⚡ 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 subject property, a 2.79-acre parcel in Paxton, MA, for its suitability as a distribution-scale Battery Energy Storage System (BESS) project. The analysis concludes with a BESS Suitability Score and a final recommendation.

1. Site Access & Topography

The property has direct frontage on Howard Street, a two-lane, local residential road. Preliminary review via satellite imagery suggests the road is paved but relatively narrow, with no sidewalks or shoulders. The primary concern is the feasibility of delivering oversized and overweight equipment. A full-size tractor-trailer delivering a 40-foot battery container (approx. 80,000 lbs) and a large mobile crane for offloading the BESS and setting the main power transformer will be required. A detailed route survey is necessary to confirm the absence of restrictive turning radii from main roads, low-hanging utility lines, or weight-limited bridges on the approach to the site. The terrain in this part of Worcester County is characterized by rolling hills and is likely to be wooded with rocky soil, typical of central New England. This will necessitate significant site work, including tree clearing, grubbing, and grading, which will increase construction costs. While direct road access exists, an access easement is not anticipated to be required for entry, but a construction easement may be needed for temporary laydown or equipment maneuvering. The suitability of the existing curb cut for heavy truck traffic Requires Verification.

2. Environmental Constraints

The environmental profile of this site presents several critical unknowns that constitute a major project risk. The FEMA Flood Zone and Wetlands status are both listed as "Unknown."

• Flood Zone: Verification via the FEMA Flood Map Service Center is a critical immediate 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, or the site may be deemed entirely unsuitable.
• Wetlands: The potential for state-jurisdictional wetlands is high in this region. A desktop screening using the USFWS National Wetlands Inventory and MassGIS data is required, followed by a formal field delineation by a certified wetland scientist. The Massachusetts Wetlands Protection Act and the Paxton Conservation Commission Bylaw impose significant regulations, typically including a 100-foot buffer zone around any delineated wetland resource area, which could severely constrain the buildable envelope on this 2.79-acre parcel.
• Advantageous Conditions: On a positive note, the site has no known proximity to Brownfield/Superfund sites, which reduces contamination risk but also means the project is ineligible for the 10% IRA brownfield tax credit adder. The lack of nearby pipelines, critical habitats, or protected areas are minor positives that simplify permitting. The site is not in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents a significant challenge. The nearest substation, COOKS POND, is 1.6 miles away. While its 69 kV bus is too high for a distribution-scale project, it indicates a point of capacity on the system. The target interconnection for a ≤5MW BESS would be a local 3-phase distribution feeder, typically operating at 13.8 kV in this region (Requires Verification with National Grid, the likely utility). A 1.6-mile distribution line extension to the substation is financially prohibitive, likely costing between $1.5M and $3M and adding significant timeline risk. The project's viability is entirely dependent on the presence of an existing 3-phase distribution line with adequate thermal and voltage capacity on Howard Street or an adjacent road. A desktop line trace is required immediately to identify potential Points of Interconnection (POI). If a suitable feeder is nearby, interconnection costs could range from $500,000 to $1,500,000 for equipment upgrades, protection, and metering. The interconnection process in Massachusetts is governed by the Department of Public Utilities (DPU) and administered by National Grid. Queue times for study and construction can be lengthy, often 24-36 months from application to commercial operation.

4. Regulatory & Zoning Analysis

The regulatory landscape is the most significant barrier for this site. The Authority Having Jurisdiction (AHJ) is the Town of Paxton. The property is zoned R40 / GRB (General Residence B), a residential designation. Energy storage facilities are not a permitted use "by-right" in any residential zone in Paxton's current zoning bylaws. Therefore, the project would require, at a minimum, a Special Permit from the Planning Board, and more likely, a Use Variance from the Zoning Board of Appeals (ZBA). A Use Variance has a much higher legal threshold to meet, requiring the applicant to prove a unique hardship. This permitting path is fraught with uncertainty and is highly susceptible to community opposition ("NIMBYism"), especially given the residential character of the neighborhood. Public hearings would be mandatory, and abutters would have significant influence. The risk of outright denial or the imposition of cost-prohibitive conditions (e.g., extreme setbacks, sound walls, landscaping) is very high. A pre-application meeting with the Paxton Town Planner is essential to gauge the town's appetite for such a project before investing further resources.

5. IRA/ITC Incentive Analysis

The site's location is financially disadvantageous from an Investment Tax Credit (ITC) perspective. Analysis confirms the property does not qualify for any of the primary ITC bonus adders:

• Opportunity Zone: No
• Energy Community (Coal Closure or Statistical Area): No
• Low-Income Community: No

As a result, the project is only eligible for the 30% base ITC. While the 10% Domestic Content adder is theoretically available, its supply chain requirements are currently very difficult to meet and document. Therefore, we must model this project with a 30% ITC, placing it at a significant 10-20% competitive disadvantage compared to projects sited in qualifying incentive zones.

6. BESS Score & Rationale

Overall BESS Suitability Score: 29 / 100

• Location (3/20): Extremely poor. Siting an industrial-use BESS in an established residential neighborhood invites significant community opposition and permitting challenges.
• Grid Access (8/25): Poor. The 1.6-mile distance to the substation is a major red