⚡ 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 analysis evaluates the site's suitability for a distribution-scale (≤5MW) or utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access: The property has excellent access, with frontage directly on Boston Road (U.S. Route 20), a major east-west highway. The data indicates "Public" road access, which is confirmed by satellite imagery. This high-quality access eliminates concerns regarding last-mile road improvements and facilitates straightforward transportation of construction materials and personnel.

Terrain & Equipment Feasibility: Based on preliminary review of aerial imagery, the site appears to be relatively flat and partially cleared, consistent with its industrial zoning and prior use. This topography is highly advantageous, minimizing the need for extensive civil work and grading, which will reduce site preparation costs. The direct access from a major highway and level terrain should easily accommodate the delivery and placement of heavy equipment, including mobile cranes, transformers, switchgear, and containerized BESS units.

Easement Concerns: While road access is direct, a full title search is required to identify any existing utility easements, right-of-ways, or other encumbrances that could impact the final site layout. The data indicates "POI Onsite," which suggests a utility right-of-way likely exists on or adjacent to the property for the transmission line. This must be confirmed to ensure our development rights are not restricted.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." This is a critical data gap. A preliminary desktop review using the FEMA Flood Map Service Center suggests the parcel is located in Zone X, an area of minimal flood hazard. However, this Requires Verification through a formal Flood Hazard Determination. Siting critical infrastructure outside of the 0.2% annual chance floodplain (Shaded Zone X) is best practice and often a financing requirement.

Wetlands: The presence of wetlands is "Unknown." This represents a significant potential risk. A desktop screening using the US FWS National Wetlands Inventory should be conducted immediately, followed by a formal wetland delineation by a certified professional. Any identified wetlands will necessitate design modifications to adhere to state and local setback requirements, potentially reducing the buildable acreage.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on the site, which significantly de-risks the project from a wildlife permitting perspective. This should be confirmed with a state-level database query (e.g., MA Natural Heritage & Endangered Species Program).

Brownfield/Superfund Status: The presence of one Superfund/brownfield site within a two-mile radius is noted. This presents both a risk and an opportunity. The risk is potential contaminant migration onto our parcel, which must be assessed via a Phase I Environmental Site Assessment (ESA). The opportunity is significant: if our site itself can be characterized as a "brownfield site" under IRA guidelines (e.g., through the presence of contamination or being adjacent to a contaminated site), it could qualify for the 10% Energy Community ITC adder. This is a pivotal point for the project's financial viability.

Pipeline Proximity: No gas pipelines are identified within a three-mile radius, which is a positive safety attribute that simplifies site design and eliminates the need for specialized pipeline-related safety and setback studies.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's grid proximity is its strongest attribute. It is located just 1 mile from the Palmer Substation (115 kV) and, more importantly, only 0.6 miles from a 115 kV transmission line. The data point "POI Onsite" strongly suggests this 115 kV line, owned by Fitchburg Gas and Electric Light Company (a Unitil subsidiary), traverses or is immediately adjacent to the parcel. Satellite imagery confirms a major transmission corridor runs along the southern property boundary. This is an ideal scenario for a utility-scale project.

Interconnection Recommendation: For a utility-scale project (>5 MW), a direct 115 kV transmission tap is the recommended interconnection strategy. This avoids potential capacity constraints on the distribution system and allows for a larger project size. For a smaller distribution-scale project (≤5 MW), interconnection to a local distribution feeder could be explored as a lower-