⚡ 14 HOWARD ST

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 29_32 (14 Howard St, Paxton, MA)

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) project based on key development criteria. The final recommendation is a NO GO for this site due to multiple fatal flaws identified in the grid infrastructure and regulatory sections.

1. Site Access & Topography

Road Access & Feasibility: The subject property is located at the end of Howard Street, a small residential cul-de-sac. Access appears to be extremely constrained. Public roads leading to the site are local residential streets not designed for heavy industrial traffic. The feasibility of transporting heavy and oversized equipment, such as a 30-50 ton main power transformer or 80,000 lb battery containers, is highly questionable. Significant logistical challenges, including temporary road closures, traffic management plans, and potential road damage, are anticipated. The turning radius at the end of the cul-de-sac is likely insufficient for standard delivery vehicles.

Terrain Characteristics: Based on aerial imagery and regional topography, the 2.79-acre parcel is heavily wooded and situated in a region of rolling hills characteristic of Central Massachusetts. Significant clearing, grading, and civil work would be required to create a level pad for the BESS equipment. A formal topographic survey is required, but we anticipate moderate to steep slopes, which will increase site preparation costs substantially.

Easement Concerns: The parcel appears to have limited or no direct, improved frontage on Howard Street. Requires Verification: A title search and survey are needed to confirm legal access. It is highly probable that an access easement across an adjacent residential property would be required, which presents a major acquisition risk and cost. Securing such an easement from a residential homeowner for an industrial-use facility is exceptionally difficult.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently listed as "Unknown". Requires Verification: A desktop review using the FEMA Flood Map Service Center is a critical next step. However, the site's elevated, hilly nature suggests a low probability of being within a Special Flood Hazard Area (SFHA). It is likely designated Zone X (minimal risk), but this must be confirmed.

Wetlands: The presence of wetlands is "Unknown" but represents a significant risk. The parcel is undeveloped and wooded, and Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. The presence of state or federally regulated wetlands could impose 50- to 100-foot "no-disturb" buffer zones, severely restricting the buildable area on this already small 2.79-acre lot. A formal wetland delineation would be mandatory before any site design.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive factor. However, we recommend a cross-reference with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to screen for any state-level species of concern that could trigger additional review or time-of-year restrictions on construction.

Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential contamination and cleanup liabilities, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant competitive disadvantage.

Pipeline Proximity: No gas transmission pipelines are located nearby, eliminating this as a safety or setback concern.

3. Grid Infrastructure & Interconnection

Substation & Feeder: The nearest substation, COOKS POND, is 1.6 miles away. This distance is a fatal flaw for a distribution-scale project. A dedicated distribution feeder would need to be constructed from the substation to the site. The cost for a 1.6-mile overhead line extension is estimated to be in the range of $1.6M - $3.2M, with undergrounding being significantly more expensive. This cost alone would render a ≤5MW BESS project economically unviable.

Interconnection Voltage & Utility: The interconnecting utility is National Grid. The COOKS POND substation has a max voltage of 69kV, indicating it likely steps down to a distribution voltage such as 13.2kV. The recommended interconnection would be at this distribution voltage. Interconnecting to the 115kV transmission line 2.6 miles away is not a feasible option due to exorbitant costs for a project of this scale.

Interconnection Process & Timeline: The interconnection process in Massachusetts is governed by the Department of Public Utilities (DPU) and managed by National Grid. Given the need for a new 1.6-mile feeder, the study process would be complex and lengthy. The timeline from application submission to commercial operation, driven primarily by the line extension engineering, easement acquisition, and construction, would likely exceed 36-48 months. National Grid's queues are known to be congested, adding further timeline risk.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The AHJ is the Town of Paxton, MA.

Zoning Compatibility: The site is zoned R40 (Residential-Vacant Land) and GRB. This is the second fatal flaw. BESS is an industrial/utility use and