⚡ 98 SGT TM DION WAY

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 98 SGT TM DION WAY, Westfield, MA (APN: 51_R_4)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis covers key site attributes, constraints, risks, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access & Equipment Delivery: The site is located on Sgt T M Dion Way, which appears to be a paved, industrial park-style road based on aerial imagery. Access from major thoroughfares like the I-90 (Massachusetts Turnpike) appears straightforward. The road seems sufficiently wide to accommodate lowboy trailers for delivering large equipment, including 40-foot BESS containers and the main power transformer. Requires Verification: A site visit is necessary to confirm the absence of low-clearance bridges, tight turning radii, or weight-limited roads on the haul route.

Terrain & Site Characteristics: The parcel is in an established industrial area. Based on aerial review, the site appears to be cleared, graded, and relatively flat, which is highly advantageous for minimizing civil engineering costs. The 2.25-acre parcel size is adequate for a 5MW BESS project, which typically requires 1-1.5 buildable acres, but could become constrained after accounting for all setbacks.

Heavy Equipment Access: On-site access for heavy equipment such as a 100-ton crane for transformer placement appears feasible, assuming the site's geotechnical properties are sufficient. The flat topography and existing road access are significant positives. A geotechnical survey will be required to confirm soil bearing capacity.

Easement Concerns: The property has direct frontage on Sgt T M Dion Way, so an access easement is unlikely to be required. However, a full title report is a critical next step to identify any utility easements (e.g., for gas, water, or existing electrical lines) that may cross the property and sterilize portions of the buildable area.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is listed as "Unknown." This is a critical data gap. A preliminary desktop review using the FEMA Flood Map Service Center is an immediate priority. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development costs could increase substantially due to requirements for elevating all equipment above the Base Flood Elevation, and the project may be un-permittable or un-insurable. This represents a potential fatal flaw.

Wetlands: The presence of wetlands is "Unknown." A desktop screen using the USFWS National Wetlands Inventory (NWI) is required immediately. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), often requiring 100-foot buffer zones from designated resource areas. The presence of wetlands could severely limit the buildable area on this 2.25-acre parcel. A formal wetland delineation by a certified professional will be necessary if any indicators are present.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This should be confirmed via the USFWS IPaC tool and a query to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) as part of formal due diligence.

Brownfield/Superfund Status: The presence of five known contaminated sites within a two-mile radius presents both a risk and a major opportunity.

• Risk: Potential for contaminant migration onto the subject property. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk.
• Opportunity: If the Phase I ESA identifies Recognized Environmental Conditions (RECs) on our parcel, it could potentially be classified as a "brownfield site." This would make the project eligible for the 10% Brownfield ITC Adder under the Inflation Reduction Act (IRA), a significant financial benefit.

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