⚡ FRENCH DR

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 039 36_28 (French Dr, Boylston, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project on a 5.39-acre parcel on French Drive in Boylston, Worcester County, Massachusetts. The analysis concludes that despite being vacant land, the site faces critical, likely insurmountable challenges related to grid access, zoning, and financial incentives, making it unsuitable for development.

1. Site Access & Topography

Road Access: The property has frontage on French Drive, a paved, two-lane local residential road. While the road itself appears capable of handling standard construction traffic, its narrowness and residential character may pose challenges for oversized/overweight loads like transformers or pre-fabricated control houses. A formal route study would be required.

Terrain & Site Access: Based on aerial imagery and regional topography, the parcel is heavily wooded and appears to have a moderate to significant slope. Substantial tree clearing, grading, and civil work would be required to create a level pad for the BESS equipment. Access from French Drive onto the parcel itself is currently undeveloped. A new, graded access road would need to be constructed, potentially requiring significant cut-and-fill operations, which will increase civil costs.

Heavy Equipment Feasibility: The primary concern is not the public road but the on-site access. The slope and undeveloped nature of the parcel present a high risk for delivering and placing heavy equipment like 40-foot battery containers and a main power transformer. The feasibility and cost of creating a stable, accessible construction entrance and equipment pad are significant unknowns that negatively impact the site's viability.

Easement Concerns: While the parcel appears to have direct frontage, the usable width of this frontage may be limited. Requires Verification: A title search and survey are needed to confirm no access easements are required across neighboring properties and to ensure the frontage is adequate for a commercial-grade entrance.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." This is a critical data gap. Given the site's sloped topography, it is likely located in Zone X (minimal flood risk), but this must be confirmed immediately via the FEMA Map Service Center. Any designation other than Zone X would introduce significant design constraints and potential permitting hurdles.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has extremely stringent wetland protection regulations (Massachusetts Wetlands Protection Act). A desktop review using MassGIS OLIVER is the immediate first step, but a formal wetlands delineation by a certified professional will be required. The presence of jurisdictional wetlands could drastically reduce the buildable area and impose significant setbacks (typically 100 feet), potentially rendering the site unusable. This is a major risk.

Habitat & Species: The site is not within a designated critical habitat or protected area. However, a query of the MA Natural Heritage & Endangered Species Program (NHESP) database is recommended to confirm there are no state-listed rare species or priority habitats present that could trigger a lengthy review process.

Brownfield/Superfund Status: The site has no known brownfield or superfund history. While this avoids environmental liability, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant financial disadvantage.

Pipeline Proximity: No major gas transmission pipelines are located near the site, which eliminates a significant safety, setback, and co-location risk.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation (WEST BOYLSTON) and the nearest transmission line (115kV) are both located approximately 1.9 miles from the parcel. This distance is a fatal flaw for a distribution-scale (≤5MW) project.

Recommended Interconnection: For a project of this size, the only economically viable interconnection is to a local 3-phase distribution feeder (e.g., 13.8kV). A 1.9-mile line extension to the substation would be cost-prohibitive, likely exceeding $2-4 million. A transmission-level (115kV) interconnection is not technically or financially feasible for a 5MW BESS.

Feeder & Utility: Requires Verification: A critical investigation is needed to determine if any 3-phase distribution lines exist closer to the site than the substation. A preliminary review of aerial imagery suggests French Drive may only have single-phase power, typical for residential areas. The interconnecting utility is likely National Grid, but this must be confirmed. The interconnection process in Massachusetts under National Grid and ISO-NE is notoriously slow and backlogged, with timelines often exceeding 24-36 months.

Cost & Timeline Estimate: Assuming a 3-phase distribution line could be found within 0.5 miles, interconnection costs would still likely be in the $500k - $1M range. With the nearest known point being 1.9 miles away, the cost is non-viable. The timeline remains a significant risk regardless of distance.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Boylston.

Zoning Compatibility: The parcel is zoned for