⚡ HUNTINGTON RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – HUNTINGTON RD, Russell, MA (APN: 11_3_6)

This report provides a comprehensive due diligence analysis for the subject property located on Huntington Road in Russell, Hampden County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on critical development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Huntington Road, which, based on satellite imagery of the area, is a rural, secondary road. The quality of this road is a primary concern and Requires Verification. It may be narrow, unpaved in sections, or have low weight limits, posing significant challenges for the delivery of heavy equipment. A BESS project requires multiple tractor-trailer deliveries for battery containers, inverters, switchgear, and a multi-hundred-thousand-pound main power transformer. A detailed route survey would be necessary to confirm bridge weight limits, turning radii, and overhead line clearances from the nearest state highway to the site entrance.

Terrain & Buildability: The property is situated in the Berkshire foothills, a region characterized by hilly and often steep terrain. The "Vacant Land" designation suggests the parcel is likely heavily wooded. Significant tree clearing, grading, and earthwork would almost certainly be required to create a level pad of 1-2 acres needed for a 5MW BESS facility. This will increase civil engineering costs and potentially trigger more stringent stormwater management permitting. The discrepancy in acreage between county data (12.97 acres) and Regrid data (8.44 acres) must be resolved via a formal survey, but either size is sufficient in theory if a suitable flat area exists.

Easement Concerns: Access to the most suitable buildable portion of the parcel from Huntington Road is not guaranteed. A new access road may need to be constructed on the property. Furthermore, we must verify that the property has clear, legal, and insurable frontage and access rights directly onto Huntington Road. Any shared access or private right-of-way would need to be thoroughly investigated for restrictions that could prohibit commercial/industrial traffic.

2. Environmental Constraints

Flood & Wetlands: The FEMA Flood Zone and wetlands status are listed as "Unknown." This represents a significant data gap and a primary diligence item. Given the hilly terrain and proximity to the Westfield River valley, there is a moderate risk of streams, vernal pools, or designated wetlands being present on the property. A desktop GIS analysis using MassGIS data layers is an immediate first step, to be followed by a formal wetland delineation by a certified professional if the site is pursued. Any identified wetlands will trigger significant state and local setback requirements (typically 100-200 feet), which could severely constrain the buildable area.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on the parcel, which is a positive initial finding. However, a formal review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is required to confirm there are no state-listed rare species or priority habitats that could be impacted by development.

Site Contamination: The absence of nearby brownfield or superfund sites is a net positive, reducing the risk of pre-existing contamination and simplifying the Phase I Environmental Site Assessment (ESA). However, this also means the site is ineligible for the 10% IRA Brownfield Adder, which is a financial disadvantage. There are no known pipelines or gas wells in the immediate vicinity, mitigating safety and setback concerns related to such infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Point of Interconnection (POI): This is the most critical and concerning aspect of the site. The nearest listed substation is the "TEXON HYDROELECTRIC PROJECT" at 1.6 miles. The name strongly suggests this is a small-scale generation facility, not a traditional utility distribution substation designed to serve load. It is highly unlikely to have available capacity for a new 5MW generator; in fact, it may be a point of injection on a capacity-constrained feeder. The "-999999 kV" voltage data is clearly an error, highlighting the poor quality of the initial grid data. The interconnecting utility, likely Eversource, must be contacted immediately to verify if this location is a viable POI at all. The 1.6-mile distance would require a new, dedicated feeder line to be constructed, at a significant cost likely in the range of $1.5M - $2.5M.

Transmission & Voltage: The nearest transmission line (115kV) is 3.8 miles away and noted as "NOT AVAILABLE." This distance makes a transmission-level interconnection economically unfeasible for a 5MW project. Therefore, the only plausible path is a distribution-level interconnection (e.g., 13.8kV). The project's viability is entirely dependent on the existence of a suitable three-phase distribution feeder with sufficient thermal and voltage capacity along Huntington Road or within a reasonable distance.

Interconnection Process: Interconnecting in Massachusetts falls under the ISO New England (ISO-NE) tariff. The queue is notoriously long, complex, and expensive. Even for a small distribution-connected project, the study process can take 18-24 months to reach an Interconnection Service Agreement (ISA), with significant uncertainty regarding required network upgrade costs. This timeline and cost risk is a major deterrent.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Russell. The parcel is zoned RR (Rural Residential). A BESS is an industrial utility use and is fundamentally incompatible with residential zoning. It is almost certain that BESS is not a permitted "by-right" use in this district.

Permitting Pathway: The project would require a highly discretionary and politically risky permitting pathway. This would likely involve applying for a Use Variance from the Zoning Board of Appeals, which requires proving a legal hardship, a very high bar to meet. Alternatively, a Special Permit might be possible if the town's bylaws have a provision for public utility facilities, but this is not guaranteed. Both pathways involve public hearings, notifications to abutters, and are subject to denial based on subjective criteria like neighborhood character. This presents a significant risk of vocal community opposition ("NIMBYism").

Moratorium Risk: Many small towns in Massachusetts, when faced with new energy technologies, enact temporary moratoriums to develop specific bylaws. There is a risk that a project application could trigger such a moratorium, causing extensive delays. A thorough review of the Town of Russell's zoning bylaws and recent Planning Board minutes is essential.

5. IRA/ITC Incentive Analysis

ITC Adders: The site's financial viability is severely hampered by its ineligibility for any of the location-based Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA).

• Energy Community: No
• Opportunity Zone: No
• Low-Income Community: No

6. BESS Score & Rationale

Overall BESS Suitability Score: 28 / 100

• Location (5/20): Rural location with likely challenging topography and unverified road access. Far from major load centers.
• Grid Access (3/25): Extremely poor. The only identified potential POI is 1.6 miles away and is likely not a viable substation but a small hydro plant. Transmission is not an option. This is a near-fatal flaw.
• Environmental (11/15): Appears relatively unconstrained based on initial data (no critical habitat/brownfields), but major unknowns for wetlands and floodplains remain.
• Regulatory (4/15): Highly unfavorable. Residential zoning creates a very difficult, discretionary, and high-risk permitting path with the Town of Russell.
• Incentives (0/15): Zero location-based IRA adders are available, placing the project at a 10-20% ITC disadvantage compared to better-sited projects.
• Buildability (5/10): Assumed to be challenging due to the forested and hilly nature of the site, likely