: DUD-MANN-01

Property Address: CHARLTON RD, Dudley, Worcester County, MA, 01571

APN: 213_005_000_000

Parcel Size: 4.86 Acres

1. Site Access & Topography

Initial desktop analysis indicates the 4.86-acre parcel has direct frontage on Charlton Road, a two-lane, paved local road. The quality appears sufficient for standard construction traffic. However, a formal road survey is required to confirm weight limits and suitability for oversized/overweight transport of key equipment like the main power transformer and containerized battery enclosures. The primary access point would likely require a new curb cut, subject to approval by the Dudley Department of Public Works.

Based on satellite imagery and regional topography, the site is heavily wooded and appears relatively flat, with a gentle slope. Significant tree clearing and grading will be required to establish a suitable pad for a 3-5 MW BESS project, which typically requires 1-2 cleared acres. The cost of this site work must be factored into the project's pro forma. Feasibility of heavy equipment access is considered high from the road to the parcel boundary, but internal site access will depend on the final layout after accounting for environmental and zoning setbacks. No immediate access easement concerns are apparent due to the direct road frontage, but a full title report is necessary to confirm no restrictive covenants or unrecorded easements exist.

2. Environmental Constraints

Environmental factors present a significant risk profile for this site that requires immediate investigation.

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. A preliminary check of the FEMA Flood Map Service Center suggests the parcel is likely in Zone X (minimal flood hazard), but this must be officially verified. Any presence of a Special Flood Hazard Area (e.g., Zone A or AE) would severely restrict development or require costly mitigation, such as elevating all equipment above the Base Flood Elevation.
• Wetlands: The presence of wetlands is Unknown and represents a primary development risk. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) and the Dudley Conservation Commission will have jurisdiction. Satellite imagery suggests potential vegetated wetlands or intermittent streams nearby. A formal wetland delineation by a certified professional is an urgent next step. The discovery of jurisdictional wetlands could dramatically reduce the buildable area due to required buffer zones (typically 100 feet), potentially rendering the site unviable.
• Habitat & Species: While initial data shows no designated critical habitat, this does not preclude the presence of state or federally listed endangered species. A formal desktop screening using the USFWS IPaC tool and MassGIS Natural Heritage & Endangered Species Program (NHESP) data is required to assess risk.
• Brownfield/Superfund Status: The presence of two brownfield/superfund sites within a two-mile radius is noted. This presents a minor risk of potential contaminant migration, which should be assessed in a Phase I Environmental Site Assessment (ESA). Importantly, for the site to qualify for the 10% IRA Brownfield ITC adder, the project parcel itself must be a designated brownfield. Proximity alone does not confer this benefit. A Phase I ESA is required to determine if historical use of this vacant land could qualify it as a brownfield, though this is unlikely for undeveloped residential land.
• Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments.

3. Grid Infrastructure & Interconnection

The site's grid proximity is its most compelling attribute. The nearest substation, EAST WEBSTER, is located 1.6 miles away and is operated by National Grid. This is an ideal distance for a distribution-scale project. The substation's 69 kV maximum voltage indicates it is a transmission node, but it will certainly have distribution-level voltage buses (likely 13.8 kV) to serve the local area.

The recommended interconnection path is via a 13.8 kV distribution feeder. Crucially, three-phase distribution lines appear to run directly along the site's frontage on Charlton Road. This is a major potential advantage, as it could mean a simple tap-in is possible rather than a full 1.6-mile radial line extension back to the substation. The key unknown is the available hosting capacity of this specific feeder.

Interconnection Cost & Timeline: If a direct tap to the existing feeder is possible and minimal upgrades are needed, costs could be in the $500k - $1M range. If the feeder lacks capacity and a new line from the substation is required, the cost for a 1.6-mile extension could easily range from $1.5M to $3.0M+. The interconnection process will be managed through the ISO New England (ISO-NE) queue, which is notoriously slow and complex. The total timeline from application to commercial operation can be 24-48 months. A formal Interconnection Pre-Application with National Grid is the essential next step to gain clarity on capacity, technical feasibility, and cost estimates.

4. Regulatory & Zoning Analysis

The regulatory pathway is the single greatest risk for this project. The Authority Having Jurisdiction (AHJ) is the Town of Dudley. The property is zoned RES-15 (Residential, 15,000 sq. ft. minimum lot size). A Battery Energy Storage System is not a permitted use by-right in any residential zone in Massachusetts.

The likely permitting pathway would be to seek a Special Permit from the Dudley Planning Board, potentially under a "public utility" or similar use category if one exists in the town's bylaws. If no such provision exists, a Use Variance from the Zoning