⚡ 14 HOWARD ST

MEMORANDUM

TO: Sunland America Corp. Development Team

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 potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis reveals several significant challenges related to zoning, grid access, and financial incentives that present substantial risk to project viability.

1. Site Access & Topography

Road Access: The property is located on Howard Street in Paxton, MA. Initial desktop review using aerial and street-level imagery indicates that Howard Street is a narrow, local residential road. It appears to be paved but may lack the width and structural integrity to support heavy haul trucks (low-boys) required for transporting multi-ton battery containers, transformers, and switchgear. A formal road survey and potentially a geotechnical analysis would be required to confirm its suitability. The need for temporary road closures, traffic management plans, and potential road reinforcement would likely add significant cost and complexity to construction.

Topography & Equipment Access: The terrain in this part of Worcester County is typically characterized by rolling hills, wooded areas, and rocky soil. The 2.79-acre parcel appears undeveloped and moderately wooded. Significant clearing, grading, and site preparation will be necessary. The feasibility of maneuvering large cranes for equipment placement (e.g., setting a 50-ton transformer) is a concern given the narrow access and likely uneven terrain. The small parcel size offers little room for construction staging and laydown areas.

Easements: The parcel's configuration and direct frontage on Howard Street suggest a direct access point may be possible. However, an access easement from the Town of Paxton would be required for any curb cuts or driveway construction. More importantly, a utility easement will be required for the interconnection line, the path and cost of which are major unknowns.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is listed as Unknown. This is a critical data gap. A review of the FEMA Flood Insurance Rate Maps (FIRM) is an immediate next step. If any portion of the buildable area is within a Special Flood Hazard Area (e.g., Zone A, AE), it would trigger significant design constraints, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing civil engineering costs and potentially rendering the site economically unviable.

Wetlands: The presence of wetlands is also Unknown. Given the undeveloped nature of the land in this region, there is a high probability of state or federally regulated wetlands and/or vernal pools being present. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around most wetland resource areas, within which development is heavily restricted. On a small 2.79-acre site, the presence of even a small wetland feature could eliminate the majority of the buildable area. A desktop screening using MassGIS OLIVER is the first step, to be followed by a formal field delineation by a Professional Wetland Scientist if the project moves forward.

Other Constraints:

• Critical Habitat / Species: The data indicates no known critical habitat, which is a positive. This should be verified with the MA Natural Heritage & Endangered Species Program (NHESP) database.
• Brownfield/Superfund: The absence of a brownfield designation means we avoid potential remediation liability. However, it also means the project is ineligible for the 10% IRA Brownfield Tax Credit Adder, a notable financial disadvantage.
• Pipeline Proximity: No pipelines within 3 miles is a significant safety and layout advantage, eliminating setback concerns related to high-pressure gas lines.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation, COOKS POND, is 1.6 miles away and has a maximum voltage of 69 kV. The nearest transmission line is a 115 kV line 2.6 miles away. For a distribution-scale project (≤5MW), a 2.6-mile interconnection to a 115 kV line is not financially or technically feasible. A 1.6-mile interconnection to the 69 kV bus at the substation would also be exceptionally expensive, likely costing well over $2 million for the line extension alone, which would be a fatal flaw for a project of this size.

Recommended Interconnection & Feeder: The only viable path for this project is to interconnect to a