⚡ 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 APN 29_32 (14 Howard St, Paxton, MA)

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 analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives. The final recommendation is based on a weighted scoring of these factors.

1. Site Access & Topography

The subject property is a 2.79-acre vacant parcel located on Howard Street. Initial desktop analysis indicates that Howard Street is a local, secondary road.

• Road Access & Equipment Delivery: Access appears to be directly from Howard Street. However, the quality and width of this road are significant concerns. Requires Verification: A site visit is mandatory to confirm if Howard Street can support the weight and turning radius of heavy-haul trucks required for delivering multi-ton battery containers, a Main Power Transformer (MPT), and construction cranes. The road may be unpaved or have restrictions on heavy vehicle traffic, which could necessitate costly road improvements.
• Terrain Characteristics: The general topography of Worcester County is characterized by rolling hills and wooded terrain. It is highly likely this parcel is not perfectly flat and may contain significant slopes, rock outcroppings, or mature trees. This could increase site preparation and grading costs, and potentially reduce the buildable acreage. A formal topographic survey would be required.
• Heavy Equipment Access: Assuming the primary access road is sufficient, internal site access must be developed. The small parcel size (2.79 acres) leaves little room for constructing a stable access road and crane pad, especially after accounting for required setbacks and potential environmental features.
• Easement Concerns: Title work is required to confirm that access from Howard Street is a public right-of-way and not subject to private easements or restrictions. Furthermore, the 1.6-mile route to the substation for the generator lead line will almost certainly require securing easements from multiple private and public landowners, a potentially time-consuming and expensive process.

2. Environmental Constraints

The site presents several critical environmental unknowns that represent significant development risk.

• FEMA Flood Zone: The flood zone designation is currently unknown. This is a critical data gap. If the site is located within a 100-year floodplain (e.g., Zone A or AE), development would be severely restricted or require elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. This must be determined immediately via the FEMA Flood Map Service Center.
• Wetlands: The presence of wetlands is unknown. Massachusetts has stringent wetland protection laws under the Massachusetts Wetlands Protection Act (WPA). Any state or federally delineated wetlands on or near the parcel would trigger significant buffer/setback requirements (typically 100 feet or more), which could render a small 2.79-acre parcel unbuildable for a BESS project. A desktop screening using the National Wetlands Inventory (NWI) is an immediate next step, to be followed by a formal wetland delineation if the screening indicates risk.
• Critical Habitat / Species: The initial screen shows no critical habitat. This is a positive indicator, but a formal request to the US Fish and Wildlife Service's IPaC system and the MA Natural Heritage & Endangered Species Program (NHESP) is recommended to confirm no sensitive species or habitats are present.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential cleanup liabilities, it also means the project is ineligible for the 10% ITC "Brownfield" adder under the Inflation Reduction Act (IRA).
• Pipeline Proximity: No gas pipelines are located nearby, eliminating a key safety and setback concern.

3. Grid Infrastructure & Interconnection

The site's viability is challenged by the distance to viable interconnection points.

• Nearest Substation: The Cooks Pond substation is 1.6 miles away. While the substation has a 69 kV bus, it is expected to have a distribution-level voltage (e.g., 13.8 kV) available for a project of this size (≤5MW). The 1.6-mile distance is substantial for a distribution-level interconnection and will require a new feeder line extension.
• Transmission Line Proximity: A 115 kV transmission line is 2.6 miles away. This is not a viable Point of Interconnection (POI) for a distribution-scale project due to the high cost of a transmission-level tap and the excessive distance.
• Recommended Interconnection: The only feasible path is a distribution-level interconnection at approximately 13.8 kV to a feeder out of the Cooks Pond substation. Requires Verification: The interconnecting utility, likely National Grid, must confirm available capacity at the substation and on the relevant feeders.
• Estimated Cost & Timeline: A 1.6-mile (approx. 8,500 feet) overhead distribution line extension could cost between $1.5M - $3.0M, depending on terrain, pole requirements, and road crossings. This cost could make the project economically unviable. The Massachusetts interconnection process is notoriously slow; a timeline of 24-36 months from application to Commercial Operation is typical.
• Feeder Configuration: It is critical to verify the presence of 3-phase power along the potential route. The absence of 3-phase infrastructure near the site would further escalate costs.

4. Regulatory & Zoning Analysis

The regulatory and zoning status of this parcel is the single greatest barrier to development and represents a likely fatal flaw.

• Authority Having Jurisdiction (AHJ): The Town of Paxton.
• Zoning Compatibility: The parcel is zoned R40 (Residential-Vacant Land) / GRB (General Residence B). BESS facilities are an industrial/utility use and are fundamentally incompatible with residential zoning. It is virtually certain that BESS is not a permitted use "by-right" in this zone.
• Permitting Pathway: The only conceivable, albeit highly improbable, pathway would be to obtain a Use Variance from the Paxton Zoning Board of Appeals. This requires proving a unique hardship tied to the land itself, a very high legal bar to clear. An alternative would be to petition the town to amend its zoning bylaw to create an overlay district or allow BESS via a Special Permit, which is a lengthy political process.
• Setback Requirements: Even if a variance were granted, the project would be subject to large residential setbacks from property lines, likely consuming a significant portion of the 2.79-acre site and severely constraining the project footprint.
• Moratorium/Restriction Risk: Given the residential character of the area, a BESS proposal would face a very high risk of intense community opposition (NIMBYism), potentially leading the town to enact a moratorium on such facilities.

5. IRA/ITC Incentive Analysis

The project's financial model is weakened by its ineligibility for key IRA incentive adders.

• Opportunity Zone: No. (0% ITC adder)
• Energy Community: No. (0% ITC adder)
• Low-Income Community: No. (0% ITC adder)

Cumulative ITC Adder: 0%. The project would only be eligible for the base 30% ITC. The lack of any location-based adders makes this site less competitive than alternative sites that qualify for a 40% or 50% ITC.

6. BESS Score & Rationale

Overall BESS Suitability Score: 18 / 100