⚡ 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 potential development of a Battery Energy Storage System (BESS) at the subject property. The analysis covers key siting criteria, identifies risks, and recommends next steps to determine project viability.

1. Site Access & Topography

The property benefits from public road access directly on Boston Road (Route 20), a major local thoroughfare. A preliminary review of aerial imagery indicates Boston Road is a two-lane, paved state highway capable of supporting heavy truck traffic. Access for construction and delivery vehicles appears straightforward from major highways like the I-90 Massachusetts Turnpike, which is located just south of the site. This is a significant advantage for the delivery of oversized and overweight equipment, such as main power transformers and 40-foot battery containers on low-boy trailers.

The provided "Buildability: Good" rating suggests favorable terrain. Given the location in Hampden County, the topography is likely gently rolling rather than perfectly flat. A formal ALTA/NSPS survey with 2-foot contours is required to confirm this and to plan for necessary civil work, including grading for container pads, access roads, and drainage. The 12.66-acre parcel size provides ample space for a ≤5MW project footprint, including necessary laydown areas during construction. No access easement concerns are immediately apparent due to direct frontage on a public road, but a title search is required to confirm no encumbrances exist that could restrict internal site access or access to the Point of Interconnection (POI).

2. Environmental Constraints

Environmental factors present the most significant unknowns and potential risks for this site.

• FEMA Flood Zone: The "Unknown" status is a critical data gap. Requires Verification. An immediate check of the FEMA Flood Map Service Center is necessary. If the buildable area falls within a Special Flood Hazard Area (e.g., Zone A or AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity, or potentially rendering the site undevelopable. An ideal outcome is Zone X (minimal flood risk).
• Wetlands: The "Unknown" status is another major risk. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act). Requires Verification. A desktop analysis using MassGIS OLIVER data is the first step, followed by a mandatory field-based wetland delineation by a certified professional. The presence of jurisdictional wetlands would trigger significant setbacks (typically a 100-foot buffer), which could severely constrain the buildable envelope on the 12.66-acre parcel.
• Habitat & Species: The data indicates no critical habitat or protected areas, which is a positive initial screen. However, a review of the USFWS IPaC tool and the MA Natural Heritage & Endangered Species Program (NHESP) database is still required to screen for state-listed species whose presence could trigger further consultation or mitigation requirements.
• Brownfield/Superfund: The presence of a superfund site within two miles is a moderate risk, suggesting potential for area-wide contamination. A Phase I Environmental Site Assessment (ESA) is non-negotiable to ensure no Recognized Environmental Conditions (RECs) exist on the subject parcel. Importantly, since the parcel itself is not a designated brownfield, it is ineligible for the 10% IRA brownfield tax credit adder, making this a potential liability rather than an advantage.
• Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating the need for extensive safety setbacks and risk assessments associated with such infrastructure.

3. Grid Infrastructure & Interconnection

The site's grid proximity is its strongest attribute. The likely interconnecting utility in Palmer is National Grid, and the interconnection process would be governed by ISO New England (ISO-NE).

• Substation & Transmission: The Palmer Substation (115 kV) is only one mile away, and more importantly, a 115 kV transmission line operated by FITCHBURG GAS AND ELECTRIC LIGHT COMPANY (a National Grid subsidiary) passes just 0.6 miles from the site. This proximity is excellent for a utility-scale project.
• Interconnection Strategy: Given the 115 kV line's proximity, a transmission-level interconnection is the most logical and valuable path. This avoids potential capacity constraints on local distribution feeders and allows the project to participate more fully in wholesale energy markets. While a distribution-level interconnection might be possible, the transmission tap is strategically superior.
• Cost & Timeline Estimate: A 0.6-mile 115 kV overhead line extension and the required switchyard at the project site represent a significant investment, likely in the $2.5M - $5M range. The ISO-NE interconnection queue is notoriously congested and complex; the timeline from application to commercial operation can easily be 30-48 months. Securing a queue position early is critical.
• Feeder Configuration: The interconnection would involve a direct tap to the 3-phase 115 kV transmission line, requiring the construction of a new, dedicated substation/switchyard on our parcel.

4. Regulatory & Zoning Analysis

The regulatory landscape appears favorable but requires local confirmation.

• Jurisdiction: The Authority Having Jurisdiction (AHJ) is Palmer Town. Permitting will be handled at the local level by the Planning Board and/or Zoning Board of Appeals (ZBA).
• Zoning Compatibility: The parcel is zoned "Industrial (General)". This is highly advantageous, as BESS is typically considered an industrial or public utility use. While the "RR" code in the data is confusing (often meaning Rural Residential), the "Industrial (General)" description should take precedence. Requires Verification.
• Permitting Pathway: It is unlikely that BESS is a by-right use. The most probable pathway is a Special Permit from the Palmer Planning Board. This process involves public hearings and discretionary review. A pre-application meeting with the Town Planner is essential to confirm the process, understand local sentiment, and identify specific application requirements (e.g., noise studies, decommissioning plans, fire safety plans).
• Risks: We must verify that Palmer Town does not have a moratorium on BESS development, as several Massachusetts municipalities have enacted them. A review of recent town meeting minutes and bylaws is a critical next step. Setback requirements specific to BESS must also be confirmed in the town's zoning code.

5. IRA/ITC Incentive Analysis

The project's eligibility for IRA tax credit adders is extremely poor based on the provided data, which significantly impacts its economic viability.