⚡ 4 BOSTON RD

MEMORANDUM

TO: Sunland America Corp. Investment Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis – Palmer, MA (APN: 227 3_6_1)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project located at 4 Boston Road in Palmer, Hampden County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) BESS project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from direct frontage on Boston Road (U.S. Route 20), a major public thoroughfare. This level of access is excellent and highly advantageous for construction. It can readily accommodate oversized and overweight vehicles required for delivering heavy equipment such as multi-ton transformers, power conversion systems (PCS), and containerized battery enclosures. No significant road upgrades are anticipated to be necessary for construction access.

Terrain Characteristics: While a formal topographical survey is required, the site's location in Palmer, MA, and its "Good" buildability rating suggest a landscape of gently rolling hills. A preliminary review of aerial imagery indicates the parcel is largely cleared and relatively flat, particularly the portions fronting Boston Road. This likely minimizes the need for extensive civil work and grading, reducing site preparation costs. The parcel appears to have been previously disturbed or used for industrial/commercial purposes, which often results in favorable, pre-graded conditions.

Heavy Equipment Access: Given the direct access from U.S. Route 20, there are no apparent constraints on the delivery and staging of heavy equipment. The primary consideration will be designing an appropriate internal site access road from the main entrance to the BESS pad location to support crane and delivery truck loads.

Easement Concerns: Requires Verification. While road access is public, a title search is necessary to identify any existing utility easements, access easements for neighboring properties, or other encumbrances that could restrict the placement of the BESS array and associated infrastructure. The discrepancy between the total parcel acreage (21.67 acres) and the Regrid-listed acreage (12.66 acres) must be resolved, as it may indicate subdivisions or easements not immediately apparent.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This represents a critical data gap and a potential fatal flaw. An immediate review of FEMA Flood Insurance Rate Maps (FIRMs) is required. If the buildable area is located within a Special Flood Hazard Area (e.g., Zone AE), development costs will increase substantially due to the need to elevate all equipment above the Base Flood Elevation, or the site may be rendered undevelopable.

Wetlands: Requires Verification. The presence of wetlands is unknown and poses a significant risk. Massachusetts has stringent wetland protection regulations under the Wetlands Protection Act. A desktop screening using the National Wetlands Inventory (NWI) is the first step, but a formal wetland delineation by a certified professional will be required. Any identified wetlands will necessitate a 100-foot buffer zone, which could severely constrain the buildable area of the parcel.

Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, a formal request to the U.S. Fish and Wildlife Service's IPaC system and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) is recommended to confirm the absence of state or federally listed species whose habitats could be impacted by development.

Brownfield/Superfund Status: The presence of one Superfund/brownfield site within two miles is a dual-edged sword. A Phase I Environmental Site Assessment (ESA) is mandatory to determine if our target parcel has a history of contamination. If the site itself is a designated brownfield, it could be eligible for the 10% Investment Tax Credit (ITC) adder under the Inflation Reduction Act (IRA), turning a potential liability into a financial advantage. If a neighboring property is the source of contamination, the Phase I ESA must assess the risk of contaminant migration onto our site.

Pipeline Proximity: The absence of major gas pipelines within a three-mile radius is a significant safety and permitting benefit, eliminating a common source of project complexity and setback constraints