⚡ 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 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 presents a compelling opportunity due to its exceptional proximity to grid infrastructure but carries significant regulatory and environmental risks that must be addressed immediately.

1. Site Access & Topography

The subject property benefits from direct access via Boston Road, a publicly maintained road. A preliminary desktop review suggests Boston Road is a two-lane, paved road capable of supporting heavy truck traffic. However, a detailed route survey is required to confirm the absence of low-clearance bridges, sharp turns, or weight-limited infrastructure between major highways and the site entrance. The data indicates "Buildability: Good," which implies the 21.67-acre parcel is likely characterized by relatively flat and stable terrain, common for industrial-zoned land in this region. This is advantageous for minimizing civil and earthwork costs.

The primary concern is ensuring that oversized and overweight vehicles, such as lowboy trailers carrying transformers (up to 100 tons) and containerized BESS units, can safely navigate from the highway to the site's final laydown area. The entrance to the property from Boston Road must be assessed for sufficient width and turning radius. The "POI Onsite" data suggests existing utility infrastructure, which may be accompanied by an access easement. A title search is critical to confirm the existence, terms, and location of any access or utility easements that could either facilitate or encumber development.

2. Environmental Constraints

The environmental profile of this site contains several critical unknowns that represent a high degree of risk.

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a major data gap. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing civil costs and potentially rendering the project uneconomical. A priority action is to screen the site using the FEMA Flood Map Service Center.
• Wetlands: The presence of wetlands is also "Unknown." Massachusetts has stringent wetlands protection regulations (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). The presence of jurisdictional wetlands could severely restrict the buildable area. A desktop screening using the National Wetlands Inventory (NWI) is an immediate first step, to be followed by a formal field delineation by a certified wetland scientist if any potential wetlands are identified.
• Brownfield/Superfund Status: The identification of one Superfund/brownfield site within a two-mile radius is a double-edged sword. It poses a potential risk of subsurface contamination migrating onto our parcel, which must be investigated via a Phase I Environmental Site Assessment (ESA). Conversely, if the subject parcel itself has a history of industrial use that qualifies it as a "brownfield" under EPA definitions, it could be eligible for the 10% Brownfield ITC Adder under the Inflation Reduction Act (IRA), providing a significant financial benefit.
• Other Considerations: The site is clear of critical habitats, protected areas, and nearby pipelines, which are all positive factors that de-risk the project from those specific environmental perspectives.

3. Grid Infrastructure & Interconnection

The site's primary strength lies in its outstanding proximity to grid infrastructure. The Palmer Substation (115 kV class) is only one mile away, and a 115 kV transmission line is just 0.6 miles distant. This significantly reduces the potential cost and complexity of the generator tie-line. The data point "POI Onsite" is highly encouraging, suggesting a Point of Interconnection may exist on the property itself.

For a distribution-scale project (≤5MW), the ideal scenario is to interconnect to a local distribution feeder (e.g., 13.8 kV) originating from the Palmer Substation. If a suitable three-phase feeder with sufficient thermal and voltage capacity crosses or is adjacent to the property, interconnection costs could be in the range of $1.5M - $3M. If no suitable distribution feeder is available, a transmission-level interconnection at 115 kV would be required. This would involve constructing a small, dedicated substation on-site, driving costs up dramatically (potentially $5M - $10M+) and would likely be infeasible for a 5MW project.

The interconnecting utility for Palmer is likely National Grid. The interconnection process in Massachusetts is governed by ISO New England (ISO-NE), which has a notoriously long and complex queue process. A project of this size would likely go through the state-level DPU process, but coordination with ISO-NE may still be required. We estimate a timeline of 24-48 months from application submission to commercial operation. The immediate next step is to submit a pre-application report to National Grid to confirm the presence, voltage, and available capacity of the onsite or nearby distribution feeder.

4. Regulatory & Zoning Analysis

This category presents the single greatest risk to the project. The provided data contains a critical contradiction: the zoning is listed as "Industrial (General)" but with a code of "RR," which typically denotes "Rural Residential." This discrepancy must be resolved immediately by contacting the Palmer Town Planning Department.

• If Zoned Industrial (General): This is the best-case scenario. BESS is often a permitted use (either by-right or via a Special Use Permit/Special Exception) in industrial zones. The