⚡ LOMBARD RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for Lombard Rd, Chicopee, MA (APN: 0270_00006)

This report provides a comprehensive due diligence analysis for the subject property located on Lombard Road in Chicopee, Hampden County, Massachusetts, for its potential as a Battery Energy Storage System (BESS) site. The analysis concludes with a suitability score, a summary of key risks, and recommended next steps.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has frontage on Lombard Road, which appears to be a two-lane, paved local road. While seemingly adequate for initial access, a detailed route survey is required to confirm its suitability for heavy haul trucks carrying multi-ton transformers and battery containers. Key points for verification include turning radii, overhead line clearances, and any weight-limited bridges or culverts between the site and major highways (e.g., I-90, I-391). A temporary construction entrance with a stabilized apron will be required off Lombard Road, subject to a permit from the Chicopee Department of Public Works.

Terrain & Buildability: Based on aerial imagery, the parcel is heavily wooded and appears relatively flat, which is favorable for minimizing civil work. However, the presence of mature trees will necessitate significant clearing and grubbing costs. A formal ALTA/topographical survey is essential to confirm the lack of significant grade changes and to identify the optimal location for the BESS pad. The large parcel size (conflicting data between 46 and 12.8 acres requires clarification) should provide flexibility in siting the project to avoid site constraints.

Easement Concerns: Requires Verification. A full title report must be obtained to identify any existing utility easements, access rights-of-way, or restrictive covenants that could encumber the property and limit the buildable area. Given the proximity to major transmission infrastructure, existing utility easements are highly probable.

2. Environmental Constraints

Flood & Wetlands: Requires Verification. The FEMA flood zone and presence of wetlands are currently unknown. These are critical, potentially fatal-flaw data gaps. Given the site's undeveloped, wooded nature in Massachusetts, the presence of state or federally regulated wetlands is highly likely. A wetland delineation will be required to determine their boundaries. Any development will be subject to significant setbacks (typically 100 feet in MA) from wetland resource areas, which could severely constrain the buildable envelope. Siting equipment within a FEMA-designated flood zone would require elevating all pads and control houses above the Base Flood Elevation, adding substantial cost and complexity.

Habitat & Species: The initial screening shows no designated critical habitats on site, which is a positive indicator. However, this must be formally verified by submitting a project review request to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed rare species or their habitats are present.

Contamination Risk: The presence of a brownfield/superfund site within two miles represents a low-to-moderate risk of potential contamination. A Phase I Environmental Site Assessment (ESA) is a mandatory next step to confirm no Recognized Environmental Conditions (RECs) exist on the subject parcel. This is currently viewed as a risk, not an advantage; the site itself is not designated as a brownfield, so it is not eligible for the 10% IRA brownfield tax credit adder.

Other Constraints: The site is not within the Chesapeake Bay Critical Area. No pipelines or gas wells are in the immediate vicinity, eliminating significant safety and setback concerns from those sources.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The site's primary asset is its exceptional proximity to robust grid infrastructure. The Shawinigan Switching Station, an Eversource asset with a maximum voltage of 115 kV, is located only 0.8 miles away. This is an ideal POI for a utility-scale BESS project.

Interconnection Strategy & Cost: The recommended path is a transmission-level interconnection at 115 kV. This will involve constructing a 0.8-mile overhead or underground gen-tie line to the switching station. The interconnection process will be governed by ISO New England (ISO-NE) and the connecting transmission owner, Eversource. This is a complex and lengthy process, typically taking 24-48 months from application to commercial operation. Preliminary, high-level cost estimates for a 115 kV interconnection at this distance, including the gen-tie, substation upgrades, and required studies, would likely fall in the $4M - $9M range. A detailed feasibility study is required to refine this estimate.

Distribution Alternative: For a smaller, distribution-scale project (≤5MW), an investigation into available 13.8 kV or similar distribution feeders from the Shawinigan station or along local roads would be necessary. This could potentially offer a faster and cheaper interconnection, but capacity is often limited. Given the site's potential, the transmission-level interconnection should be the primary focus.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Chicopee. The zoning data is conflicting, listed as "Private Preserve, Open Space" and also "RESA" (likely Residence A). Neither of these zoning designations would permit a BESS project "by-right." This represents the single greatest non-financial risk to the project.

Permitting Pathway: Development will require discretionary approval from the city. The most likely pathway is a Special Permit from the Chicopee City Council or Zoning Board of Appeals, and potentially a zoning variance. This process is public, subjective, and carries significant risk of denial due to community opposition ("NIMBYism"). The project will need to demonstrate a clear benefit to the community and proactively address concerns regarding safety, noise, and visual impact.

Regulatory Risks: We must immediately verify if Chicopee has any specific ordinances related to BESS or a moratorium on their development, which has become more common in Massachusetts municipalities. The project will need to comply with all state-level requirements, including the Massachusetts Fire Prevention Regulations (527 CMR 1.00) which incorporates NFPA 855 for BESS safety.

5. IRA/ITC Incentive Analysis

This site performs very poorly on federal incentive criteria, which significantly impacts project economics.

• Opportunity Zone: No. (0% Adder)
• Energy Community: No. (0% Adder)
• Low-Income Community: No. (0% Adder)

Potential Cumulative ITC: 30%. The project is only eligible for the base 30% Investment Tax Credit, assuming prevailing wage and apprenticeship labor requirements are met. The lack of any 10% or 20% adders makes this site financially less competitive than sites that qualify for these bonuses. Project viability will depend heavily on state-level incentives (e.g., Clean Peak Energy Standard) and favorable market revenue streams.

6. BESS Score & Rationale

Overall BESS Suitability Score: