⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Development Team

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, for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS). The analysis identifies key site attributes, risks, and recommended next steps to determine project viability.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from direct access to Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent, high-quality access for all phases of development, from initial site visits to the delivery of heavy equipment. The road appears suitable for semi-trucks carrying battery containers, medium-power transformers, and other large-scale components without requiring significant road improvements.

Terrain & Equipment Access: Based on aerial imagery, the site appears relatively flat and cleared in the areas adjacent to the road, which is highly favorable for construction. The "Good" buildability rating in the provided data supports this initial assessment. Heavy equipment, including cranes needed for setting transformers and enclosures, should be able to access and operate on the site with standard site preparation (e.g., grading, construction of a gravel pad). There is a discrepancy in parcel size between data sources (21.67 acres vs. 12.66 acres) which must be clarified via a survey, but either size is more than sufficient for a ≤5MW BESS project.

Easement Concerns: The data indicates "POI Onsite," which suggests an interconnection point exists on the property. This would significantly reduce or eliminate the need for off-site gen-tie easements. However, a full title search is required to confirm the absence of any restrictive easements (e.g., conservation, utility right-of-way) that could encumber the proposed development area.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are both listed as "Unknown." These are critical, potentially fatal-flaw data gaps. Development within a designated flood hazard area (e.g., Zone AE) would require significant civil engineering, elevated foundations, and increased costs, potentially rendering the project non-viable. Similarly, the presence of state or federally protected wetlands would trigger significant setback requirements under the Massachusetts Wetlands Protection Act, potentially reducing the buildable area. Immediate desktop screening using FEMA and National Wetlands Inventory (NWI) maps is required.

Habitat & Protected Species: The site is not located within a designated critical habitat or protected area, which is a significant positive, reducing the risk of lengthy and complex endangered species consultations.

Brownfield/Superfund Status: The presence of a Superfund site within two miles is a moderate concern that warrants investigation in a Phase I Environmental Site Assessment (ESA) to rule out any potential for migrating contamination. Conversely, this proximity does not automatically qualify the subject parcel for the 10% IRA Brownfield tax credit adder. To qualify, the site itself must be certified as a brownfield, which would require a Phase I/II ESA to demonstrate the presence of contamination. This presents a potential opportunity but should be treated as a risk until proven otherwise.

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

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located approximately 1 mile from the Palmer Substation (115 kV max voltage) and 0.6 miles from a 115 kV transmission line. This proximity to high-capacity infrastructure is promising for grid stability but presents a challenge for a distribution-scale project.

Interconnection Recommendation: A direct 115 kV interconnection for a ≤5MW BESS is technically feasible but prohibitively expensive, likely costing over $3 million and adding years to the development timeline. The most viable path is a distribution-level interconnection (e.g., 13.2 kV). The "POI Onsite" data point strongly suggests a distribution feeder crosses or is adjacent to the property, originating from the Palmer Substation. This is the most critical technical assumption to verify.

Cost & Timeline Estimate:

• Scenario A (Distribution POI Onsite): If a 3-phase distribution feeder with sufficient capacity is confirmed on-site, interconnection costs could be in the $750,000 to $1.5 million range for protective equipment, reclosers, and minor upgrades.
• Scenario B (Transmission 115kV Tap): If a distribution feeder is not available, a transmission-level interconnection would likely cost $4 million+ and is not recommended for a project of this scale.

Feeder Configuration: The likely configuration is a 3-phase overhead distribution line running along Boston Road. A pre-application to the utility is essential to confirm the feeder voltage, available capacity, and exact POI location.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The AHJ is Palmer Town.

Zoning Compatibility: There is a critical and contradictory data point regarding zoning. The designation is listed as "Industrial (General)" but with a code of "RR," which typically stands for