⚡ 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, for its potential as a distribution-scale or utility-scale Battery Energy Storage System (BESS) project. The analysis covers key aspects of site viability, including access, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Equipment Delivery: The site has direct frontage on Boston Road (U.S. Route 20), a major, well-maintained public highway. This provides excellent and unrestricted access for all phases of construction and operation. Delivery of heavy and oversized equipment, including battery containers, power conversion systems (PCS), and main power transformers, is anticipated to be highly feasible with minimal need for road improvements.

Terrain & Buildability: While a formal topographical survey is required, preliminary satellite imagery review of this location in Hampden County suggests the parcel is relatively flat with minimal grade changes, consistent with the "Good" buildability rating provided. This characteristic is highly favorable, as it will likely minimize civil engineering and earthwork costs associated with site grading and foundation construction. The parcel appears to be cleared of significant vegetation, further reducing site preparation costs.

Equipment & Easement Concerns: The "POI Onsite" data point suggests an existing utility presence, which implies a utility easement is likely already in place. This is a significant advantage. However, the terms of this easement must be reviewed via a title report to ensure it allows for the construction and operation of a BESS and its associated infrastructure. A new, wider access easement from Boston Road onto the buildable portion of the site may be required, but this appears straightforward to secure given the public road frontage.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently listed as "Unknown." These are the most critical environmental risks for the site. A desktop screening using FEMA's Flood Insurance Rate Map (FIRM) and the National Wetlands Inventory (NWI) is an immediate priority. Any presence within a Special Flood Hazard Area (e.g., Zone A, AE) would necessitate elevating all critical equipment above the Base Flood Elevation, significantly increasing civil costs or potentially rendering the site unbuildable. Similarly, the presence of jurisdictional wetlands would trigger significant setback requirements under the Massachusetts Wetlands Protection Act, potentially reducing the buildable acreage. A formal wetlands delineation will be required if initial screening indicates a high probability of presence.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive finding. This should be verified through a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The presence of a Brownfield/Superfund site within two miles presents a potential opportunity. If this specific parcel (4 Boston Rd) can be classified as a brownfield site through a Phase I Environmental Site Assessment (ESA), it would be eligible for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA). This is a significant economic advantage. However, it also carries the risk that contamination could be present, which would require costly remediation. A Phase I ESA is essential to both quantify this risk and determine eligibility for the tax credit.

Other Constraints: The absence of pipelines within a three-mile radius is a major safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments. The site is not within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The site's grid access is excellent. It is located just 1 mile from the Palmer 115 kV Substation and 0.6 miles from a 115 kV transmission line owned by Fitchburg Gas and Electric Light Company (a subsidiary of Unitil or National Grid, Requires Verification). This proximity makes a utility-scale, transmission-level interconnection (115 kV) technically and economically feasible, allowing for a project larger than 5MW.

Distribution & POI: The "POI Onsite" data point is a key advantage, indicating a Point of Interconnection is available on the property itself. This almost certainly refers to a three-phase distribution feeder (likely 13.2 kV or similar voltage class). This provides a clear and highly attractive pathway for a distribution-scale project (≤5MW), which would have a significantly lower interconnection cost and a potentially shorter timeline than a transmission-level build.

Recommended Interconnection & Costs:

• Distribution (≤5MW): Interconnect to the onsite feeder. Estimated Cost: $1.5M - $3M. Estimated Timeline: 18-24 months through the utility's distribution generation queue.
• Transmission (>5MW): Tap the 115kV line 0.6 miles away. This would require a new project-owned substation/switchyard. Estimated Cost: $7M - $12M+. Estimated Timeline: 36-48+ months through the ISO-New England (ISO-NE) queue.

4. Regulatory & Zoning Analysis