⚡ 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 but faces significant regulatory and financial incentive hurdles that must be addressed before committing further resources. The following sections detail the findings of our initial evaluation.

1. Site Access & Topography

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

Terrain & Equipment Feasibility: Preliminary review of satellite imagery suggests the site is relatively flat and partially cleared, consistent with its "Good" buildability rating. This topography is highly favorable for BESS development, minimizing the need for extensive civil work and grading. The robust access from U.S. Route 20 ensures that heavy equipment, including mobile cranes, transformers, and prefabricated battery containers, can be delivered and maneuvered onto the site without significant logistical challenges.

Easement Concerns: While road access is public, the data indicates "POI Onsite" (Point of Interconnection). It is critical to confirm the exact location of the POI on the parcel. A full title search is required to identify any existing utility easements that may impact the site layout or require negotiation for access. We must ensure our access rights to the POI are secured and do not conflict with other property encumbrances. There is also a notable discrepancy in listed acreage between two data sources (21.67 vs. 12.66 acres), which must be clarified via a survey and title review to confirm the actual parcel size.

2. Environmental Constraints

Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently listed as "Unknown." These are critical data gaps representing a significant potential risk. Development within a designated flood hazard area (e.g., Zone A, AE) would trigger substantial design constraints, elevated construction costs for platforms, and potential permit denial. Similarly, the presence of state or federally protected wetlands would enforce setback requirements, reducing the buildable area and potentially requiring costly mitigation. A desktop screening using FEMA and National Wetlands Inventory (NWI) maps is an immediate priority.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this should be formally verified through a U.S. Fish and Wildlife Service IPaC (Information for Planning and Consultation) report to ensure no endangered species or migratory bird considerations are overlooked.

Brownfield/Superfund Status: The presence of a Brownfield/Superfund site within two miles is noted. This does not mean the subject property is contaminated, but it raises the possibility. A Phase I Environmental Site Assessment (ESA) is mandatory to assess the site's history and determine if it could qualify for the 10% ITC Brownfield adder under the Inflation Reduction Act (IRA). Qualification would be a significant financial advantage; conversely, discovering unmitigated contamination would be a major liability.

Other Constraints: The site is not within the Chesapeake Bay Critical Area. No pipelines or gas wells are in close proximity, eliminating those specific safety and setback concerns.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's grid access is its strongest attribute. The Palmer Substation (115 kV) is only one mile away, and a 115 kV transmission line is just 0.6 miles from the parcel. Most importantly, the "POI Onsite" designation suggests that a viable distribution or transmission line is already traversing or immediately adjacent to the property boundary, which dramatically reduces the cost and complexity of the generator lead line.

Interconnection Strategy: For a distribution-scale project (≤5MW), the likely interconnection point would be a local distribution feeder, likely at a voltage of 13.8 kV or 23 kV. The "POI Onsite" suggests such a feeder is readily available. For a larger utility-scale project, a direct tap to the 115 kV transmission line is feasible given the proximity. We recommend initially targeting a distribution-level interconnection to minimize costs and potentially streamline the study process.

Cost, Timeline & Utility: The interconnecting utility is listed as a UUID and must be identified immediately—it is likely National Grid or Eversource in this region. Interconnection costs could be relatively low (potentially $500k - $1.5M) if the "POI Onsite" holds true and the local feeder has capacity. However, if substation upgrades are required by the utility, costs could escalate significantly. The ISO New England (ISO-NE) interconnection queue is notoriously long and complex; a realistic timeline from application to commercial operation is 36+ months. Early engagement with the utility is critical.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning Conflict: The Authority Having Jurisdiction (AHJ) is Palmer Town. There is a critical conflict in the provided zoning data. The description is "Industrial (General)," which is favorable for BESS development. However, the associated zoning code is "RR," which in the Palmer, MA Zoning Bylaws corresponds to "Rural Residential." This is a potential fatal flaw. BESS is highly unlikely to be a permitted use in a Rural Residential zone.

Permitting Pathway:

• If Zoned Industrial: