⚡ 42 MASON ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis - "Project Palmer" (42 Mason St, Palmer, MA)

This report provides a comprehensive due diligence analysis for the property located at 42 Mason St, Palmer, Hampden County, MA (APN: 227 2_59). The 3.16-acre site has been evaluated for its suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis concludes that while the site possesses excellent grid infrastructure proximity, significant and likely insurmountable regulatory and land-use challenges render it a high-risk candidate.

1. Site Access & Topography

Road Access: The property has frontage on Mason Street, which appears to be a narrow, local, and potentially unpaved or poorly maintained road based on aerial imagery. The quality of this access is a significant concern for the delivery of heavy equipment.

Equipment Delivery: Delivery of multi-ton components such as transformers, inverters, and containerized battery systems requires roads capable of supporting 80,000-lb tractor-trailers (lowboys). Mason Street, in its current state, is unlikely to be suitable without significant upgrades. Furthermore, its connection to main thoroughfares like US-20 would need to be surveyed for turning radii, bridge weight limits, and overhead line clearances.

Topography & Site Prep: Satellite imagery suggests the parcel is heavily wooded and located in an area with rolling hills, characteristic of Western Massachusetts. Significant tree clearing and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. These site preparation activities will substantially increase construction costs and may trigger additional environmental review for stormwater management (SWPPP).

Easement Concerns: The parcel appears to have direct frontage, but the narrowness of the lot and the road may necessitate temporary construction easements from adjacent landowners for laydown areas and equipment maneuvering. No existing access easements are noted, but this requires a title search for verification.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as Unknown. This is a critical data gap. A review of the FEMA Flood Map Service Center is an immediate next step. Any designation within a 100-year floodplain (e.g., Zone A or AE) would likely render the site unbuildable or require cost-prohibitive mitigation, such as elevating all equipment above the Base Flood Elevation.

Wetlands: The presence of wetlands is Unknown. Given the wooded nature of the site in Massachusetts, there is a high probability of state or federally regulated wetlands and/or vernal pools. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone ("Riverfront Area") around any identified resource areas, which would severely constrain the 3.16-acre parcel's buildable area. A formal wetlands delineation by a certified professional is required.

Habitat & Species: While no critical habitats are flagged in the initial data, a project-specific review with the MA Natural Heritage & Endangered Species Program (NHESP) is necessary to ensure no state-listed rare or endangered species habitat would be impacted.

Brownfield/Superfund Status: The site itself is not a known brownfield. The presence of a superfund site within two miles is noted but is unlikely to impact the subject property directly, though it may be flagged for further review during a Phase I Environmental Site Assessment (ESA). As the site is not a brownfield, it is not eligible for the 10% IRA brownfield tax credit adder, which is a disadvantage.

Pipeline Proximity: No gas pipelines are identified within a three-mile radius, which is a positive finding that eliminates risks associated with pipeline setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: This is the site's strongest attribute. The PALMER substation (115 kV) is only 0.8 miles away, and a 115 kV transmission line owned by Western Massachusetts Electric Company (an Eversource Energy subsidiary) is even closer at 0.6 miles. This proximity is highly desirable.

Interconnection Voltage & Feeder: For a ≤5MW BESS, a transmission-level (115 kV) interconnection would be economically unviable, costing upwards of $5-10 million. The recommended strategy is to interconnect to a distribution-level feeder (e.g., 13.8 kV) originating from the Palmer substation. The key unknown is the availability, routing, and capacity of a suitable 3-phase distribution feeder near the site. A formal interconnection pre-application is required to obtain this information from Eversource.

Estimated Cost & Timeline: Assuming a viable distribution feeder is within 0.8 miles, the interconnection cost for line extensions and substation upgrades could range from $750,000 to $2,000,000. The interconnection process in Massachusetts under ISO-New England is notoriously slow and complex. The timeline from application to commercial operation can realistically be 24-48 months, pending study results and queue position.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): Palmer Town. Permitting will be governed by the Town's Zoning Bylaws and Planning Board.

Zoning Compatibility: The current zoning is RR (Residential-Vacant Land). This is a critical, likely fatal, flaw. BESS facilities are considered an industrial or utility use and are fundamentally incompatible with residential zoning. It is extremely unlikely that a BESS would be a permitted use "by-right."

Permitting Pathway: The project would, at a minimum, require a Special Permit or a Special Exception from the Planning Board or Zoning Board of Appeals. More likely, it would require a Use Variance, which carries a very high legal burden of proof (demonstrating a unique hardship related to the land itself). An alternative, rezoning the parcel, is a lengthy, costly, and politically uncertain process.

Risks: There is a very high risk of significant local opposition (NIMBYism) from adjacent residential property owners, which could lead to a permit denial or a town-wide moratorium on such facilities. The lack of clear BESS regulations in the town's bylaws creates significant uncertainty.

5. IRA/ITC Incentive Analysis

The site's eligibility for key Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) is poor, limiting its financial attractiveness.

• Energy Community: No. Not eligible for the 10% adder. (Requires verification with DOE mapping tool).
• Opportunity Zone: No. Not eligible for the 10% adder.
• Low-Income Community: No. Not eligible for the 10