⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Development Team

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.

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 thoroughfare. The data indicates "Public" road access, which is confirmed by visual review. This high-quality access eliminates concerns regarding last-mile travel on unmaintained or private roads.

Terrain & Equipment Feasibility: Based on aerial imagery, the site appears to be relatively flat and cleared, consistent with its industrial zoning and prior use. This topography is highly favorable for BESS development, minimizing the need for extensive civil work and grading. The direct access from a major highway ensures that heavy equipment, including cranes for setting transformers and battery containers, can be delivered and maneuvered on-site with minimal logistical challenges. The parcel size (noted as 12.6 to 21.6 acres, a discrepancy requiring clarification) appears more than sufficient to establish a proper construction laydown area without impacting public rights-of-way.

Easement Concerns: While the Point of Interconnection (POI) is listed as "Onsite," which is a significant advantage, a title report is required to identify any existing utility easements, access restrictions, or other encumbrances that could impact the BESS array layout. A new easement will likely be required by the interconnecting utility for the gen-tie line and any associated equipment, even if the POI is on the parcel.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is currently "Unknown." This represents a critical data gap and a potential fatal flaw. Development within a high-risk flood zone (e.g., Zone A, AE) would introduce significant design challenges, increase costs for elevating equipment, and could face permitting denial. A FEMA Flood Insurance Rate Map (FIRM) review is an immediate priority.

Wetlands: The presence of wetlands is also "Unknown." Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. The presence of jurisdictional wetlands would trigger significant setback requirements (typically 100-foot buffer zones) and a lengthy, complex permitting process through the Palmer Conservation Commission. A desktop screening using the National Wetlands Inventory (NWI) is the first step, likely to be followed by a full field delineation.

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

Brownfield/Superfund Status: The presence of a brownfield site within two miles is noted. This poses a minor risk of potential subsurface contamination migrating onto the subject property. A Phase I Environmental Site Assessment (ESA) is strongly recommended to assess this risk. Importantly, the project site itself is not designated as a brownfield, and the project does not qualify as being in an "Energy Community," meaning it is ineligible for the 10% IRA brownfield bonus adder.

Pipeline Proximity: No gas pipelines are identified within a three-mile radius, which is a significant safety and design advantage, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site is located approximately 1 mile from the Palmer Substation, which has a maximum voltage of 115 kV. A 115 kV transmission line operated by "FITCHBURG GAS AND ELECTRIC LIGHT COMPANY" (likely a data error, as this area is served by National Grid) is just 0.6 miles away. This robust grid infrastructure in close proximity is a primary strength of the site.

Interconnection Recommendation: For a distribution-scale project (≤5MW), a 115 kV transmission-level interconnection would be cost-prohibitive. The most viable path is an interconnection to a local distribution feeder. The data point "POI Onsite" suggests a distribution line may already traverse the property or run along Boston Road. The likely interconnection voltage would be in the 13.2 kV to 23 kV range. Verification of a viable three-phase distribution feeder with available capacity is the single most important grid-related diligence item.

Cost & Timeline: Assuming a viable distribution feeder is