⚡ 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 14 Howard Street in Paxton, Worcester County, Massachusetts. The 2.79-acre parcel presents a mix of opportunities and significant challenges. The analysis concludes with a site suitability score, a summary of key risks, and a recommended course of action.

1. Site Access & Topography

• Road Access & Equipment Delivery: The site has frontage on Howard Street, which appears to be a narrow, local residential road based on aerial imagery. The quality of this road for heavy haul trucks is a significant concern. A detailed route survey is required to assess turning radii, road width, weight limits, and potential obstructions like low-hanging utility lines that could impede the delivery of 40-foot battery containers, a step-up transformer, and construction cranes. Access appears constrained and may require temporary road improvements or traffic management plans, increasing cost and complexity.
• Terrain Characteristics: As is typical for Worcester County, the site is wooded and the topography is likely to be rolling or hilly with potential for rock ledge. This assumption requires verification with a formal topographical survey and geotechnical analysis. Significant grading and site preparation will almost certainly be necessary, increasing civil engineering costs. The presence of bedrock near the surface could substantially increase foundation costs.
• Heavy Equipment Accessibility: On-site accessibility is currently non-existent. A new access road would need to be cut from Howard Street onto the property. The feasibility and cost of this road will depend entirely on the site's topography, soil conditions, and any environmental setbacks (e.g., from wetlands).
• Easement Concerns: Requires Verification. While the parcel appears to have direct road frontage, the exact width and suitability of this frontage is unknown. A title search is necessary to confirm there are no existing access easements burdening the property or to determine if easements from neighboring properties would be required for either construction or utility interconnection routing.

2. Environmental Constraints

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown and represents a critical data gap. A desktop review using the FEMA Map Service Center is an immediate next step. If any portion of the buildable area falls within a Special Flood Hazard Area (e.g., Zone A or AE), it would likely render the site undevelopable for critical infrastructure like a BESS or require cost-prohibitive mitigation measures like elevating all equipment pads above the Base Flood Elevation.
• Wetlands: Requires Verification. The presence of wetlands is a high-risk factor. Massachusetts has a stringent Wetlands Protection Act (WPA) with significant buffer zone requirements (typically 100 feet). Given the undeveloped, wooded nature of the site, there is a high probability of state or federally regulated wetlands, streams, or vernal pools. A formal wetlands delineation is essential and could severely restrict the buildable acreage, potentially making a 5MW project infeasible.
• Critical Habitat / Endangered Species: The initial data indicates no critical habitat. This is a positive finding, but it must be verified via a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database. Any overlap with priority habitats could trigger lengthy consultations and potential time-of-year restrictions on construction.
• Brownfield/Superfund Status: The site is not a brownfield. This is a disadvantage from an incentives perspective, as it makes the project ineligible for the 10% IRA brownfield tax credit adder. However, it is an advantage from a risk and liability perspective, as it avoids potential soil contamination and costly remediation efforts.
• Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and permitting advantage, eliminating the need for specialized risk assessments and setbacks associated with such infrastructure.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The Cooks Pond substation is located 1.6 miles from the site. This is a feasible, but not ideal, distance for a distribution line extension. The substation's 69 kV maximum voltage indicates it is a transmission-fed substation that almost certainly has distribution-level voltage buses (e.g., 13.2 kV or 23 kV) suitable for a project of this scale. The interconnecting utility is National Grid.
• Transmission Proximity: A 115kV transmission line is 2.6 miles away. This is too far and at too high a voltage to be a viable Point of Interconnection (POI) for a ≤5MW BESS project; costs would be prohibitive.
• Recommended Interconnection: The only viable path is a distribution-level interconnection to a feeder from the Cooks Pond substation. Requires Verification: A key unknown is whether a suitable three-phase distribution feeder runs along Howard Street or a nearby thoroughfare. A "line walk" or utility map review is needed to confirm feeder availability.
• Estimated Cost & Timeline: A 1.6-mile overhead distribution line extension is a major cost driver. A rough order-of-magnitude cost estimate is $1.5M - $3.0M, highly dependent on terrain, pole replacements, rock drilling, and road crossing requirements. The National Grid interconnection process in Massachusetts under ISO-NE is