⚡ RIVER ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis – APN 112_27, RIVER ST, Easthampton, MA

This report provides a comprehensive due diligence analysis for the subject property located on River Street in Easthampton, Hampshire County, Massachusetts. The site presents a compelling opportunity due to its excellent grid proximity and significant IRA incentive potential. However, substantial risks related to environmental constraints, regulatory approvals, and fundamental site characteristics must be addressed before committing further capital.

1. Site Access & Topography

The property is located on "River St," which suggests it is adjacent to a public right-of-way. However, the quality of this road is unknown and requires immediate verification. A key initial diligence item is to confirm whether River St is a paved, public road capable of supporting heavy-haul trucks. Based on satellite imagery of the surrounding agricultural area, the terrain is likely flat to gently rolling, which is generally favorable for BESS construction. The primary concern is the soil's load-bearing capacity, given the potential for alluvial deposits near a river.

A significant red flag is the discrepancy in reported acreage: the master data indicates 24.46 acres, while the Regrid parcel data shows only 2.68 acres. This must be resolved immediately via a title search and survey. A 2.68-acre site would be extremely constrained for a utility-scale project, likely only supporting a 2-4MW system with limited construction laydown area. A 24-acre site offers much greater flexibility.

Assuming the road access is adequate, delivery of heavy equipment like transformers and containerized BESS units appears feasible, provided there are no low-clearance bridges or weight-restricted roads on the primary access route. A haul route study will be necessary. No access easements are noted, but if the primary access point is not directly on River St, an easement will be required from the landowner and potentially adjacent parcels. This requires verification.

2. Environmental Constraints

The environmental profile of this site is defined by high uncertainty and high potential risk/reward.

• FEMA Flood Zone: The designation is "Unknown." Given the "River St" address and likely proximity to the Connecticut River or a tributary, there is a high probability that portions of the site are within a 100-year (Zone AE) or 500-year (Zone X) floodplain. Any development within a Special Flood Hazard Area would require significant civil engineering (e.g., raising equipment pads above Base Flood Elevation) and could face permitting denial. This is a potential fatal flaw.
• Wetlands: The presence of wetlands is "Unknown" but highly likely due to the location. A desktop National Wetlands Inventory (NWI) screening is the first step, followed by a formal field delineation by a certified wetland scientist. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet) that could severely limit the buildable area.
• Critical Habitat: Data indicates no critical habitat, which is a positive initial finding. This should be cross-referenced with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-listed species are present.
• Brownfield/Superfund: The presence of four listed sites within a two-mile radius is a notable risk that necessitates a Phase I Environmental Site Assessment (ESA). However, this also presents a significant opportunity. If this agricultural site can be qualified as a "brownfield site" under IRA guidelines (e.g., through the discovery of certain contaminants, even if minor), it would be eligible for the 10% Brownfield ITC adder. This transforms a potential liability into a major financial advantage.
• Pipeline Proximity: No major pipelines nearby is a significant safety and layout advantage, reducing the risk of explosion or setback conflicts.

3. Grid Infrastructure & Interconnection

The site's primary strength is its proximity to robust grid infrastructure.

• Substation & Transmission: The property is located just 1.1 miles from a 115 kV substation and only 0.3 miles from a 115 kV transmission line owned by Western Massachusetts Electric Company (an Eversource subsidiary). This dual-option proximity is exceptional.
• Interconnection Recommendation: For a utility-scale project (>5MW), a 115 kV transmission-level interconnection is the most viable path. A direct tap of the line at 0.3 miles would likely be the most cost-effective option, avoiding extensive line construction. For a smaller distribution-scale project (≤5MW), a distribution-level connection from the substation might be possible, but this is often less certain and capacity-constrained. The available distribution capacity requires verification with Eversource.
• Cost & Timeline Estimate: Interconnection in ISO-New England is expensive and slow. A 115 kV line tap at this short distance could range from $3M - $6M for the switchyard, protection equipment, and line work. A new bay at the substation would likely be more expensive, potentially $5M - $10M+. The ISO-NE interconnection queue is notoriously backlogged; a realistic timeline from application to commercial operation is 4-6 years.
• Utility & Process: The interconnecting utility is Eversource, and the RTO is ISO-NE. We would need to enter the formal ISO-NE Interconnection Request queue. An initial Feasibility Study (FS) is recommended to get a preliminary, non-binding cost and timeline estimate.

4. Regulatory & Zoning Analysis

Permitting in Massachusetts is a significant hurdle and requires careful navigation.

• Authority Having Jurisdiction (AHJ): The City of Easthampton Planning Department and Conservation Commission.
• Zoning Compatibility: The current zoning is R-35 (Agricultural/Rural). This zoning designation almost never permits energy storage facilities "by-right." A discretionary permit will be required.
• Permitting Pathway: The most likely pathway is a Special Permit from the Easthampton Planning Board. This process involves public hearings and gives the board significant discretion to approve, deny, or condition the project. We must thoroughly review the Easthampton Zoning Bylaw to see if BESS is a defined use; if not, the path is more uncertain and may require a use variance, which is much harder to obtain. The project will also require an Order of Conditions from the Conservation Commission due to the high likelihood of wetlands or riverfront areas.
• Setbacks & Restrictions: Setback requirements are currently unknown and must be determined from the local bylaw. There is a growing trend of Massachusetts municipalities enacting moratoriums on large-scale solar and BESS projects; a key risk is that Easthampton could enact one during our permitting process. Early and collaborative engagement with the AHJ is critical.

5. IRA/ITC Incentive Analysis