⚡ 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 for "Project Palmer"

PROPERTY: 4 BOSTON RD, Palmer, Hampden County, MA (APN: 227 3_6_1)

RECOMMENDATION: MAYBE

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a Battery Energy Storage System (BESS) at the subject property. The site possesses exceptional grid infrastructure access, a primary driver for its consideration. However, significant risks related to environmental unknowns and a lack of federal incentive adders require immediate investigation before committing further capital. The final recommendation is a conditional "MAYBE," pending the successful and economic resolution of key diligence items outlined below.

1. Site Access & Topography

Road Access: The property has direct frontage on Boston Road (U.S. Route 20), a major east-west state highway. The data indicates "Public" road access, which is confirmed by visual assessment. This high-quality, paved access is ideal for the transportation of heavy and oversized loads, including battery containers, power conversion systems (PCS), and large transformers.

Topography & Equipment Feasibility: Preliminary review of aerial imagery suggests the site is relatively flat and partially cleared, consistent with its industrial zoning and prior use. This topography is highly favorable, minimizing the need for extensive grading and civil engineering work, thereby reducing potential construction costs. The direct access from U.S. Route 20 ensures that heavy equipment, such as a 100-ton crane required for setting transformers and switchgear, can be mobilized to the site with minimal logistical hurdles or the need for temporary road improvements.

Easement Concerns: The data indicates a "POI Onsite," which strongly implies the presence of a utility right-of-way or easement on the property. While this is excellent for interconnection, a full title search is mandatory to understand the exact location, width, and restrictions associated with this and any other potential easements (e.g., access, drainage). This is a critical step to ensure the proposed BESS layout does not conflict with existing encumbrances.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This represents a critical and potentially fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would introduce significant design complexity, cost (e.g., elevating all equipment pads), and potential permit denial. Immediate verification using the FEMA Flood Insurance Rate Map (FIRM) is required.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection regulations under the Wetlands Protection Act (WPA), which typically enforces a 100-foot buffer zone ("Riverfront Area") from any delineated wetland resource area. The presence of wetlands could severely constrain the buildable area. A desktop screening using MassGIS and the National Wetlands Inventory (NWI) must be performed immediately, followed by a formal field delineation by a certified wetland scientist if the screening indicates risk.

Habitat & Species: The site is not within any designated Critical Habitat or Protected Areas, which is a significant de-risking factor. However, a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is still recommended to confirm no state-listed species or priority habitats are present.

Contamination Risk: While there are no known Brownfield/Superfund sites on the parcel itself, one is located within a 2-mile radius. This means the project is likely ineligible for the 10% IRA Brownfield tax credit adder. A Phase I Environmental Site Assessment (ESA) is a standard and necessary step to assess any risk of contaminant migration from off-site sources and to establish a baseline environmental condition.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's primary strength is its proximity to robust grid infrastructure. The Palmer Substation (115 kV) is just one mile away, and a 115 kV transmission line owned by Fitchburg Gas and Electric (a Unitil company) is located 0.6 miles away. Critically, the data states "POI Onsite," which suggests a transmission or distribution line directly traverses or is adjacent to the parcel boundary. This discrepancy (0.6 miles vs. onsite) must be clarified; an onsite POI would dramatically reduce interconnection costs