⚡ 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. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) or small utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has direct frontage on Boston Road (U.S. Route 20), a major east-west federal highway. This provides excellent, high-quality public road access suitable for all phases of construction and operation. Delivery of heavy equipment, including multi-ton transformers, switchgear, and containerized battery systems via flatbed trucks, is expected to be straightforward without the need for significant road improvements. Proximity to the I-90 Massachusetts Turnpike further enhances logistical efficiency.

Terrain & Buildability: Based on aerial imagery and its "Industrial (General)" zoning, the site appears to be relatively flat and largely cleared, consistent with prior industrial or commercial use. The "Good" buildability rating in the provided data supports this assessment. A formal topographic survey is required to confirm precise grades, but significant earthwork is not anticipated, which will help control civil construction costs. The discrepancy between the total listed acreage (21.67) and the Regrid parcel acreage (12.66) must be resolved via a survey and title review to confirm the actual project area.

Heavy Equipment Access: The direct access from U.S. Route 20 allows for easy ingress and egress for cranes, delivery trucks, and other heavy machinery. The site appears to have sufficient frontage to establish a wide construction entrance. The internal site layout should easily accommodate circulation for delivery and placement of BESS containers and the main power transformer.

Easement Concerns: While road access is public, a full title report is a critical next step. We must verify that no prohibitive access easements, utility right-of-ways, or other encumbrances cross the prime buildable area of the parcel that could restrict the BESS footprint or construction activities.

2. Environmental Constraints

FEMA Flood Zone: The 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 trigger significant design constraints, including elevating all equipment above the Base Flood Elevation, potentially rendering the project uneconomical. Immediate verification using FEMA's Map Service Center is required.

Wetlands: The presence of wetlands is "Unknown." This is another major risk. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act). Any state or federal jurisdictional wetlands on site would require significant setbacks (typically 100 feet or more) and could severely constrain the buildable area. A desktop screening using MassGIS and NWI data is an immediate priority, 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 "None" for critical habitat, which is a positive initial finding. However, this must be formally verified through the U.S. Fish and Wildlife Service's IPaC tool and a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The presence of a superfund/brownfield site within 2 miles is noted. This presents both a risk and an opportunity. The risk is potential contaminant migration onto our parcel, which must be assessed via a Phase I Environmental Site Assessment (ESA). The opportunity is the 10% ITC "Brownfield" adder under the Inflation Reduction Act (IRA). A Phase I ESA is essential to determine if our specific parcel meets the federal definition of a brownfield, which could significantly improve project economics. This is a key diligence item.

Pipeline Proximity: The absence of major gas pipelines within 3 miles is a significant safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid access is a primary strength. It is located just 1 mile from the Palmer Substation (max voltage 115 kV) and 0.6 miles from a 115 kV transmission line. This close proximity is highly desirable and drastically reduces the cost and complexity of the generator lead line.

Point of Interconnection (POI): The data notes "POI Onsite," which, if accurate, is a major advantage. This likely refers to a three-phase distribution feeder running along Boston Road, originating from the Palmer Substation. This is the ideal scenario for a distribution-scale (≤5MW) project. Verification of the feeder's voltage class (e.g., 13.8 kV) and available capacity is the single most important technical diligence item.

Recommended Interconnection: For a project ≤5MW, the recommended path is a distribution-level interconnection to the feeder identified as "POI Onsite." For a larger utility-scale project, the proximity to the 115 kV line or the Palmer Substation offers a viable, albeit more expensive and complex, transmission-level interconnection path.

Cost & Timeline Estimate:

• Distribution (≤5MW): Assuming a simple tap to an adjacent feeder with adequate capacity, interconnection costs could range from $750,000 to $2.5 million. The timeline would be governed by the ISO-New England (ISO-NE) interconnection queue, likely 24-36 months from application to commercial operation, assuming no major system upgrades are required.
• Transmission (>5MW): A 115 kV interconnection would be substantially more, likely in the $5 million to $10+ million range, requiring either a new bay at