⚡ BETHANY RD

TO: Sunland America Corp. Investment Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 112_020, Bethany Rd, Monson, MA

This report provides a comprehensive due diligence analysis for a 5.05-acre parcel located on Bethany Road in Monson, Hampden County, Massachusetts (APN 112_020). 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 & Equipment Delivery: The subject parcel appears to have direct frontage on Bethany Road, a two-lane, paved local road. Based on aerial imagery, the road quality seems adequate for standard construction traffic. However, a formal evaluation is required to confirm its suitability for heavy-haul transportation of critical BESS components like multi-ton transformers and containerized battery enclosures. This evaluation must include a review of turning radii from main thoroughfares, overhead line clearances, and any potential weight-limited bridges or culverts on the delivery route. The lack of a formal access road onto the parcel means a new curb cut and driveway will need to be permitted and constructed, likely requiring approval from the Monson Department of Public Works.

Terrain & Site Preparation: The site is currently wooded and appears relatively flat, which is advantageous for minimizing earthwork costs. However, significant tree clearing and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. A geotechnical survey will be essential to determine soil stability, bearing capacity, and identify any potential subsurface risks (e.g., rock ledge) that could complicate foundation work and increase costs.

Easement Concerns: With direct road frontage, a dedicated access easement is likely not required. However, a full title report must be commissioned to verify this and to identify any other existing easements (e.g., utility, conservation) that could encumber the property and restrict the buildable area.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently marked as Unknown. These are critical, potentially fatal-flaw data gaps, especially in Massachusetts, which has stringent environmental regulations under the Massachusetts Wetlands Protection Act. Action Item: An immediate desktop review using FEMA's Map Service Center and the U.S. Fish & Wildlife Service's National Wetlands Inventory (NWI) is required. Any presence of FEMA-designated floodplains (e.g., Zone A, AE) or NWI-mapped wetlands would trigger significant design constraints, including elevated equipment pads, extensive permitting, and potentially large, unbuildable buffers that could render the 5.05-acre parcel insufficient for a viable project.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitat maps to ensure no state-listed species or habitats are present, which could trigger lengthy consultations and mitigation requirements.

Brownfield/Superfund Status: The presence of two brownfield/superfund sites within a two-mile radius is a moderate risk. While this does not mean the subject parcel is contaminated, it raises the possibility of migratory contamination. A Phase I Environmental Site Assessment (ESA) is a mandatory next step to assess this risk and provide liability protection. It is important to note that the site does not qualify for the 10% IRA brownfield tax credit adder unless the Phase I ESA identifies the parcel itself as a brownfield, which is currently not the case.

Other Considerations: The site is not within the Chesapeake Bay Critical Area. The absence of pipelines within a three-mile radius is a significant safety and design advantage, eliminating the need for specialized setbacks and safety studies related to pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission Infrastructure: The nearest major substation is Palmer, located 2.0 miles from the site with a maximum voltage of 115 kV. This distance is a major concern for a distribution-scale project. A 2-mile dedicated line extension (gen-tie) would be prohibitively expensive, likely costing several million dollars. The nearby 115 kV transmission line, 1.2 miles away, is noted as "NOT AVAILABLE," which is a critical red flag requiring immediate investigation with the utility. It may be at capacity or physically unsuitable for a new interconnection.

Likely Interconnection Point & Voltage: For a ≤5MW BESS, interconnection would almost certainly target a local 3-phase distribution feeder, not the 115 kV transmission system. Aerial imagery suggests distribution poles run along Bethany Road. The key unknown is the identity of the interconnecting utility (likely National Grid or Eversource in this region) and the capacity of that local feeder. The project's viability is entirely dependent on the existence of a nearby distribution line with sufficient thermal and voltage capacity to accommodate a 5MW injection/withdrawal.

Estimated Costs & Timeline: If a viable distribution feeder is adjacent to the site, interconnection costs could be in the range of $500k - $1.5M for necessary upgrades. If a new line or significant reconductoring is needed, costs will escalate rapidly. The interconnection process in ISO-New England is notoriously slow and complex; a realistic timeline from application submission to Commercial Operation Date (COD) is 24-36 months or longer.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Monson. The parcel is zoned "I" (Industrial), which is highly favorable for BESS development. Energy storage is often considered a compatible use in industrial zones, which simplifies the justification for the project.

Permitting Pathway: While the zoning is favorable, it is unlikely that a BESS project would be permitted "by-right." A review of Monson's zoning bylaws is required to determine the specific process. The most probable pathway is a Special Permit issued by the