⚡ 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 distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis covers key site characteristics, 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 public thoroughfare. This provides excellent, year-round access for construction crews, material deliveries, and ongoing operations and maintenance. The quality of access is considered a significant asset for the site.

Terrain & Equipment Feasibility: While a formal topographic survey is required, the "Good" buildability rating and general characteristics of the area suggest the site is likely relatively flat with minimal grade changes. This is favorable for minimizing civil engineering and earthwork costs. Access from a major road like US-20 indicates that large, heavy-haul trucks carrying battery containers, pad-mount transformers, and other critical equipment should be able to reach the site entrance without issue. Requires Verification: A route survey should be conducted to confirm the absence of low-clearance bridges, sharp turns, or weight-limited infrastructure between major highways and the site entrance.

Easement Concerns: The "POI Onsite" data point strongly suggests an existing utility easement is already in place, which is highly advantageous for interconnection. However, a full title search is critical to identify any other easements (e.g., access, conservation, drainage) that could encumber the property and reduce the buildable area. The exact location and width of the existing utility easement must be confirmed via an ALTA survey.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This represents a critical data gap and a potential fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone AE) would necessitate elevating all equipment above the Base Flood Elevation, significantly increasing civil costs. Development within a designated floodway is typically prohibited. Immediate verification using FEMA's Flood Insurance Rate Map (FIRM) is required.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) that often require significant setbacks (e.g., 100-foot buffer zones) from delineated wetland boundaries. The presence of extensive wetlands could severely restrict the buildable acreage and render the project infeasible. A National Wetlands Inventory (NWI) screening followed by a formal field delineation by a certified professional is a critical next step.

Habitat & Protected Areas: The data indicates "None" for Critical Habitat or Protected Areas, which is a positive initial finding. This reduces the risk of encountering project-stopping issues related to state or federally listed endangered species. However, a desktop environmental screening should still be performed to confirm this and check for any local species of concern.

Brownfield/Superfund Status: The presence of a superfund site within two miles is a moderate risk. While this does not qualify the subject property for the 10% IRA brownfield tax credit adder (which requires the project site itself to be a brownfield), it necessitates a Phase I Environmental Site Assessment (ESA) to ensure no soil or groundwater contamination has migrated onto our parcel.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The grid infrastructure in this location is excellent. The Palmer Substation (115 kV class) is only one mile away, and a 115 kV transmission line is even closer at 0.6 miles. The most valuable piece of data is "POI Onsite," indicating a Point of Interconnection is available on the property itself. This drastically reduces project risk and cost.

Interconnection Strategy: For a distribution-scale project (≤5MW), the ideal interconnection point is a 3-phase distribution feeder. The "POI Onsite" likely refers to such a feeder, probably a 13.2 kV or similar voltage line, originating from the Palmer Substation. This avoids the extremely high cost and complexity of a transmission-level (115 kV) tap, which would be non-viable for a project of this size.

Cost & Timeline Estimate: With a POI onsite, the interconnection cost should be on the lower end of the spectrum. Costs will be driven by utility-required upgrades at the substation and any necessary reconductoring of the local line. A preliminary budget of $400,000 - $1,200,000 is a reasonable starting estimate. The interconnecting utility (Requires Verification: likely National Grid or Eversource) operates within the ISO New England (ISO-NE) territory. The ISO-NE interconnection queue is notoriously congested and complex; a realistic timeline from application submission to Commercial Operation Date (COD) is typically 24-36 months.

Feeder Configuration: The onsite POI is almost certainly a 3-phase overhead distribution line. A key diligence step will be to obtain feeder maps from the utility to confirm its capacity, current loading, and configuration (e.g., radial