⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Investment 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 a potential distribution or utility-scale Battery Energy Storage System (BESS) project at 4 Boston Road in Palmer, Hampden County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including access, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Delivery Feasibility: The property has frontage on Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent and direct access for both construction crews and the delivery of heavy equipment. Preliminary review of aerial imagery suggests sufficient road width to accommodate oversized loads like battery containers, inverters, and main power transformers.

Terrain Characteristics: Based on satellite imagery, the parcel appears relatively flat and cleared, particularly the sections fronting Boston Road. While this region of Massachusetts can have rolling hills, this specific site seems well-suited for development with minimal grading requirements. The "Good" buildability rating in the provided data supports this initial assessment. A formal topographic survey is required for confirmation.

Heavy Equipment Access: Access from U.S. Route 20 is a significant advantage. Heavy haul trucks should be able to access the site entrance directly. However, a detailed logistics plan must verify turning radii into the property and confirm that no local or state bridge weight restrictions exist on the planned delivery route.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests an existing utility right-of-way or easement crossing the property. While this is beneficial for interconnection, its exact location and any associated use restrictions must be identified. A full ALTA survey and title report are critical next steps to define all existing easements (access, utility, drainage) and ensure they do not conflict with the proposed BESS layout.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." This is a critical data gap and a potential fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would impose significant design constraints, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing civil engineering and construction costs. Immediate verification using FEMA's Flood Insurance Rate Maps (FIRMs) is a high-priority action item.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection laws under the Massachusetts Wetlands Protection Act, which mandates significant setbacks (typically 100-foot buffer zones) from delineated wetland resources. The presence of wetlands could substantially reduce the buildable acreage. A desktop screening using National Wetlands Inventory (NWI) maps is required immediately, to be followed by a formal wetland delineation by a certified professional if the screening indicates potential resources.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive finding. This reduces the risk of project delays or costly mitigation measures. This should be formally verified through a query of the U.S. Fish and Wildlife Service's IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database.

Brownfield/Superfund Status: There is one Superfund site located within two miles of the property. This presents a potential risk of subsurface contamination (e.g., groundwater plumes) migrating onto the subject parcel. A Phase I Environmental Site Assessment (ESA) is mandatory to assess this risk. Conversely, if the subject property itself has a history of industrial use and could be classified as a brownfield, it could qualify for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This presents a potential, albeit unlikely, advantage.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's proximity to grid infrastructure is its strongest attribute. The Palmer Substation (115 kV) is only one mile away, and a 115 kV transmission line owned by Fitchburg Gas and Electric Light