⚡ 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 14 Howard Street in Paxton, Worcester County, Massachusetts. The subject property is a 2.79-acre parcel of vacant residential land. The analysis evaluates the site's suitability based on key development criteria, including access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Howard Street, which appears to be a local, two-lane residential road. Requires Verification: A desktop review using satellite imagery suggests the road is paved but may be narrow, with limited shoulder space. The quality and load-bearing capacity of this road are unknown and must be confirmed to ensure it can support heavy haul trucks.

Equipment Delivery: Access for large, heavy equipment is a significant concern. Delivery of multi-ton battery containers, a main power transformer (MPT), and a large crane will be challenging on local residential streets. A detailed route survey and turning-radius analysis are mandatory to confirm feasibility. The route from a major highway to the site must be assessed for low bridges, tight turns, and weight-limited infrastructure.

Topography: As is typical for Worcester County, the site likely features rolling terrain. While the exact slope is unknown, any significant grade will increase civil engineering and site preparation costs for creating level pads for the BESS equipment. A topographical survey is an essential next step.

Easement Concerns: The property is a landlocked parcel with frontage but is surrounded by other residential properties. A title search is required to identify any existing utility or access easements that may encumber the property and restrict the buildable area. Furthermore, the 1.6-mile distance to the substation will require securing new, permanent easements from the Town of Paxton or multiple private landowners for the distribution line extension, which is a time-consuming and potentially costly process with no guarantee of success.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. If the property is located within a Special Flood Hazard Area (e.g., Zone A or AE), development could be prohibited or require elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. A FEMA FIRMette must be obtained immediately.

Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). On a small 2.79-acre parcel, the presence of regulated wetlands could render the site undevelopable. A desktop screening using MassGIS data is a priority, to be followed by a formal wetlands delineation by a certified professional if the site progresses.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be formally verified via the USFWS IPaC tool and consultation with the MA Natural Heritage & Endangered Species Program (NHESP) during the permitting phase.

Site Contamination: The absence of nearby brownfield or superfund sites is positive from a liability standpoint but eliminates the opportunity to capture the 10% IRA Brownfield tax credit adder.

Pipeline Proximity: No gas pipelines are located near the site, mitigating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation is National Grid’s COOKS POND substation, located 1.6 miles away. This is a considerable distance for a distribution-scale project. The substation’s 69 kV maximum voltage indicates it likely has distribution-level feeders (e.g., 13.2 kV) suitable for a ≤5MW BESS. However, the capacity of these feeders to accommodate a new generator is unknown.

Recommended Interconnection: The only viable interconnection path is a new distribution-level (e.g., 13.2 kV) line extension from the Cooks Pond substation to the project site. A transmission-level interconnection to the 115kV line 2.6 miles away would be financially and technically infeasible for a project of this scale.

Cost & Timeline: The 1.6-mile distribution line build is a major financial red flag. Estimated costs for such an extension can range from $1.5M to $3.0M+, depending on terrain, property acquisition/easement costs, and whether the line is overhead or underground. This cost could make the project economically unviable. The timeline for study, design, easement acquisition, and construction of this line would likely be 24-36 months.

Utility Process: Interconnection will be with National Grid, and the process is governed by the Massachusetts DPU. Queue times in ISO-New England are significant. A pre-application report must be filed immediately to obtain preliminary feedback on feeder capacity and potential roadblocks before committing significant capital.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Paxton.

Zoning Compatibility: The site is zoned Residential (R40 / GRB). Energy storage is not a permitted by-right use in any residential zone in Massachusetts. This zoning designation is a major, and potentially fatal, flaw.

Permitting Pathway: Development will require, at a minimum, a Special Permit from the Paxton Planning