⚡ 14 HOWARD ST

TO: Sunland America Corp. Investment 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 14 Howard Street in Paxton, Worcester County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

The 2.79-acre subject property is an undeveloped, wooded parcel located on Howard Street, a two-lane, paved local road. Based on satellite imagery review, Howard Street appears to be in fair condition but is relatively narrow and lacks shoulders, which could present challenges for oversized and overweight vehicles.

• Road Access Quality: Access from major state highways (like MA-31 or MA-122) involves navigating several miles of smaller local and residential roads. A detailed transportation route survey would be required to confirm bridge weight limits, turning radii, and overhead line clearances for the delivery of heavy equipment such as transformers, switchgear, and battery containers.
• Terrain Characteristics: The site is heavily wooded and, consistent with the topography of Central Massachusetts, appears to have a moderate slope, descending from the road frontage. Significant clearing, grading, and civil work will be required to create a level pad for the BESS equipment. The cost and feasibility of this work depend on the steepness of the grade, which requires a formal topographical survey.
• Heavy Equipment Feasibility: While access is physically possible, it is not ideal. The primary concern is the final approach and entry onto the site itself. A new curb cut and a robust, graded access drive would need to be constructed from Howard Street. The ability to stage multiple large trucks and a crane on-site will be constrained by the parcel's small size and slope.
• Easement Concerns: No existing access easements are noted, as the property has direct frontage on a public road. However, easements for the new electrical interconnection line will be a major factor, given the distance to the substation.

2. Environmental Constraints

The site presents several significant environmental unknowns that must be resolved before committing capital. While it avoids some major flags, the potential for wetlands is a primary concern.

• FEMA Flood Zone: The FEMA designation is currently Unknown. This is a critical data gap. Any location within a Special Flood Hazard Area (e.g., Zone A, AE) would likely render the site undevelopable for critical infrastructure like a BESS or add substantial costs for elevating all equipment above the Base Flood Elevation. This must be verified immediately via the FEMA Map Service Center.
• Wetlands Presence: The presence of wetlands is Unknown. Given the site is undeveloped and wooded in Massachusetts, there is a high probability of jurisdictional wetlands, vernal pools, or bordering vegetated wetlands being present. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet) that would severely restrict the buildable area on this small 2.79-acre parcel. A formal wetlands delineation is an essential and immediate next step.
• Critical Habitat / Species Risk: The data indicates no critical habitat or protected areas on site, which is a significant positive. This reduces the risk of lengthy and complex consultations with US Fish and Wildlife Service or MassWildlife.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential environmental liability and cleanup costs, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable disadvantage for project economics.
• Pipeline Proximity: No gas transmission pipelines are located nearby, eliminating risks related to pipeline safety setbacks and potential co-location restrictions.

3. Grid Infrastructure & Interconnection

The grid infrastructure is the most significant challenge and likely a fatal flaw for this site. The distance to viable points of interconnection (POI) is well beyond the typical range for an economically viable distribution-scale project.

• Nearest Substation: The Cooks Pond substation is 1.6 miles away. This is a prohibitive distance for a new distribution feeder. The substation's 69kV bus indicates it is a source for local distribution circuits, likely at a voltage of 13.2kV or similar. While capacity may be available, the cost to reach it is extreme.
• Transmission Proximity: The nearest transmission line (115kV) is 2.6 miles away. Interconnecting at transmission voltage is non-viable for a project of this size (≤5MW) due to the high cost of a dedicated switchyard and the even greater line extension expense.
• Recommended Interconnection: The only plausible interconnection would be at distribution voltage (e.g., 13.2kV) via a new, dedicated feeder built from the Cooks Pond substation to the project site.
• Estimated Cost & Timeline: A 1.6-mile overhead distribution line extension in this area could cost between $1.5M - $3.0M, and potentially more if significant undergrounding is required. This cost alone could make a ≤5MW BESS project uneconomical. The timeline for study, design, permitting, and construction of such a line by the utility (likely National Grid) would be extensive, easily 24-36 months after the interconnection application is deemed complete.
• Utility & Queue: The interconnecting utility is Requires Verification but is likely National Grid. The Massachusetts interconnection process (MASS-ACA) is notoriously complex, backlogged, and expensive. Queue times are long, and study costs are high.