⚡ BAKER PASS

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – BAKER PASS, Fitchburg, MA (APN: 86-2-0)

This report provides a comprehensive due diligence analysis for the property located at Baker Pass in Fitchburg, Worcester County, MA. The 2.39-acre parcel presents a potentially strategic location due to its proximity to grid infrastructure, but carries significant environmental and regulatory risks that must be thoroughly investigated. The following analysis details the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project.

1. Site Access & Topography

Road Access & Equipment Delivery: Preliminary review via satellite imagery indicates the site has direct frontage on Baker Pass, which connects to John Fitch Highway (Route 2A), a major commercial and arterial road. This suggests excellent existing road access suitable for construction traffic and the delivery of heavy equipment. The quality of Baker Pass itself appears to be paved and sufficient for tractor-trailers carrying battery containers, inverters, and the main power transformer. A formal route survey is required to confirm bridge weight limits, turning radii, and overhead line clearances from the nearest port or manufacturing hub.

Terrain & Buildability: The parcel appears to be relatively flat and cleared, consistent with its "Commercial-Vacant Land" designation. This topography is highly advantageous, as it will minimize grading costs and site preparation complexity. The 2.39-acre size is adequate but potentially tight for a 5MW BESS project once setbacks, stormwater management infrastructure, and construction laydown areas are considered. A conceptual site layout is a critical next step to confirm fit.

Heavy Equipment & Easements: Feasibility for delivering and placing multi-ton transformers and containerized BESS units appears high due to the flat terrain and direct road access. However, a key unknown is the presence of any existing utility or access easements crossing the property. A title search is mandatory to identify any such encumbrances that could restrict the buildable envelope and compromise the project layout.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: Requires Verification. The FEMA flood zone and wetlands status are currently unknown and represent the most significant potential fatal flaws for this site. Any designation within a 100-year floodplain (e.g., Zone A, AE) would likely render the project infeasible or require cost-prohibitive mitigation. Similarly, the presence of state-jurisdictional wetlands under the Massachusetts Wetlands Protection Act could impose 100-foot or greater buffer zones, severely constraining the usable acreage on this 2.39-acre lot. An immediate desktop screening using FEMA and National Wetlands Inventory (NWI) maps is the highest priority.

Brownfield/Superfund Status: The data indicates a high concentration of 41 brownfield or superfund sites within a 2-mile radius, suggesting a history of industrial activity in the area. This presents both a risk and an opportunity.

• Risk: The subject parcel itself could have legacy contamination, which would introduce significant liability and potential remediation costs.
• Opportunity: If the site can be officially classified as a "brownfield site" per IRA guidelines, the project would be eligible for a 10% ITC adder. This is a critical potential enhancement to project economics. A Phase I Environmental Site Assessment (ESA) is non-negotiable to assess contamination risk and determine eligibility for the tax credit.

Other Constraints: The site shows no risk related to critical habitats, protected areas, or proximity to gas pipelines, which are all positive findings. The project is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Interconnection Point (POI): The site is located approximately 0.5 miles from the Pleasant Street Substation. This proximity is excellent and is the site's strongest attribute, as it dramatically reduces the potential cost and complexity of the generator lead line. The utility is presumed to be National Grid, which serves the Fitchburg area.

Voltage & Capacity: Requires Verification. The provided substation voltage data (-999999 kV) is an error. We assume the substation serves standard distribution voltages, likely 13.8 kV. The available capacity at the substation and on the specific distribution feeder that would serve the project is the single most important technical unknown. A lack of capacity would trigger costly substation upgrades, potentially killing the project's economic viability. The nearest transmission line (115kV at 3.1 miles) is too distant to be a feasible POI for a project of this scale.

Interconnection Recommendation & Costs: The recommended pathway is a distribution-level interconnection to a 13.8 kV (or similar) feeder from the Pleasant Street Substation. Assuming no major substation upgrades are required, the interconnection cost for the 0.5-mile tie-in is estimated to be in the range of $750