⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Investment Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 4 Boston Rd, Palmer, MA (APN: 227 3_6_1)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 4 Boston Rd, Palmer, Massachusetts. The site consists of approximately 12-22 acres (Note: Discrepancy between data sources requires verification) and presents several promising characteristics, alongside significant risks that require immediate investigation.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Boston Road (US Route 20), a major public thoroughfare. This provides excellent and straightforward access for all phases of construction and operation. US-20 is a state highway capable of handling heavy truck traffic, which is a significant advantage for the delivery of oversized and overweight equipment such as battery containers, inverters, and the main power transformer.

Terrain & Equipment Access: Based on aerial imagery and the site's location in an established industrial corridor, the topography is expected to be relatively flat and cleared, consistent with the "Good" buildability rating provided. This should minimize the need for extensive civil work and grading, reducing construction costs. Access for heavy equipment, including a 100-ton crane for setting the transformer, appears feasible directly from Boston Road.

Easement Concerns: The data indicates a "POI Onsite," which strongly suggests an existing utility right-of-way or easement crossing the property. While this is beneficial for interconnection, a full ALTA survey and title report are required to confirm the easement's boundaries, rights, and any restrictions it may impose on the placement of BESS equipment. We must also verify that our access rights from the public road to the project footprint are clear and unencumbered.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap and a primary risk. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, requiring all equipment pads to be elevated above the Base Flood Elevation (BFE), dramatically increasing civil costs. A desktop review of FEMA's Flood Insurance Rate Maps (FIRMs) is an immediate next step.

Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. The presence of jurisdictional wetlands could impose significant setbacks (typically 100-foot buffer zones) that would reduce the buildable area and could render the site infeasible. A desktop National Wetlands Inventory (NWI) screening followed by a formal field delineation by a certified wetland scientist is required.

Habitat & Species: The site is not within a designated critical habitat or protected area, which is a positive finding. However, we recommend a cross-check with the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-listed species or sensitive ecological areas are present.

Brownfield/Superfund Status: The data notes one brownfield site within a 2-mile radius. This presents both a risk and an opportunity.

• Risk: The proximity of a contaminated site raises the potential for contaminant migration onto our subject parcel. A Phase I Environmental Site Assessment (ESA) is necessary to evaluate this risk.
• Opportunity: If the subject parcel itself can be classified as a "brownfield site" under IRA guidelines (e.g., through the Phase I ESA), the project could qualify for the 10% Brownfield ITC adder. This is the only potential incentive adder identified and must be a key focus of our diligence.

Pipeline Proximity: No gas pipelines are located within a 3-mile radius, eliminating risks associated with pipeline safety setbacks and potential co-location conflicts.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site is exceptionally well-located with respect to grid infrastructure. The Palmer Substation (115 kV) is approximately 1 mile away, and a 115 kV transmission line is only 0.6 miles away. The data point of "POI Onsite" suggests a distribution feeder is likely on or adjacent to the property, running along Boston Road.

Recommended Interconnection: For a distribution-scale project (≤5MW), a transmission-level interconnection at 115 kV would be economically prohibitive. The most viable path is to interconnect to a local 3-phase distribution feeder. The utility in this area is likely National Grid or Eversource (Requires Verification). The typical distribution voltage would be in the 13.2 kV class.

Cost & Timeline Estimate: Assuming a suitable distribution feeder with available capacity is adjacent to the site, the interconnection cost could range from $750,000 to $2,000,000. This would cover the line tap, reclosers, metering, and other required utility upgrades. The interconnection process under ISO-New England can be lengthy, typically taking 24-36 months from application submission to commercial operation. Submitting a pre-application report is a critical next step to get an initial capacity screening from the utility.

Feeder Configuration: We anticipate a 3-phase overhead distribution line along Boston Road, which is typical for a commercial/industrial area. A site visit is needed to confirm the presence, configuration, and condition of this infrastructure