⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Palmer, MA (APN: 3_6_1)

This report provides a comprehensive due diligence analysis for the property located at 4 Boston Road in Palmer, Hampden County, Massachusetts. The site consists of approximately 12-22 acres of land zoned for industrial use. The analysis evaluates the property'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 property has frontage on Boston Road (U.S. Route 20), a major, publicly maintained thoroughfare. This provides excellent and direct access for all phases of construction and operation. The quality of the road is more than sufficient for heavy haul trucks carrying battery containers, medium-voltage transformers, and switchgear. No significant road upgrades are anticipated.

Terrain & Site Maneuverability: Given the "Industrial (General)" zoning and "Good" buildability rating, the site is presumed to be relatively flat, level, and potentially previously graded. This is highly advantageous, minimizing civil engineering costs associated with site preparation. However, a formal topographic survey is required for verification. Assuming favorable terrain, access for heavy equipment, including a 100-ton crane for setting transformers, appears feasible without major issue.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests an existing utility easement is present along the property's road frontage. This is a positive factor, but the specific terms, width, and restrictions of this easement must be verified through a title search. We must ensure there are no restrictions that would prevent the installation of our BESS facility or its associated collection lines. A title report is a critical next step to identify any other access, drainage, or restrictive easements that could impact the site layout. There is a notable discrepancy in listed acreage (21.67 vs 12.66 acres) which must be resolved via survey and title review.

2. Environmental Constraints

This category presents the most significant unknowns and potential risks for the project.

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap. Any location within a 100-year floodplain (e.g., Zone A, AE) would introduce substantial design challenges, requiring all equipment to be elevated above the Base Flood Elevation (BFE). This would dramatically increase civil and structural costs and could be a fatal flaw. Verification via FEMA's Flood Insurance Rate Maps (FIRMs) is an immediate priority.
• Wetlands: The presence of wetlands is "Unknown." Massachusetts has some of the most stringent wetlands regulations in the country under the Massachusetts Wetlands Protection Act (WPA). Development is heavily restricted within 100 feet of a designated wetland (the "Buffer Zone"). A desktop screening using MassGIS and the National Wetlands Inventory (NWI) is the first step, but a formal wetland delineation by a certified professional will be required to confirm the absence or extent of wetlands and their associated buffers, which could severely limit the buildable area.
• Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be verified with a query of the U.S. Fish and Wildlife Service's IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state or federally listed species have habitats that overlap with the project area.
• Brownfield/Superfund Status: The presence of a brownfield site within 2 miles is a dual-edged sword. It indicates a potential risk of on-site contamination from historical industrial activity in the area, mandating a Phase I Environmental Site Assessment (ESA) immediately. Conversely, if our specific parcel can be classified as a brownfield (defined as a property where expansion or redevelopment is complicated by the presence or potential presence of a hazardous substance), it would qualify the project for the 10% ITC Brownfield Adder. The Phase I ESA is critical to both mitigate risk and explore this significant incentive opportunity.
• Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and layout de-risking factor.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site is in a strong location relative to grid infrastructure. It is 1 mile from the Palmer 115 kV Substation and 0.6 miles from a 115 kV transmission line. However, for