⚡ 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 interconnection, regulatory hurdles, and financial incentives. The findings indicate significant challenges that likely render the site non-viable for BESS development.

1. Site Access & Topography

The subject property is a 2.79-acre vacant parcel located on Howard Street. Initial desktop review indicates that Howard Street is a two-lane, paved local road. While seemingly adequate for standard vehicle traffic, its suitability for heavy-haul transport required for BESS components is a concern.

• Road Access Quality: Access appears to be directly from Howard Street. However, the road's width, turning radii from main thoroughfares (like Route 31), and load-bearing capacity are unknown and require verification. There may be challenges navigating large trucks through what appears to be a semi-rural, residential area.
• Terrain & Equipment Delivery: Satellite imagery suggests the terrain is gently rolling with moderate tree cover, typical of central Massachusetts. A formal topographic survey is required, but there do not appear to be prohibitive slopes on the parcel itself. The primary concern is the final approach and on-site maneuverability. The small parcel size (2.79 acres) provides very limited laydown area for construction staging and crane operations needed to offload and place multi-ton battery containers and the main power transformer.
• Access Feasibility: The ability to deliver a 50-70 ton transformer and multiple 20-40 ton battery enclosures is questionable without road improvements or temporary construction access paths. Overhead utility lines along Howard Street could also present clearance issues for tall equipment.
• Easement Concerns: Requires Verification. A title search is necessary to identify any existing access, utility, or conservation easements that could encumber the property and restrict the placement of equipment or access roads. Given the parcel's configuration, any significant easement could severely limit the buildable area.

2. Environmental Constraints

The site presents significant environmental due diligence requirements, particularly concerning water resources which are heavily regulated in Massachusetts.

• FEMA Flood Zone: Requires Verification. The FEMA flood designation is currently unknown. Any location within a 100-year floodplain (Zone A/AE) would likely make the site undevelopable for critical infrastructure like a BESS or require costly mitigation measures such as elevating all equipment pads above the Base Flood Elevation.
• Wetlands: Requires Verification. The presence of wetlands is unknown and represents a major risk. Massachusetts has one of the nation's most stringent wetlands protection frameworks under the Massachusetts Wetlands Protection Act (M.G.L. c. 131, § 40) and local town bylaws. If state or federally-jurisdictional wetlands are present, significant buffers (typically 100 feet or more) would be required, which could consume a large portion of this small 2.79-acre parcel and render the project infeasible. A wetland delineation by a certified professional is a critical next step.
• Habitat & Species: The initial screen shows no critical habitat or protected areas on site, which is a positive finding. However, a formal review against the MA Natural Heritage & Endangered Species Program (NHESP) database is recommended during formal permitting.
• Brownfield/Superfund Status: The site is not a brownfield. While this means lower environmental liability risk, it also means the project is ineligible for the 10% ITC "Brownfield Adder" under the Inflation Reduction Act (IRA), a notable financial disadvantage.
• Pipeline Proximity: No major gas transmission pipelines are located nearby, mitigating risks associated with pipeline-related safety setbacks and consultations.

3. Grid Infrastructure & Interconnection

Grid interconnection appears to be the most significant technical and financial challenge for this site. The distance to viable Points of Interconnection (POI) is substantial for a project of this scale.

• Nearest Substation: The COOKS POND substation is 1.6 miles away. This is a considerable distance for a new distribution line extension, which could easily incur costs of $1-2 million per mile, depending on terrain, pole requirements, and road crossings. The substation's 69 kV bus is sub-transmission voltage, which would require a dedicated, expensive bay position and protection scheme, likely overkill for a ≤5MW BESS.
• Feeder Configuration: Requires Verification. The most critical unknown is the presence, capacity, and voltage of a 3-phase distribution feeder along Howard Street or adjacent roads. The interconnecting utility is likely National Grid. We must conduct a desktop utility map review to determine if a suitable 13.8 kV (or similar) feeder is accessible. If no 3-phase line is nearby, the project is non-viable. If a line exists, its available capacity to accommodate 5MW of bi-directional flow is a major uncertainty that can only be determined through the formal interconnection application process.
• Recommended Interconnection: The only feasible interconnection would be to a local 13.8 kV distribution feeder. Interconnecting at 69 kV or 115 kV is financially and technically infeasible for a 5MW project.
• Cost & Timeline Estimate: Assuming a suitable distribution feeder is nearby but requires upgrades, the interconnection cost could range from $750,000 to over $2,500,000. If a 1.6-mile line extension is required, costs would likely exceed $3,000,000. The interconnection process with National Grid within the ISO-New England (ISO-NE) territory is notoriously slow; timelines from application to commercial operation can often exceed 24-36 months.

4. Regulatory & Zoning Analysis

The regulatory and zoning landscape presents a near-fatal flaw for this project. The site is located in a residential zone, making a BESS an incompatible use.

• Authority Having Jurisdiction (AHJ): Town of Paxton, specifically the Paxton Planning Board and Zoning Board of Appeals.
• Zoning Compatibility: The parcel is zoned R40 (Residential - 40,000 sq. ft. minimum lot) and/or GRB (General Residence B). BESS facilities are typically classified as "utility" or "industrial" uses, neither of which is permitted in a residential zone. This fundamental conflict is the single greatest barrier to development.
• Permitting Pathway: A BESS project is not a by-right use. The project would require, at a minimum, a Special Permit from the Planning Board and likely a Use Variance from the Zoning Board of Appeals. A Use Variance is exceptionally difficult to obtain in Massachusetts, as it requires proving a unique hardship related to the land itself. Public opposition from neighboring residential property owners is virtually guaranteed and would likely be successful.
• Setback Requirements: Requires Verification. Even if a permit were conceivable, the Town of Paxton's specific setback requirements for non-residential uses in a residential zone would need to be determined. These are likely to be substantial and would further constrain the already small buildable area.
• Moratorium Risk: Given the rise of energy projects, many small Massachusetts towns have enacted or are considering moratoriums on large-scale battery or solar projects to update their bylaws. This represents an additional layer of political and timeline risk.

5. IRA/ITC Incentive Analysis

The project's financial viability is weakened by its ineligibility for key IRA tax credit adders.

• Opportunity Zone: No. The site is not in a qualified Opportunity Zone. (0% adder)
• Energy Community: No. The site does not qualify based on the coal closure or statistical area criteria. (0% adder)
• Low-Income Community: No. The site does not meet the criteria for the Low-Income Community adder. (0% adder)

Potential Cumulative ITC Adder: 0%. The project would only be eligible for the base 30% ITC (assuming prevailing wage and apprenticeship requirements are met). This lack of a 10-20% bonus credit significantly impacts the project's return profile compared to more strategically located sites.

6. BESS Score & Rationale

Overall BESS Suitability Score: 18 / 100

• Location (3/20): Poor. Sited in a residential neighborhood