⚡ 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 (≤5MW) Battery Energy Storage System (BESS) based on key development criteria. The overall recommendation is a NO GO due to significant, likely insurmountable, challenges related to zoning and grid interconnection.

1. Site Access & Topography

Road Access & Feasibility: The subject parcel is located on Howard Street, which appears to be a minor local road in a residential area. Initial desktop review suggests access may be via an unpaved or gravel drive. The quality of this access is a significant concern for heavy equipment delivery. A full logistics and transportation study would be required to confirm if the road network can support the weight and turning radii of flatbed trucks carrying battery containers (approx. 80,000 lbs) and a main power transformer (often exceeding 100,000 lbs). Road upgrades would likely be required at significant cost.

Terrain Characteristics: As is typical for Worcester County, the site is expected to have rolling topography. Satellite imagery shows the 2.79-acre parcel is heavily wooded. This will necessitate extensive clearing and grading, increasing site preparation costs and potentially triggering local tree removal ordinances. A formal topographic survey is required to assess slope and determine the final buildable area.

Heavy Equipment Access: Access is rated as poor. The combination of a minor residential street, a potentially unpaved final approach, and wooded, rolling terrain presents a high risk for construction logistics.

Easement Concerns: Significant easement concerns exist, primarily related to the 1.6-mile interconnection route to the Cooks Pond substation. Acquiring permanent utility easements from dozens of private landowners along this route would be an extremely time-consuming (24+ months) and expensive process with a high risk of failure. Furthermore, the legal status of the site's direct access from Howard Street requires verification to ensure no access easements are needed from adjacent property owners.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. Any location within a Special Flood Hazard Area (e.g., Zone A, AE) would render the site unsuitable or require costly mitigation measures like elevating all equipment, which is often infeasible for BESS.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly likely given the site's wooded nature in this region of Massachusetts. The Massachusetts Wetlands Protection Act imposes strict regulations, including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A formal wetland delineation is mandatory and could severely constrain the buildable area on this small parcel.

Critical Habitat / Endangered Species: The initial screen shows no designated critical habitat on site, which is a positive finding. However, a formal desktop review using the USFWS IPaC tool and MassGIS data is recommended to confirm no state or federally listed species have ranges that overlap with the project area.

Brownfield/Superfund Status: The site is not a brownfield, which avoids potential environmental liability but also makes it ineligible for the 10% IRA Brownfield ITC adder.

Pipeline Proximity: No major gas transmission pipelines are located near the site, mitigating a key safety and setback risk.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The closest point of interconnection (POI) is the Cooks Pond Substation, located 1.6 miles from the site. This is a prohibitive distance for a distribution-scale project. The substation's 69kV bus indicates it has sub-transmission capacity, but it would likely serve distribution feeders at a lower voltage (e.g., 13.2kV). The nearest transmission line (115kV at 2.6 miles) is not a viable POI for a project of this size due to extreme cost and complexity.

Recommended Interconnection: The only plausible interconnection would be at distribution voltage (likely 13.2kV) via a new dedicated feeder line constructed from the Cooks Pond Substation to the project site.

Estimated Cost & Timeline: The 1.6-mile distribution line extension is the project's primary economic fatal flaw. A high