⚡ 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 potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis covers key evaluation criteria including site access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access & Equipment Delivery: The subject property has direct frontage on Howard Street, a two-lane, paved local road. A preliminary review via satellite imagery suggests the road is in fair condition but may be narrow in sections. Feasibility for heavy equipment delivery is a concern. A low-boy trailer transporting a 30-40 ton transformer or a 53-foot BESS container would require careful route planning. Turns from major arteries like Route 31 onto local roads leading to the site must be evaluated for turning radii. A formal route survey is required to confirm access for oversized and overweight vehicles.

Topography: Located in Worcester County, the regional terrain is characterized by rolling hills. The 2.79-acre parcel appears to have some slope, which is typical for the area. Significant grading and civil work may be necessary to create a level pad for the BESS equipment, switchgear, and access roads. This could increase site preparation costs. A formal topographic survey is essential to quantify the required earthwork and inform the site layout.

Heavy Equipment Access to Site: While the property fronts the road, the specific location of a new curb cut and access drive will need to be permitted by the Paxton Department of Public Works. The load-bearing capacity of Howard Street and any culverts or small bridges along the delivery route must be verified. There are no obvious barriers like low-clearance overpasses, but this requires confirmation.

Easement Concerns: As a vacant residential lot, there is a risk of unrecorded or pre-existing utility or access easements that could encumber the property. A full ALTA survey and title report are necessary to identify any such restrictions that could limit the buildable area.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone status is listed as "Unknown." Immediate verification using the FEMA Flood Map Service Center is a critical next step. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase substantially due to requirements for elevating equipment above the Base Flood Elevation, and permitting may be impossible. If it is in Zone X (minimal risk), this would be a significant positive.

Wetlands: The presence of wetlands is "Unknown." A desktop review using the USFWS National Wetlands Inventory (NWI) mapper should be conducted immediately. Regardless of the NWI results, a formal wetlands delineation by a certified professional is non-negotiable. Massachusetts has stringent wetlands protection laws (Massachusetts Wetlands Protection Act), and the Paxton Conservation Commission will enforce buffer zones (typically 50-100 feet) that would directly reduce the buildable acreage.

Critical Habitat / Endangered Species: The data indicates no critical habitat on site, which is a positive finding. This should be confirmed with a formal desktop screening using the USFWS IPaC tool to ensure no federally listed species or habitats are impacted.

Brownfield/Superfund Status: The site is not a brownfield, with no superfund sites within a 2-mile radius. While this mitigates environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, a notable economic disadvantage compared to other potential sites.

Pipeline Proximity: The absence of gas pipelines within a 3-mile radius is a major safety and layout advantage, eliminating significant setback and risk mitigation requirements.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is Cooks Pond, located 1.6 miles away, with a maximum voltage of 69 kV. This 69 kV line is sub-transmission. For a ≤5MW BESS project, interconnection would almost certainly be to a distribution feeder originating from this substation, likely at a voltage of 13.2 kV. The 1.6-mile distance is a major project risk.

Interconnection Cost & Timeline: A 1.6-mile distribution line extension represents a significant capital expenditure. A rough order-of-magnitude cost for this work could range from $1.5M to $3M+, depending on whether new poles are required, the number of road crossings, and make-ready work on existing poles. This cost could render a 5MW project economically unviable. The timeline for such a utility upgrade can easily exceed 24 months post-execution of an Interconnection Agreement (IA).

Interconnecting Utility & Process: The utility is not specified but is likely the Paxton Municipal Light Department (PMLD). Interconnecting with a municipal utility presents unique challenges compared to an ISO-NE utility. Their interconnection process may be less defined, and their distribution system may have limited capacity to host new generation. Understanding PMLD's specific technical requirements, queue process, and prior experience with BESS is a paramount, immediate task.

Feeder Configuration: A 3-phase distribution feeder would need to be extended to the site. The route feasibility, right-of-way acquisition, and environmental permitting for this 1.6-mile extension are all significant unknowns and potential sources of delay and cost.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Paxton is the AHJ. Permitting will be handled by the Paxton Planning Board, Zoning Board