⚡ WEST ST

MEMORANDUM

TO: Sunland America Corp. Development Team

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 111 2_C_11-_1 (West St, Granby, MA)

This report provides a comprehensive due diligence analysis for the subject property located on West Street in Granby, Hampshire County, Massachusetts. The site presents a compelling grid interconnection opportunity but faces significant, potentially fatal flaws related to zoning and regulatory approval. The following sections detail the findings of our initial evaluation.

1. Site Access & Topography

Road Access: The property is located on West Street, which appears to be a two-lane, paved local road based on aerial imagery. The quality seems sufficient for standard construction traffic. However, a detailed route survey is required to confirm its suitability for oversized and overweight loads, such as a main power transformer on a lowboy trailer or 40-foot battery containers. We must verify the absence of low-clearance bridges, sharp turning radii, or seasonal weight restrictions on the likely delivery route from the nearest major highway.

Terrain & Equipment Access: Based on regional topography, the site is likely to have some rolling hills, characteristic of Western Massachusetts. A detailed topographical survey is essential. The current parcel appears to be undeveloped woodland. Significant clearing and grading will be required to create a level pad for the BESS equipment. The ability for heavy equipment like cranes, drill rigs, and delivery trucks to navigate from West Street onto the site itself is a key unknown. The current lack of a formal entrance will necessitate the construction of a new, robust access road capable of supporting heavy loads.

Easements: A new access easement will need to be secured from the property line to the project footprint. Given the owner is a single individual, this should be straightforward to negotiate as part of a lease or purchase agreement. No other access easement concerns are immediately apparent, but a title search is required to confirm.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. If any portion of the buildable area is within a 100-year floodplain (Zone AE) or an unstudied floodplain (Zone A), it could render the site unsuitable or add substantial costs for elevating all equipment above the Base Flood Elevation (BFE). This must be determined immediately via the FEMA Flood Map Service Center.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) which often include 100-foot buffer zones where development is heavily restricted. A desktop review using the National Wetlands Inventory (NWI) is the first step, but a formal field delineation by a certified wetland scientist will be required to confirm the absence or extent of any jurisdictional wetlands. This is a major potential constraint on the buildable acreage.

Habitat & Protected Species: The initial screen shows no critical habitat or protected areas on site, which is a positive finding. A Phase I Environmental Site Assessment (ESA) should still be conducted to confirm this and to satisfy financing and permitting requirements.

Site Contamination: The property has no known brownfield or superfund sites nearby. While this eliminates the risk of environmental liability, it also means the project is not eligible for the 10% IRA brownfield ITC adder, which is a commercial disadvantage.

Pipeline Proximity: No major gas pipelines are located within three miles. This significantly reduces safety risks and siting complexity, eliminating the need for specialized pipeline impact studies.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The site's primary strength is its exceptional proximity to high-voltage infrastructure. A 115 kV transmission line owned by Western Massachusetts Electric Company (Eversource) is located just 0.1 miles from the parcel. The nearest substation (TAP140793) is 0.7 miles away and is also on the 115 kV system. This proximity dramatically reduces the length and cost of the generator lead line.

Interconnection Point & Voltage: The most logical Point of Interconnection (POI) is a direct tap of the adjacent 115 kV transmission line. Interconnecting at transmission voltage is ideal for a utility-scale BESS as it avoids potential capacity constraints on the local distribution system. A distribution-level interconnection is not a viable option here.

Cost & Timeline: A 115 kV transmission tap is a capital-intensive undertaking. It will require constructing a new project substation with high-voltage breakers, switches, and a main power transformer. Estimated interconnection costs are likely in the $3M - $6M range. The timeline will be protracted, governed by the ISO New England (ISO-NE) interconnection queue process. From application to a signed Interconnection Agreement can take 18-24 months, with an additional 24-36 months for utility construction and equipment procurement.

Utility & Process: The interconnecting utility is Eversource, and the RTO is ISO-NE. The ISO-NE queue is known to be complex and backlogged. A formal interconnection application must be filed as soon as possible to secure a queue position, but this requires a significant financial deposit and demonstration of site control.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Granby, MA.

Zoning Compatibility: This is the site's most significant risk. The property is zoned RS (Residential Single-Family). A utility-scale BESS is an industrial use and is fundamentally incompatible with this zoning designation. It is almost certain that BESS is not a permitted use "by-right" in this zone.