⚡ 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 site presents a compelling opportunity due to its exceptional grid infrastructure access, but carries significant risks related to regulatory and environmental unknowns that must be addressed immediately.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has direct frontage on Boston Road (U.S. Route 20), a major, publicly maintained thoroughfare. This provides excellent and unrestricted access for all phases of development, from initial surveying to the delivery of heavy equipment. Large trucks carrying battery containers, power conversion systems (PCS), and the main power transformer should have no issue accessing the site entrance. The proximity to major highways like the I-90 Massachusetts Turnpike further enhances logistical efficiency.

Terrain & Topography: Based on aerial imagery and the "Good" buildability rating, the site appears to be relatively flat and partially cleared, consistent with its industrial zoning designation. Minimal grading is anticipated, which would reduce civil construction costs and timelines. The parcel appears to be at-grade with the adjacent road, simplifying the construction of an access drive.

Heavy Equipment Feasibility: Access is deemed highly feasible. The primary constraint would be the load-bearing capacity of the internal site access road to be constructed, which is a standard civil engineering consideration. There are no apparent low-clearance bridges, tight turns, or other logistical barriers on the primary access route (US-20).

Easement Concerns: The data indicates "POI Onsite," which strongly suggests a pre-existing utility right-of-way or easement crossing the property. While this is highly advantageous for interconnection, a full title search is mandatory to understand the exact location, width, and restrictions associated with this easement. We must ensure that the BESS equipment layout does not infringe upon the utility's access or operational rights. Additional access easements are not anticipated to be required given the direct public road frontage.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap and a potential fatal flaw. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design changes, such as elevating all equipment on platforms, and could face permitting challenges. A FEMA FIRMette must be procured immediately to determine the site's status.

Wetlands: The presence of wetlands is "Unknown." Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), which mandate significant setbacks (typically 100-foot buffer zones) from any delineated wetland resources. The presence of wetlands could severely constrain the buildable area. A desktop National Wetlands Inventory (NWI) screening is the immediate first step, to be followed by a formal field delineation if any potential resources are identified.

Critical Habitat / Endangered Species: The data indicates "None" for critical habitat or protected areas, which is a significant positive. This reduces the risk of lengthy and complex consultations with the U.S. Fish and Wildlife Service (USFWS) or the Massachusetts Division of Fisheries and Wildlife (MassWildlife).

Brownfield/Superfund Status: The presence of a brownfield/superfund site within two miles is a dual-edged sword. Risk: A Phase I Environmental Site Assessment (ESA) is non-negotiable to ensure no contamination has migrated to our target parcel. Opportunity: If our specific parcel can be classified as a "