⚡ 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 site presents a compelling opportunity due to its exceptional grid infrastructure access and favorable zoning, but carries significant risks related to unverified environmental constraints and incentive eligibility. The following analysis details these factors to inform a go/no-go decision on proceeding with further development efforts.

1. Site Access & Topography

Road Access: The property has direct frontage on Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent, year-round access for all phases of development, from initial surveying to final equipment delivery.

Terrain & Equipment Feasibility: Preliminary review of aerial imagery suggests the site is relatively flat and has been previously cleared or disturbed, consistent with its industrial zoning. This topography is highly advantageous, minimizing the need for extensive grading and civil work. Access for heavy equipment, including cranes for setting transformers and battery containers, appears straightforward from Boston Road. The "Good" buildability rating in the provided data supports this assessment.

Easement Concerns: While road access is public, a full title report is a necessary next step. We must verify that there are no restrictive private access easements, utility right-of-ways, or other encumbrances that could conflict with the proposed BESS layout. The "POI Onsite" data point suggests a utility easement already exists, which must be clearly defined.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase significantly due to the need for elevated foundations and potential for project ineligibility. A FEMA FIRMette must be generated immediately.

Wetlands: Requires Verification. The presence of wetlands is also unknown. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act, which mandates significant setbacks. The presence of jurisdictional wetlands could severely constrain the buildable area, potentially rendering the 21.67-acre parcel insufficient for a viable project. A desktop screening using MassGIS and NWI data is an immediate priority, to be followed by a formal wetland delineation by a qualified consultant if the screening indicates risk.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be confirmed via a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The presence of a Superfund site within two miles is a double-edged sword. It presents a potential risk of migrating contamination, which must be assessed via a Phase I Environmental Site Assessment (ESA). However, it also raises the possibility that our subject parcel could qualify as a "brownfield site" under IRA guidelines due to historical industrial use or perceived contamination. Successfully classifying the site as a brownfield would unlock a valuable 10% ITC adder, making this a crucial point of investigation.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and design advantage, eliminating setback requirements and explosion-risk considerations associated with such infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's proximity to grid infrastructure is its strongest attribute. It is located just one mile from the Palmer Substation (max voltage 115 kV) and 0.6 miles from a 115 kV transmission line. This indicates a robust power backbone in the immediate vicinity.

Point of Interconnection (POI) & Voltage: The data point "POI Onsite" is extremely promising for a distribution-scale (≤5MW) project. This likely refers to a 3-phase distribution feeder located on or adjacent to the property, probably running along