⚡ 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 potential acquisition and development of a Battery Energy Storage System (BESS) project at 4 Boston Road in Palmer, Hampden County, Massachusetts. The analysis covers key site attributes, constraints, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access: The property has frontage on Boston Road (U.S. Route 20), a major, publicly maintained highway. This provides excellent, high-quality access for both construction and operational phases.

Equipment Delivery: Access from a U.S. highway is a significant advantage for the delivery of heavy and oversized equipment, including battery containers, inverters, and the main power transformer. A detailed route survey will be required to confirm the absence of low-clearance bridges, sharp turns, or weight-restricted local roads on the final approach from major interstates (I-90 is nearby), but initial assessment is highly favorable.

Terrain & Topography: While a formal topographical survey is required, the "Good" buildability rating and general terrain in Palmer, MA suggest the site likely consists of rolling hills but is manageable for development. We anticipate moderate civil work and grading will be necessary to create a level pad for the BESS equipment, but no extreme slopes are expected that would render the site unbuildable. The 21.67-acre parcel size provides ample flexibility for siting the project to avoid challenging terrain.

Easement Concerns: The property has direct public road frontage, minimizing the need for off-site access easements. However, a full title review is necessary to identify any existing utility easements (for gas, communications, or sewer) that may cross the property and constrain the buildable area. The "POI Onsite" data point suggests a utility right-of-way may already exist, which must be investigated.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status 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 costs and design challenges, requiring all equipment to be elevated above the Base Flood Elevation. Immediate verification using FEMA's Map Service Center is the highest priority.

Wetlands: The presence of wetlands is "Unknown." This is another critical risk. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) in addition to federal regulations, which impose significant setbacks (typically 100-foot buffer zones) that can severely restrict the buildable area. A formal wetland delineation will be a mandatory, early-stage due diligence item.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive finding. A desktop review using the USFWS IPaC tool and MassGIS OLIVER should be conducted to confirm no state or federally listed species have ranges that overlap with the project area.

Brownfield/Superfund Status: The presence of a Superfund site within two miles is noted. Crucially, this does not mean our target parcel is contaminated, but its location in an industrial area raises the possibility that it could qualify as a "brownfield site" under IRA guidelines. This presents a significant opportunity for a 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is required to evaluate historical land use and determine if the site meets the definition, turning a potential risk into a financial advantage.

Pipeline Proximity: No major gas pipelines are located within three miles. This is a significant safety and layout advantage, as it removes the need to design around pipeline-related setbacks and hazard zones.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located just 1.0 mile from the Palmer Substation (115 kV class) and 0.6 miles from a 115 kV transmission line. This proximity to high-capacity infrastructure is a primary strength of the site.

Interconnection Voltage & Point of Interconnection (POI): For a distribution-scale project (≤5MW), a 115 kV transmission-level interconnection would be cost-prohibitive. The optimal path is to interconnect to a local distribution feeder, likely at 13.8 kV. The "POI Onsite" data is promising but requires immediate verification. We must identify if a suitable three-phase distribution line, originating from the Palmer Substation, crosses or is adjacent to the property. The capacity of this feeder is a critical unknown. The interconnecting utility must be confirmed; it is likely National Grid or Eversource in this territory.

Estimated Cost & Timeline: Interconnection costs are highly variable.

• Best Case: If a suitable capacity feeder is on or adjacent to the site, costs could be in the $750,000 - $1.5 million range for protection upgrades and line work.
• Worst Case: If a new 1-mile feeder must be built from the substation, costs could easily exceed $3 million.

Feeder Configuration: Requires Verification. The voltage, phase, and current loading of the local distribution circuit are unknown