⚡ 14 HOWARD ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 14 Howard St, Paxton, MA (APN: 29_32)

This report provides a comprehensive due diligence analysis for the property located at 14 Howard Street in Paxton, Worcester County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale Battery Energy Storage System (BESS) of up to 5MW. The findings indicate severe challenges across multiple critical categories, leading to a recommendation against proceeding with this site.

1. Site Access & Topography

Road Access & Feasibility: Initial desktop review using satellite and street-level imagery indicates that site access is a significant and potentially fatal flaw. Howard Street is a narrow, local road. The parcel itself appears to be accessed via a long, unpaved, and narrow driveway that may be shared with other residential properties. This access route is wholly inadequate for the transportation of heavy BESS equipment.

Heavy Equipment Access: Delivery of multi-ton battery containers, pad-mount transformers, and switchgear requires wide, stable roads with sufficient turning radii and vertical clearance. The existing access appears to fail on all counts. Significant, costly road construction and widening would be required, likely extending over 1,000 feet from the main road.

Topography: The site is heavily wooded and, consistent with the central Massachusetts region, appears to have rolling topography with a noticeable grade change. This will necessitate substantial clearing, grubbing, and grading, increasing site preparation costs significantly. A formal topographical survey would be required to quantify the earthwork needed.

Easement Concerns: There is a high probability that the access driveway is either private or shared. Securing a permanent, heavy-haul-rated access easement from abutting residential landowners would be a prerequisite. This process is often time-consuming, expensive, and fraught with legal and community-relations risks. It is a major barrier to development.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Requires Verification. Siting critical infrastructure like a BESS within a Special Flood Hazard Area (e.g., Zone A, AE) is generally prohibited or requires extensive, cost-prohibitive mitigation measures like elevating all equipment above the Base Flood Elevation. This is a critical go/no-go data point that must be confirmed immediately via the FEMA Flood Map Service Center.

Wetlands: The presence of wetlands is Requires Verification. Given the undeveloped, wooded nature of the parcel in this region, there is a high likelihood of state- and federally-jurisdictional wetlands and/or vernal pools. Massachusetts has a stringent Wetlands Protection Act (M.G.L. c. 131, § 40) that imposes significant buffer zones (typically 100 feet) where development is heavily restricted. The presence of wetlands could easily render the 2.79-acre parcel unbuildable.

Habitat & Protected Species: The data indicates no known critical habitat or protected areas on site, which is a positive. However, a formal desktop review using the USFWS IPaC tool and MassGIS data layers is a standard diligence step to confirm no state-listed species (e.g., under the Massachusetts Endangered Species Act) are present.

Brownfield/Superfund Status: The site is not a brownfield. This is a double-edged sword: it reduces the risk of encountering soil contamination and associated liability, but it also means the project is ineligible for the 10% IRA Brownfield Adder, making it less financially competitive.

Pipeline Proximity: The absence of major gas transmission pipelines within three miles is a significant safety and design advantage, eliminating the need for specialized risk assessments