⚡ 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 property presents a compelling opportunity due to its excellent grid proximity and apparent buildability, but it is encumbered by significant regulatory uncertainty and a lack of financial incentives that require immediate investigation.

1. Site Access & Topography

• Road Access & Equipment Delivery: The site has direct frontage on Boston Road (US Route 20), a major public thoroughfare. This provides excellent, year-round access for all phases of development, from initial surveying to final equipment delivery. US-20 is a suitable haul route for heavy and oversized loads, including battery containers, medium-voltage transformers, and construction cranes.
• Terrain Characteristics: Based on aerial imagery, the site appears to be relatively flat and previously cleared or developed, consistent with its industrial zoning designation. The "Good" buildability rating in the provided data supports this assessment. This topography will likely minimize the need for extensive grading, reducing civil engineering costs and construction timelines.
• Heavy Equipment Accessibility: The combination of direct access from a major highway and flat terrain makes the site highly accessible for all necessary heavy equipment. There are no apparent obstructions like low bridges, narrow roads, or steep grades that would impede delivery or on-site maneuvering.
• Easement Concerns: While public road access is secure, a full title report is required to identify any potential utility easements, access restrictions, or rights-of-way that could encumber the buildable area. Given the industrial nature of the area, existing utility easements are likely but are not anticipated to be a fatal flaw. This requires verification.

2. Environmental Constraints

• FEMA Flood Zone: The site's flood zone designation is currently Unknown. This is a critical data gap. Development within a Special Flood Hazard Area (e.g., Zone AE) would necessitate elevating all equipment above the Base Flood Elevation, adding significant cost and complexity. A FEMA FIRMette must be generated immediately to assess this risk.
• Wetlands Presence: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws, and the presence of jurisdictional wetlands would trigger significant setback requirements (typically 100-foot buffer zones) under the Massachusetts Wetlands Protection Act, potentially reducing the buildable acreage. A desktop screening using National Wetlands Inventory (NWI) data is an immediate next step, to be followed by a formal wetland delineation if necessary.
• Critical Habitat / Endangered Species: The data indicates no designated Critical Habitat on site. However, a formal check of the USFWS IPaC system and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is required to screen for any state or federally listed species that could require consultation or mitigation.
• Brownfield/Superfund Status: The presence of one Superfund/brownfield site within two miles is noted. This presents both a risk (potential for contaminant migration onto the subject parcel) and an opportunity. A Phase I Environmental Site Assessment (ESA) is mandatory to assess contamination risk and to determine if the subject parcel itself could qualify as a "brownfield site" under IRA guidelines, which would make the project eligible for a 10% ITC adder.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a significant positive, eliminating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

• Nearest Substation & Transmission: The site is exceptionally well-located with respect to grid infrastructure. The Palmer Substation (115 kV) is approximately 1 mile away, and a 115 kV transmission line is even closer at 0.6 miles. The data also indicates "POI Onsite," which is a major potential advantage.
• Likely Interconnection Voltage: For a ≤5MW BESS project, a transmission-level (115 kV) interconnection would be cost-prohibitive. The most viable path is a distribution-level interconnection, likely at 13.2 kV. The "POI Onsite" data point strongly suggests a 3-phase distribution feeder is either on or immediately adjacent to the property along Boston Road, which would be the ideal Point of Interconnection (POI).
• Feeder Configuration: Requires verification via a site visit and utility consultation. The target would be a 3-phase overhead distribution line with sufficient thermal capacity. The utility for this area is likely National Grid, operating within the ISO New England (ISO