⚡ JARVIS AVE

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for JARVIS AVE, Holyoke, MA (APN: 146-00-016)

This report provides a comprehensive due diligence analysis for the subject property located on Jarvis Ave in Holyoke, Hampden County, Massachusetts, for its potential as a distribution or utility-scale Battery Energy Storage System (BESS) site. The analysis concludes that while the site benefits from a key federal incentive, it faces severe, potentially fatal flaws related to zoning, grid access, and physical buildability.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Jarvis Avenue, a paved but relatively narrow residential street. Initial desktop review suggests the parcel itself may be landlocked or possess very limited, undeveloped frontage. This presents a critical risk for both construction and operational access. The feasibility of delivering heavy equipment, such as 53-foot battery containers, a power conversion system (PCS) skid, and a multi-ton main power transformer, is highly questionable. The route from major highways to the site must be surveyed for turning radii, bridge weight limits, and overhead power line clearances. The current access appears insufficient for heavy industrial transport.

Terrain & Buildability: Located in the variable terrain of the Pioneer Valley, the site is heavily wooded and appears to have significant topographic relief. Substantial tree clearing and grading will be required, increasing site preparation costs and potentially triggering additional environmental review. The discrepancy between the listed 34.66 acres and the Regrid parcel data of 18.21 acres must be resolved via a formal survey. The actual buildable area, after accounting for slopes and environmental setbacks, is likely a small fraction of the total acreage.

Easement Concerns: A primary risk is the potential need to acquire a new, permanent access and utility easement from one or more neighboring property owners. Negotiating such easements can be prohibitively expensive, time-consuming, and ultimately unsuccessful, creating a fatal flaw for the project. A title search is immediately required to confirm the existence and scope of any legal access.

2. Environmental Constraints

Flood & Wetlands: The FEMA flood zone and wetlands status are currently unknown. These are critical data gaps. Given the site's undeveloped nature, the presence of state-jurisdictional wetlands under the Massachusetts Wetlands Protection Act is highly probable. This would trigger significant buffer requirements (typically 100 feet), which could severely constrain the site layout and reduce the buildable envelope. A desktop screening using FEMA and National Wetlands Inventory (NWI) maps is an immediate next step, to be followed by a formal field delineation if the project proceeds.

Habitat & Species: While initial data shows no critical habitat, this requires verification with the MA Natural Heritage & Endangered Species Program (NHESP). The wooded nature of the site could provide habitat for protected species, potentially requiring time-of-year restrictions on clearing or other mitigation measures.

Brownfield/Superfund Status: The presence of 10 known contaminated sites within a two-mile radius is a concern that necessitates a Phase I Environmental Site Assessment (ESA) to rule out on-site contamination. However, this also presents an opportunity. If the subject property itself can be classified as a "brownfield site" under federal definitions (e.g., through the Phase I ESA), the project would qualify for the 10% IRA Brownfield tax credit adder. This is a significant potential upside that warrants investigation.

Other Considerations: The site is not within the Chesapeake Bay Critical Area. The lack of pipelines within a three-mile radius is a positive, eliminating a common safety and setback constraint.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The nearest identified substation is 2.3 miles away and has a 115 kV bus. For a distribution-scale project (≤5MW), this distance is a major economic barrier. A 2.3-mile primary distribution line extension could easily cost between $2 million and $4 million, rendering a small project financially non-viable. The nearby 115 kV transmission line is noted as "NOT AVAILABLE" for interconnection, reinforcing that a distribution-level tie-in is the only plausible path.

Recommended Interconnection: The recommended pathway is a 13.8 kV (or similar) distribution-level interconnection. The immediate priority must be to identify the local utility (likely Eversource or the municipal Holyoke Gas & Electric) and obtain distribution feeder maps to search for a three-phase circuit closer to the property than the substation. Without a significantly closer Point of Interconnection (POI), this site is not feasible.

Cost, Timeline & Utility Process: Interconnection in ISO-New England is notoriously slow and expensive. The formal study process can take 18-24 months to complete, with significant uncertainty regarding required network upgrade costs. The utility-specific process must be confirmed, as a municipal utility may have different standards and timelines than an investor-owned utility like Evers