⚡ 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 Rd in Palmer, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis highlights strong grid infrastructure but identifies significant regulatory and financial incentive risks that require immediate investigation.

1. Site Access & Topography

Road Access: The site benefits from direct access to Boston Road (U.S. Route 20), a major public thoroughfare. This provides excellent, year-round access for all phases of development, from initial surveying to final commissioning.

Equipment Delivery: Access via U.S. Route 20 is ideal for the delivery of heavy and oversized equipment, including step-up transformers, switchgear, and containerized battery systems. The road appears capable of handling heavy haul trucks without significant issue. A final route survey will be required prior to transport.

Terrain & Buildability: Based on aerial imagery, the site appears to be relatively flat and partially cleared, consistent with its industrial zoning designation. The "Good" buildability rating suggests minimal grading will be required, reducing civil construction costs. However, the discrepancy in listed acreage (21.67 vs. 12.66 acres) must be resolved via a survey and title review to confirm the actual buildable area.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests an existing utility right-of-way or easement crosses the property. While this is excellent for interconnection, a full title search is mandatory to understand the scope, restrictions, and location of any existing easements to ensure they do not conflict with the proposed BESS layout.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, requiring elevated equipment pads and potentially rendering the project financially unviable. A FEMA FIRM panel review is an immediate next step.

Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). The potential presence of wetlands poses a major risk to the available buildable area. A desktop National Wetlands Inventory (NWI) screening followed by a formal field delineation by a certified wetland scientist is required.

Critical Habitat / Species: The site is not within a designated critical habitat or protected area, which is a significant de-risking factor. A standard desktop review should still be conducted to confirm no state-listed species of concern are present.

Brownfield/Superfund Status: The presence of a Brownfield/Superfund site within two miles presents both a risk and a potential opportunity.

• Risk: If the subject parcel is downgradient from the identified site, there is a risk of soil or groundwater contamination, which could trigger costly remediation requirements. A Phase I Environmental Site Assessment (ESA) is essential to assess this risk.
• Opportunity: If the subject parcel itself qualifies as a "brownfield site" under IRA guidelines, the project could be eligible for the 10% Brownfield ITC adder. This is the only potential incentive adder identified for this site and must be investigated thoroughly.

Pipeline Proximity: No gas transmission pipelines are located within three miles, eliminating a key safety and setback concern.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's grid access is its strongest attribute. It is located just 1 mile from the Palmer 115 kV Substation and 0.6 miles from a 115 kV transmission line. The "POI Onsite" designation is a major advantage, suggesting a line suitable for interconnection either crosses or is immediately adjacent to the parcel, which could dramatically reduce gen-tie construction costs.

Interconnection Voltage & Feeder: For a ≤5MW project, a transmission-level (115 kV) interconnection would be prohibitively expensive. The most likely and cost-effective path is a distribution-level interconnection (e.g., 13.8 kV). It is highly probable that a distribution feeder from the Palmer Substation runs along Boston Road. This must be verified.

Utility & Process: The interconnecting utility is not clearly identified (data lists an ID and a transmission owner, Fitchburg Gas and Electric/Unitil, which may not be the distribution provider). The likely utility in Palmer, MA is National Grid. We must confirm the correct utility and begin their specific pre-application process immediately to understand feeder capacity and potential upgrade costs. The ISO-New England (ISO-NE) queue can be lengthy and complex, so early engagement is critical.

Estimated Cost & Timeline: Assuming a viable distribution feeder is adjacent to the site, interconnection costs could range from $750,000 to $2,000,000. The timeline, from application to commercial operation, would likely be 24-36 months, contingent on the ISO-NE study timeline and the extent of required utility upgrades.

4