⚡ 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) or utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent and straightforward access for all phases of development, from initial surveying to final commissioning. No complex, multi-parcel access easements appear necessary.

Terrain & Equipment Access: Based on aerial imagery, the site appears to be relatively flat and partially cleared, consistent with its industrial zoning and prior use. This topography is highly favorable for BESS development, minimizing the need for extensive civil work and grading. The direct access from U.S. Route 20 is more than adequate to accommodate the delivery of heavy equipment, including large tractor-trailers carrying battery containers, power conversion systems (PCS), and the main power transformer.

Easement Concerns: While primary access is secure, a full title report is required to identify any existing utility easements (e.g., for gas, water, or existing electrical lines) that may cross the property. Such easements could constrain the final site layout and reduce the buildable area. The discrepancy in listed acreage (21.67 vs. 12.66 acres in different data sources) must be clarified via a formal survey, as this directly impacts site capacity.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This represents a critical and potentially fatal flaw risk. Immediate desktop analysis using the FEMA Flood Insurance Rate Map (FIRM) database is required. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase significantly due to requirements for elevating equipment, and portions of the site may be undevelopable.

Wetlands: The presence of wetlands is also Unknown. This is another major risk, particularly in Massachusetts, which has stringent state (Massachusetts Wetlands Protection Act) and local wetland regulations. A desktop screening using MassGIS OLIVER is the immediate next step. If potential wetlands are identified, a formal wetland delineation by a certified professional will be necessary. The presence of jurisdictional wetlands would trigger significant setbacks (typically 100-foot buffer zones) and a lengthy, complex permitting process with the Palmer Conservation Commission.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be confirmed with a U.S. Fish & Wildlife Service IPaC report as part of standard diligence.

Brownfield/Superfund Status: The presence of one Superfund/brownfield site within two miles is a dual-edged sword. It presents a risk of potential migrating soil or groundwater contamination, which must be assessed via a Phase I Environmental Site Assessment (ESA). However, if the subject property itself can be classified as a "brownfield site" under federal definitions (e.g., due to prior industrial use and perceived contamination), it could qualify for the 10% Energy Community ITC adder under the Inflation Reduction Act (IRA). This is the site's only apparent path to an ITC bonus and warrants aggressive investigation.

Other Considerations: The absence of pipelines or gas wells within the vicinity is a significant safety and design advantage, simplifying the layout and reducing third-party constraints.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's proximity to grid infrastructure is a primary strength. It is located approximately 1 mile from the Palmer Substation (115 kV max voltage) and 0.6 miles from a 115 kV transmission line. However, the data point "POI Onsite" conflicts with these distances. This must be clarified immediately. If a suitable POI is truly on-site (e.g., a transmission line traverses the property), it is a major advantage. If a 0.6-1.0 mile gen-tie is required, the project is still viable but will incur significant additional cost.

Interconnection Voltage & Recommendation: For a ≤5MW project, a distribution-level interconnection (e.g., 13