⚡ MEADOW RD

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for MEADOW RD, Spencer, MA (APN: U21-65)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale Battery Energy Storage System (BESS) on a 2.9-acre parcel located on Meadow Road in Spencer, Worcester County, Massachusetts. The analysis covers key site attributes, constraints, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access: The property is located on "Meadow Rd." The quality and legal status of this road are currently unknown and represent a critical data gap. A desktop review using satellite imagery suggests Meadow Road is a secondary, likely unpaved or poorly maintained road. This raises significant concerns for the delivery of heavy equipment.

Equipment Delivery: Delivery of BESS equipment involves oversized and overweight loads, including 40-foot battery containers, multi-ton transformers, and large cranes for placement. The feasibility of navigating these vehicles on a narrow, potentially unpaved rural road is highly questionable. A detailed route survey and a site visit are mandatory to assess turning radii, road width, load-bearing capacity of any culverts or small bridges, and overhead line clearances.

Topography: While a formal survey is required, the general topography of Worcester County is characterized by rolling hills. The site will likely have some grade changes, which could increase civil engineering and site preparation costs. A flat, graded pad of approximately 1-1.5 acres will be required for a 5MW BESS, and achieving this on a 2.9-acre sloped parcel could be challenging and costly.

Easement Concerns: It is critical to verify that Meadow Road is a public right-of-way with legal access to the parcel. A title report must be ordered immediately to confirm access rights. If access is via a private road, a formal, permanent access easement capable of supporting heavy commercial traffic must be negotiated and secured from all relevant landowners, which can be a costly and time-consuming process.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is unknown. This is a fatal flaw risk that must be resolved immediately via a FEMA FIRMette map review. Any portion of the site within a 100-year floodplain (Zone A/AE) would likely be undevelopable for critical electrical infrastructure or would require significant and expensive mitigation measures (e.g., raising equipment on platforms), making the project economically unviable.

Wetlands: The presence of wetlands is unknown. Given the parcel's location in Massachusetts, it is highly probable that wetlands or vernal pools are present. The Massachusetts Wetlands Protection Act imposes stringent regulations, including significant buffer zones (typically 100 feet). On a small 2.9-acre parcel, the presence of wetlands could easily reduce the buildable area to zero. A desktop National Wetlands Inventory (NWI) screening followed by a formal wetland delineation by a certified professional is a critical and immediate next step.

Critical Habitat / Species: The data indicates no critical habitat on site, which is a positive initial finding. However, this should be verified with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are impacted.

Brownfield/Superfund Status: The presence of five brownfield/superfund sites within a two-mile radius is a double-edged sword. It introduces a risk that our target parcel could have legacy contamination requiring remediation. However, it also presents a significant opportunity. If this specific parcel can be classified as a "brownfield site" under IRA guidelines, the project would be eligible for a 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is required to assess both the risk of contamination and the potential for securing this valuable incentive.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating setback constraints and explosion-risk concerns.

3. Grid Infrastructure & Interconnection

Substation & POI: The MEADOW ROAD substation is located 1.1 miles from the site, with a maximum voltage of 69 kV. This is an ideal distance for a distribution-scale project. The Point of Interconnection (POI) would not be at the 69 kV bus but rather on a distribution feeder (e.g., 13.2 kV) originating from the substation. The 1.1-mile distance will require a line extension, the cost of which will be substantial.

Interconnecting Utility: Requires Verification. The utility is likely National Grid or potentially the Spencer Municipal Light Plant. Identifying the correct utility is a top priority, as it dictates the entire interconnection process, cost structure, and timeline.

Interconnection Cost & Timeline: A 1.1-mile, 3-phase overhead distribution line extension could range from $1.0M to $2.5M, depending on terrain, pole requirements, and road crossings. Undergrounding would be significantly more expensive. In the ISO-NE territory, the interconnection process is notoriously long and complex. From application to Commercial Operation Date (COD), a timeline of 24-48 months should be anticipated. A formal interconnection application is necessary to determine if the local feeder and substation have sufficient capacity to accommodate a 5MW injection without requiring costly upgrades.

Feeder Configuration: We must assume the project will require a new dedicated 3-phase feeder extension from the nearest existing 3-phase line or directly from the substation. A feeder map from the utility is essential.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Spencer, Massachusetts.

Zoning Compatibility: The parcel is zoned RR (Rural Residential). This is a major impediment. BESS is an industrial/utility use and is fundamentally incompatible with residential zoning. It is highly unlikely to be