⚡ 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) Battery Energy Storage System (BESS) project based on key development criteria. The site presents a compelling opportunity due to its exceptional grid infrastructure access but faces significant risks related to environmental unknowns and a lack of federal incentive adders.

1. Site Access & Topography

Road Access: The property benefits from direct frontage on Boston Road (U.S. Route 20), a major, publicly maintained thoroughfare. This provides excellent and reliable access for all phases of development, from initial surveying to final commissioning.

Terrain & Equipment Feasibility: Based on aerial imagery, the parcel appears relatively flat and cleared, consistent with its "Industrial (General)" zoning and prior use. This topography is highly advantageous, minimizing the need for extensive civil work and grading, thereby reducing site preparation costs. The direct access from a major US highway ensures that heavy equipment, including low-boy trailers carrying transformers, switchgear, and containerized BESS units, can be delivered to the site without significant logistical challenges, such as tight turns, low-clearance bridges, or weight-restricted local roads.

Easement Concerns: While primary access is public, a title search is required to confirm the absence of any restrictive easements that could encumber the proposed BESS footprint or access routes from the public right-of-way onto the developable portion of the parcel. The discrepancy in listed acreage (21.67 acres vs. 12.66 acres in Regrid data) must be resolved via an ALTA survey to confirm the legal boundaries and net buildable area.

2. Environmental Constraints

This category represents the most significant data gap and potential risk for the project.

• FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical flaw in the preliminary data. A desktop review using the FEMA Flood Map Service Center is an immediate next step. If the site is located within a Special Flood Hazard Area (e.g., Zone A, AE), development costs could increase substantially due to mitigation requirements (e.g., elevating equipment), or the site could be rendered undevelopable.
• Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. An immediate desktop screening using MassGIS and National Wetlands Inventory (NWI) data is necessary, to be followed by a formal field-based wetland delineation by a qualified consultant. The presence of jurisdictional wetlands would introduce significant setbacks and reduce the buildable acreage.
• Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-listed species or priority habitats are present.
• Brownfield/Superfund Status: The property is not a listed brownfield, but one Superfund site is noted within a two-mile radius. This makes it highly unlikely that the project would qualify for the 10% IRA Brownfield Adder, which requires the project to be sited on a qualifying brownfield parcel itself. A Phase I Environmental Site Assessment (ESA) is strongly recommended to ensure no contamination from nearby sites has migrated onto the subject property and to establish a baseline environmental condition.
• Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

The site's primary strength lies in its grid proximity and favorable interconnection characteristics.

• Substation & POI: The property is located just 1 mile from the Palmer Substation, a 115 kV facility. Critically, the data indicates the Point of Interconnection (POI) is "Onsite." This is an exceptional advantage, suggesting a suitable distribution or transmission line is directly on or adjacent to the parcel. This dramatically reduces the cost and complexity of the generator lead line, which is often a major project expense.
• Interconnection Voltage & Feeder: For a ≤5MW project, interconnection will almost certainly be at the distribution level (e.g., 13.8 kV or 23 kV). The "POI Onsite" likely refers to a 3-phase overhead distribution feeder running along Boston Road. An initial pre-application report from the interconnecting utility (presumed to be National Grid, the primary provider in Palmer) is required to confirm the exact feeder voltage, configuration, and available capacity.
• Cost & Timeline Estimate: With an onsite POI, interconnection costs will be dominated by utility-side upgrades (reclosers, protection system upgrades) and the project's own switchgear, rather than line extension costs. A preliminary budget of $750,000 to $2,000,000 is a reasonable starting estimate, pending the results of utility system impact studies. The interconnection process in Massachusetts with National Grid and ISO-New England can be lengthy, typically ranging from 24 to 36 months from application to commercial operation.

4. Regulatory & Zoning Analysis

Authority & Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Palmer.