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

1. Site Access & Topography

Road Access: The site benefits from excellent access, with frontage directly on Boston Road (U.S. Route 20), a major public thoroughfare. This existing, high-quality road infrastructure is a significant advantage, capable of supporting heavy truck traffic required for BESS component delivery.

Topography & Equipment Feasibility: Based on aerial imagery and the "Good" buildability rating, the site appears to be relatively flat and cleared, consistent with its industrial zoning. This topography is ideal for BESS development, minimizing the need for extensive civil work and grading. The direct access from U.S. Route 20 ensures that oversized and overweight loads, such as transformers, switchgear, and battery containers, can be delivered to the site with minimal logistical hurdles. A detailed survey will be required to confirm precise grades, but no major topographical challenges are anticipated.

Easement Concerns: The data indicates a "POI Onsite," which strongly suggests an existing utility easement crosses or is adjacent to the property. While this is beneficial for interconnection, a full title report is required to identify the exact location, width, and restrictions of this and any other access or utility easements. Understanding these restrictions is critical to creating a viable site layout that does not infringe on easement rights.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap and a high-priority risk. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. Immediate review of the official FEMA Flood Insurance Rate Maps (FIRMs) is required.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically a 100-foot buffer). The presence of regulated wetlands could severely constrain the buildable area. A desktop screening using MassGIS and National Wetlands Inventory (NWI) data should be performed immediately, followed by a formal field delineation by a certified wetland scientist.

Habitat & Protected Species: The site is not located within a designated critical habitat or protected area, which is a positive finding. However, a standard check of the USFWS IPaC system and state-level Natural Heritage & Endangered Species Program (NHESP) database is recommended to ensure no state-listed species of concern have habitats on or near the parcel.

Brownfield/Superfund Status: While there is a Superfund site approximately 2 miles away, the subject parcel itself is not listed. Given its industrial zoning, there is a possibility the site could qualify as a "brownfield" under IRA guidelines. This presents a potential opportunity. A Phase I Environmental Site Assessment (ESA) is necessary to determine if the site has a history of contamination that would qualify it for the 10% Brownfield ITC adder. This could be a significant financial advantage.

Pipeline Proximity: No major gas pipelines are located within 3 miles, which eliminates a significant safety, setback, and permitting risk.

3. Grid Infrastructure & Interconnection

Substation & Transmission Assets: The site is in an excellent location relative to robust grid infrastructure. The Palmer Substation (115 kV) is only 1 mile away, and a 115 kV transmission line owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary) is just 0.6 miles away. This proximity is highly favorable.

Interconnection Voltage & Feasibility: This is the most critical uncertainty for a ≤5MW project. The known