⚡ PROSPECT ST EXT

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 40_R_48 (Prospect St Ext), Westfield, MA

This report provides a comprehensive due diligence analysis for the 19.57-acre property located on Prospect St Ext in Westfield, Hampden County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access: The property is accessed via "Prospect St Ext," which suggests an unimproved or private extension of a public road. Initial desktop review of satellite imagery indicates this is likely a narrow, unpaved or gravel road. This presents a significant challenge for construction. The quality and legal status of this access are critical unknowns.

Topography & Feasibility: As a forested, undeveloped parcel in Western Massachusetts, the terrain is likely to be uneven with moderate slopes and significant tree cover. Extensive clearing, grading, and civil work would be required to create a level pad for BESS containers, transformers, and switchgear. The current access road may be incapable of supporting the weight and turning radius of heavy construction vehicles, including low-boy trailers for transformers and flatbeds for battery containers. A full geotechnical survey and civil engineering assessment would be mandatory.

Easement Concerns: The "Extension" designation raises immediate red flags regarding legal access. We must verify if a deeded, all-weather access easement exists for commercial/industrial use. If the road crosses other private parcels, securing upgraded access rights could be costly and time-consuming, or impossible. This is a potential fatal flaw.

2. Environmental Constraints

Flood & Wetlands: FEMA flood zone and wetland presence are currently unknown. Given the site's undeveloped, forested nature in New England, there is a high probability of wetlands, streams, or vernal pools being present. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet) that could severely restrict or eliminate the buildable area. A full wetland delineation is a critical and immediate next step.

Brownfield/Superfund Status: The presence of five brownfield or superfund sites within a two-mile radius is a double-edged sword. It introduces a risk of potential soil or groundwater contamination on our target parcel, which would require costly remediation. However, if the site itself qualifies as a "brownfield" under EPA definitions (even if only minimally contaminated), it could be eligible for the 10% ITC adder under the Inflation Reduction Act (IRA). This requires a Phase I Environmental Site Assessment (ESA) to confirm.

Habitat & Other Factors: The site is clear of designated critical habitats and protected areas, which is a significant positive. It is outside the Chesapeake Bay Critical Area, and no pipelines are in the immediate vicinity, reducing safety and setback concerns.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation (UNKNOWN133472) is 0.9 miles away with a 115kV maximum voltage. A 115kV transmission line is located 0.5 miles from the site. Interconnecting a ≤5MW BESS at transmission voltage (115kV) is economically non-viable. The costs for a new switchyard bay, high-voltage equipment, and a 0.5-mile gen-tie line would likely exceed $4-6 million, rendering the project unprofitable.

Distribution Feeder & Utility: The project's viability is entirely dependent on the presence of a suitable 3-phase distribution feeder (e.g., 13.8kV) adjacent to or crossing the property. Requires Verification. The interconnecting utility is likely Westfield Gas & Electric (WG+E), a municipal light plant (MLP). Interconnecting with an MLP involves a different process than with an investor-owned utility (IOU). While sometimes faster, their capacity study processes can be less transparent and their hosting capacity on specific feeders is a major unknown.

Cost & Timeline: If a viable distribution feeder with adequate capacity is not directly adjacent to the site, interconnection costs could still be substantial ($500k - $1.5M+ for a line extension). The WG+E interconnection queue timeline is unknown and must be investigated. The lack of an identified, viable Point of Interconnection (POI) at distribution voltage is a primary risk factor.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Westfield. The parcel's zoning is listed inconsistently as "Vacant Land - Private Preserve, Open Space-Vacant Land" and "RR" (Rural Residential). Both are highly problematic for BESS development.

Permitting Pathway:

• Private Preserve / Open Space: This designation is a potential fatal flaw. It often implies conservation restrictions that would prohibit this type of development entirely.
• Rural Residential (RR): BESS is not a by-right use in any residential zone. The project would require, at a minimum, a Special Permit from the Planning Board and likely a Use Variance from the Zoning Board of Appeals (ZBA). This is a discretionary, lengthy, and high-risk process with significant potential for public opposition.

Risks & Requirements: Massachusetts has rigorous safety standards for BESS, referencing NFPA 855. A detailed fire safety and emergency response plan will be required. The "Private Preserve" designation must be clarified immediately with the Westfield Planning Department, as it could represent a complete moratorium on development for this parcel.