⚡ 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, MA, for its potential as a distribution or utility-scale Battery Energy Storage System (BESS) site. The analysis covers key development pillars including site access, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The site benefits from excellent public road access, fronting Boston Road, which is also US Route 20. This is a major, well-maintained thoroughfare capable of supporting heavy truck traffic. This significantly de-risks the logistics of equipment delivery.

Topography & Site Conditions: Based on aerial imagery, the parcel appears relatively flat and has been previously disturbed or cleared, which is highly advantageous for minimizing civil engineering costs. The "Good" buildability rating in the provided data supports this assessment. There is a discrepancy in the listed acreage (21.67 vs. 12.66 acres) which must be resolved via a title search and survey to confirm the actual parcel size and buildable area.

Heavy Equipment Feasibility: Access from US Route 20 directly to the site entrance should easily accommodate the delivery of heavy and oversized equipment, including multi-ton transformers, switchgear, and containerized BESS units via flatbed trucks. No significant access constraints are immediately apparent.

Easement Concerns: While primary site access is public, development will require granting a utility easement for interconnection infrastructure and ongoing access for the interconnecting utility. The "POI Onsite" data point, if accurate, simplifies this, but an easement will still be a formal requirement of the Interconnection Agreement. A title search is required to identify any existing easements (e.g., for drainage, existing utilities) that could encumber the buildable area.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap and a high-priority risk. The property is located approximately 0.5 miles north of the Quaboag River, which increases the potential for portions of the site to be within a designated floodplain (Zone A or AE). Any development within a Special Flood Hazard Area would require significant engineering, potential elevation of equipment, and complex permitting, drastically increasing costs. A FEMA FIRM panel review is an immediate next step.

Wetlands: The presence of wetlands is Unknown. Given the proximity to the Quaboag River and regional hydrology, there is a moderate to high probability of jurisdictional wetlands on the property. A desktop screening using the National Wetlands Inventory (NWI) is required immediately, to be followed by a formal field delineation by a certified wetland scientist. Any identified wetlands will trigger state (Massachusetts Wetlands Protection Act) and federal (Clean Water Act) setback requirements, which could significantly constrain the buildable envelope.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this must be verified through the US Fish & Wildlife Service's IPaC tool and a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to screen for state-listed species whose habitats may be impacted.

Brownfield/Superfund Status: The presence of a brownfield site within two miles is noted. This does not qualify our parcel for the 10% IRA brownfield tax credit adder unless the subject parcel itself can be designated as a brownfield. The proximity of a contaminated site warrants a Phase I Environmental Site Assessment (ESA) to ensure no legacy contamination exists on our target property from historical industrial use in the area.

Pipeline Proximity: No gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating risks and setback requirements associated with high-pressure pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's primary strength is its grid proximity. It is located just 1 mile from the Palmer 115 kV Substation and 0.6 miles from a 115 kV transmission line. The data point "POI Onsite" is highly valuable but conflicts with the stated distances; this must be clarified. If a 115 kV line crosses the property, it presents an ideal, low-cost POI for a utility-scale project. If the POI is at the substation 1 mile away, the cost for a new line extension (gen-tie) would be substantial.

Interconnection Voltage & Strategy: For a distribution-scale project (≤5MW), a 115 kV