⚡ 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 mix of compelling attributes, primarily excellent grid infrastructure proximity, alongside significant regulatory and environmental uncertainties that must be resolved before committing further capital. The following sections detail the findings of our initial evaluation.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has direct frontage on Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent access for both construction crews and the delivery of heavy equipment. Large trucks carrying battery containers, transformers, and switchgear should have no issue accessing the property entrance. A preliminary review of aerial imagery suggests the immediate access point is wide and accommodating.

Terrain Characteristics: Based on aerial and topographic map review, the parcel appears to be relatively flat and partially cleared, consistent with its "Industrial" zoning classification and "Good" buildability rating. This is highly favorable, as it will likely minimize earthwork and civil engineering costs. The parcel size, noted as 21.67 acres (with a conflicting Regrid report of 12.66 acres), should be more than sufficient for a distribution-scale BESS project of up to 5MW, including necessary access roads, equipment pads, and setbacks.

Heavy Equipment Feasibility: Access from a U.S. highway is a major advantage. However, a formal logistics study is required to confirm that all local bridges and culverts between the site and the nearest interstate (I-90) can support the weight of a fully loaded transformer (often exceeding 100,000 lbs). Turning radii from Boston Road onto the site must also be confirmed during a site visit.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests a pre-existing utility easement crosses the property. This is a significant benefit for interconnection but must be confirmed via a title search. The title report will be critical to verify the width, rights, and restrictions of this easement to ensure it does not encumber the planned BESS footprint. We must also secure a clear access easement from Boston Road to the project area if the parcel is subdivided or set back from the road.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, requiring elevated equipment pads and potentially prohibitive insurance costs. Verifying the site's status on the official FEMA Flood Insurance Rate Maps (FIRMs) is an immediate priority.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. The presence of jurisdictional wetlands could impose substantial setbacks (typically 100-foot buffer zones) that would severely restrict the buildable area. A desktop screening using the National Wetlands Inventory (NWI) is the first step, but a formal field delineation by a certified wetland scientist will be required to confirm boundaries and secure permits.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on site, which is a positive sign. This should be verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present, which could trigger lengthy consultations and mitigation requirements.

Brownfield/Superfund Status: The property is not a listed brownfield. While a Superfund site is located within two miles, it is unlikely to impact this parcel directly. A Phase I Environmental Site Assessment (ESA) is still required to confirm no historical contamination exists on the subject property itself. The lack of brownfield status means the project is ineligible for the 10% IRA brownfield ITC adder, which is a financial disadvantage.

Pipeline Proximity: No gas transmission pipelines are located within three miles, mitigating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's primary strength is its location relative to grid infrastructure. It is approximately 1 mile from the Palmer Substation (115 kV) and 0.6 miles from a 115 kV transmission line. The data point of "POI Onsite" is extremely valuable, suggesting a distribution or transmission line already traverses the property, which could dramatically reduce interconnection costs.

Likely Interconnection Voltage: For a distribution-scale project (≤5MW), a 115 kV transmission-level interconnection would be cost-prohibitive. The most likely and economically viable path is to interconnect to a distribution feeder, likely at 13.8 kV or a similar voltage, originating from the Palmer Substation. The "POI Onsite" likely refers to such a distribution line. This must be verified immediately.

Cost & Timeline Estimate:

• Distribution Interconnection (Assumed): If a feeder with sufficient capacity is onsite or adjacent, costs could range from $1.5M to $3M for protection upgrades, reclosers, and a short line extension.
• Transmission Interconnection (Unlikely): A 115 kV tap would likely cost over $5M - $7M+ and is not recommended for this project scale.