⚡ 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 the property located at 4 Boston Road in Palmer, Hampden County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria. The site presents a compelling opportunity due to its proximity to grid infrastructure and favorable zoning, but carries significant risks related to unverified environmental and regulatory details.

1. Site Access & Topography

Site access appears to be excellent. The property has direct frontage on Boston Road (U.S. Route 20), a major public thoroughfare capable of supporting heavy truck traffic. This is critical for the delivery of large, heavy equipment such as battery containers, pad-mount transformers, and switchgear. A preliminary review of satellite imagery suggests the terrain is relatively flat and has been previously disturbed or developed, which significantly reduces the need for extensive civil work and grading. This "Good" buildability rating is a strong positive.

The primary concern is ensuring that internal site circulation can be established to move equipment from the public road to the project footprint. The delivery of a 40-ton transformer or a fully-loaded BESS container requires wide turning radii and stable ground conditions. While access from the main road is secure, a detailed logistics plan and geotechnical survey will be necessary to confirm internal access paths. The "POI Onsite" data point suggests a utility right-of-way may already exist on the property, which could streamline access for construction and operations. However, a full title search is required to confirm the extent and any restrictions associated with existing access or utility easements.

2. Environmental Constraints

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

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." The site is located approximately 0.5 miles north of the Quaboag River, elevating the risk that portions of the parcel could lie within a Special Flood Hazard Area (e.g., Zone A or AE). Any development within a designated flood zone would require extensive civil engineering, potential elevation of all equipment pads above the Base Flood Elevation (BFE), and significant permitting hurdles with the Palmer Conservation Commission and FEMA. This is a potentially fatal flaw that must be investigated immediately via FEMA's Flood Insurance Rate Map (FIRM) database.
• Wetlands: The presence of wetlands is also "Unknown." Proximity to the river and other local water bodies makes the presence of jurisdictional wetlands highly probable. Massachusetts has stringent wetland protection laws (the Massachusetts Wetlands Protection Act) with buffer zone requirements (typically 100 feet) that could sterilize a significant portion of the property and complicate the site layout. A desktop screening using the National Wetlands Inventory (NWI) is an immediate next step, to be followed by a formal wetland delineation by a certified professional if the screening indicates risk.
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• Brownfield/Superfund Status: The presence of a Brownfield/Superfund site within two miles is a double-edged sword. It poses a risk of potential contaminant migration onto our subject parcel, which must be assessed via a Phase I Environmental Site Assessment (ESA). Conversely, if our site itself can be classified as a "brownfield site" under EPA definitions (e.g., due to prior industrial use), it could qualify the project for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This represents a significant, albeit uncertain, financial upside.
• Other Constraints: The site is positively noted as having no critical habitat, protected areas, or nearby pipelines, which removes several common environmental hurdles.

3. Grid Infrastructure & Interconnection

The grid infrastructure in the immediate vicinity is a primary strength of this site. The Palmer Substation (115 kV) is only one mile away, which is an ideal distance for a distribution-level interconnection. A 115 kV transmission line is even closer at 0.6 miles. For a ≤5MW BESS, a transmission-level (115 kV) interconnection would be cost-prohibitive. The optimal path is to interconnect to a distribution feeder, likely at 13.2 kV, originating from the Palmer Substation.

The data point "POI Onsite" is extremely promising, suggesting a viable Point of Interconnection may exist on or directly adjacent to the property. This likely refers to a 3-phase overhead distribution line running along Boston Road. If this feeder has sufficient hosting capacity, interconnection costs could be relatively low, potentially in the $500,000 to $1,500,000 range, covering the line tap, switchgear, and utility-side upgrades. If a new feeder exit is required from the substation, costs could escalate to $2,000,000 - $3,500,000+.

The interconnecting utility is not explicitly named but is likely National Grid, the incumbent utility in Palmer. The interconnection process is governed by the Massachusetts Department of Public Utilities (DPU) and the ISO New England (ISO-NE) tariff. Timelines are a major industry challenge; a standard interconnection study process in Massachusetts can take 24-36 months from application to an executed Interconnection Service Agreement (ISA). Early engagement with the utility via a pre-application is critical to de-risk the project.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is the Town of Palmer. The provided zoning is "Industrial (General)," which is typically highly favorable for BESS development. Such uses