⚡ 4 BOSTON RD

BESS SITE DILIGENCE ANALYSIS REPORT

To: Sunland America Corp. Development Committee

From: Senior BESS Site Evaluation Analyst

Date: October 26, 2023

Subject: Comprehensive Site Analysis for 4 BOSTON RD, Palmer, MA (APN: 227 3_6_1)

This report provides a comprehensive due diligence analysis for the subject property in Palmer, Massachusetts, for its potential as a distribution or utility-scale Battery Energy Storage System (BESS) project. The analysis is based on the initial data provided and identifies key strengths, weaknesses, risks, and recommended next steps.

1. Site Access & Topography

Road Access: The property has public road access directly on Boston Road, which appears to be US Route 20, a major state highway. This is a significant advantage, providing excellent, all-weather access for construction crews, standard vehicles, and oversized/overweight deliveries.

Equipment Delivery: Access from a major US Route should readily accommodate the delivery of heavy and large equipment, including battery containers (megapacks/powerblocks), pad-mount transformers, and large cranes required for installation. A detailed route survey will be necessary, but initial indicators are highly positive.

Topography & Buildability: While a formal topographic survey is required, the "Good" buildability rating and satellite imagery of the area suggest the terrain is likely manageable, with relatively flat or gently sloping characteristics suitable for BESS development. Hampden County can be hilly, but this specific parcel appears favorable. Minimal grading may be required, reducing civil construction costs. The discrepancy between the listed 21.67 acres and the Regrid data of 12.66 acres must be clarified via a survey and title review.

Easement Concerns: The data indicates "POI Onsite," which, if accurate, drastically reduces the need for off-site access or utility easements for a gen-tie line. However, we must verify the exact location of the Point of Interconnection and review a title report for any existing utility easements (e.g., for the 115kV line) or access restrictions that could constrain the site layout.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap and a potential fatal flaw. Siting critical infrastructure in a Special Flood Hazard Area (e.g., Zone AE) would require elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. An immediate desktop FEMA map review is required.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection laws under the Wetlands Protection Act. A desktop review using the National Wetlands Inventory (NWI) is the first step. If potential wetlands are identified, a formal wetland delineation will be mandatory. The presence of jurisdictional wetlands could significantly reduce the buildable area due to required 100-foot buffer zones and 25-foot no-disturb zones.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a strong positive. This should be verified with the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The presence of one brownfield site within two miles is a key finding. A Phase I Environmental Site Assessment (ESA) is non-negotiable to determine if our parcel is impacted by contamination from this nearby site or has its own unrecognized environmental conditions. Crucially, if our parcel itself can be classified as a brownfield (per 42 U.S.C. § 9601(39)), it would qualify for the 10% IRA Energy Community tax credit adder. This transforms a potential risk into a significant financial opportunity.

Pipeline Proximity: No gas pipelines within a three-mile radius is a major safety and design advantage, eliminating concerns related