⚡ 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 site presents a compelling opportunity due to its favorable industrial zoning and exceptional proximity to grid infrastructure. However, critical data gaps in environmental and regulatory areas must be addressed before further commitment. The potential to qualify for a 10% brownfield Investment Tax Credit (ITC) adder significantly enhances the project's potential financial viability.

1. Site Access & Topography

• Road Access & Feasibility: The site benefits from public road access on Boston Road. As this is an industrially zoned area, the road is likely constructed to a standard capable of handling heavy truck traffic. Requires Verification: A desktop review using satellite imagery and Google Street View is necessary to confirm road width, turning radii from Boston Rd onto the site, and the absence of any vertical clearance issues (e.g., low bridges, overhead lines) that could impede equipment delivery.
• Terrain Characteristics: Located in Hampden County, the regional topography is generally characterized by rolling hills. However, the parcel's "Good" buildability rating and industrial zoning suggest the site itself is likely relatively flat, possibly having been graded previously. A formal topographic survey will be required to confirm elevations and drainage patterns for detailed engineering design.
• Heavy Equipment Access: Access for critical heavy equipment, including mobile cranes, transformers (potentially 50+ tons), and prefabricated battery containers, appears feasible given the public road access. A preliminary logistics plan should verify bridge weight limits and local hauling restrictions on the anticipated delivery route.
• Easement Concerns: The data indicates "POI Onsite," which is a significant advantage, reducing the need for off-site easements for electrical conduits. However, a full title report is a critical next step to identify any existing utility easements, access easements benefiting other parcels, or other encumbrances that could restrict the developable area or construction access.

2. Environmental Constraints

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical information gap and a potential fatal flaw. Immediate action is required to check the FEMA Flood Map Service Center. If the site is within a Special Flood Hazard Area (e.g., Zone A, AE), development costs will increase substantially due to the need to elevate all equipment above the Base Flood Elevation, and the site may become unviable. A designation of Zone X would be ideal.
• Wetlands: The presence of wetlands is "Unknown." This is another major risk. A desktop screening using the National Wetlands Inventory (NWI) and MassGIS data is the immediate first step. Given the site's location in Massachusetts, any state-jurisdictional wetlands would likely trigger significant buffer zone requirements (typically 100 feet under the MA Wetlands Protection Act), which would severely constrain the buildable area. If the desktop screening indicates potential wetlands, a formal wetlands delineation by a certified professional is mandatory.
• Habitat & Species: The data indicates no Critical Habitat or Protected Areas, which is a positive initial finding. As standard diligence, we must still consult the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to screen for state or federally listed species whose presence could trigger consultation requirements or time-of-year restrictions on construction.
• Brownfield/Superfund Status: The presence of a brownfield/superfund site within 2 miles is a notable finding. This requires a Phase I Environmental Site Assessment (ESA) to ensure no contamination has migrated to our parcel. Crucially, this also presents a major opportunity. If the Phase I ESA determines our specific parcel meets the definition of a "brownfield site" under 42 U.S.C. § 9601(39), the project would be eligible for the 10% Energy Community ITC adder under the Inflation Reduction Act (IRA). This is a significant potential upside.
• Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating risks associated with pipeline-related setbacks and explosion hazards.

3. Grid Infrastructure & Interconnection

• Substation & Grid Proximity: The site is located just 1 mile from the Palmer Substation (115 kV max voltage). This is excellent proximity for a distribution-scale project. The data point "POI Onsite" suggests a suitable distribution feeder is directly on or adjacent to the property, which would dramatically reduce the cost and complexity of the generator lead line.
• Transmission Access: A 115 kV transmission line is located only 0.6 miles away. While a transmission-level interconnection is overly complex and expensive for a ≤5MW project, its proximity confirms the robustness of the local grid.
• Recommended Interconnection: The recommended path is a distribution-level interconnection to a feeder from the Palmer Substation, likely at a standard voltage like