⚡ 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, Palmer, MA. The analysis evaluates the site's suitability for a distribution or utility-scale Battery Energy Storage System (BESS) project based on initial data. The property presents a potentially exceptional interconnection opportunity, but significant regulatory and environmental uncertainties must be resolved before committing further capital.

1. Site Access & Topography

Road Access: The site has frontage on Boston Road (Route 20), a major state highway. This provides excellent public road access for both personnel and equipment. Satellite imagery confirms Boston Road is a well-maintained, paved, multi-lane road capable of handling heavy truck traffic.

Equipment Delivery: Access appears highly feasible. The proximity to a major route minimizes transit through residential areas or on smaller, weight-restricted roads. Standard flatbed trucks for battery containers and heavy-haul transporters for the main power transformer should be able to access the site entrance directly from Boston Road without issue. Requires Verification: A detailed transport route study should be conducted to confirm no low-clearance bridges or other obstructions exist from the nearest interstate (I-90) to the site.

Topography & Site Conditions: The data indicates "Good" buildability. Satellite imagery shows the parcel as largely cleared and relatively flat, consistent with its industrial zoning and prior use. The 21.67-acre parcel size (though Regrid data suggests a smaller 12.66 acres, which needs reconciliation) offers ample space for a ≤5MW project footprint, including required equipment spacing, access roads, and stormwater management features.

Easement Concerns: The data point "POI Onsite" is a significant advantage, suggesting the point of interconnection is within the parcel boundaries. This would likely eliminate the need for a costly and time-consuming off-site gen-tie easement. Access appears to be direct from Boston Road, but a title search is required to confirm there are no restrictive access easements or encumbrances.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is "Unknown". This is a critical data gap and a potential fatal flaw. If the buildable area is within a Special Flood Hazard Area (e.g., Zone A or AE), project costs will increase substantially due to the need to elevate all equipment above the Base Flood Elevation, or the site may be rendered undevelopable. Immediate verification using the FEMA Flood Map Service Center is required.

Wetlands: The presence of wetlands is "Unknown". This is another major risk. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act). The presence of jurisdictional wetlands could significantly reduce the buildable acreage due to required setbacks (typically 100-foot buffer zones). A desktop screening using the National Wetlands Inventory (NWI) is the first step, followed by a formal field delineation by a certified professional if the screening indicates potential wetlands.

Critical Habitat / Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be confirmed via a desktop review of the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or sensitive habitats are present.

Brownfield/Superfund Status: The presence of a superfund site within two miles is a dual-edged sword. It presents a risk of potential contamination on our parcel, which must be investigated via a Phase I Environmental Site Assessment (ESA). However, it also raises the possibility that our industrial-zoned parcel could itself qualify as a "brownfield site" under IRA guidelines. If so, this would unlock a valuable 10% ITC adder. The Phase I ESA is critical to assess both the environmental liability risk and the financial incentive opportunity.

Pipeline Proximity: No gas pipelines within three miles is a significant safety and layout advantage, eliminating setback constraints and explosion-risk concerns.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's grid access is its most compelling feature. It is located just 1 mile from the Palmer 115 kV Substation and, more importantly, only 0.6 miles from a 115 kV transmission line. The most promising data point is "POI Onsite," which strongly implies this 115 kV line traverses or is immediately adjacent to the property boundary.

Interconnection Recommendation: The recommended point of interconnection is a direct tap to the 115 kV transmission line. This is preferable to a substation connection as it is closer and likely involves a simpler physical build. A transmission-level interconnection provides robust capacity, suitable for an initial ≤5MW project with potential for future expansion. A distribution-level connection is a secondary, less attractive option.

Cost & Timeline Estimate: Interconnecting to an onsite or adjacent 115 kV line is the most cost-effective scenario. Estimated costs could range from $1.5M to $3.5M for the switchyard, protection and control systems, and short gen-tie. This is