⚡ 40 MILLBURY RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 40 Millbury Rd, Oxford, MA (APN: 16_D03)

This report provides a comprehensive due diligence analysis for a potential Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The 12.58-acre parcel presents a mix of opportunities and significant challenges that require careful consideration. The analysis covers site access, environmental constraints, grid infrastructure, regulatory hurdles, incentive potential, and overall buildability, culminating in a final recommendation.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has frontage along Millbury Road, which appears to be a two-lane, paved local road. While sufficient for standard vehicles, a detailed survey is required to confirm its width, turning radii, and weight-bearing capacity for heavy haul trucks delivering multi-ton battery containers, power conversion systems (PCS), and the main power transformer. The key challenge is that the parcel itself has no existing improved access point; it is currently undeveloped woodland directly abutting the road.

Terrain & Site Preparation: Based on satellite and topographic imagery, the parcel is heavily wooded and appears to have moderate elevation changes. Significant clearing, grubbing, and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. The costs associated with this level of site preparation will be substantial and must be factored into the project pro forma. A preliminary geotechnical investigation would be necessary to assess soil stability and rock presence.

Heavy Equipment Feasibility: Access for heavy equipment is a major concern. A new, permanent access road would need to be constructed from Millbury Road onto the site, designed to accommodate lowboy trailers and a large crane for setting the transformer and battery enclosures. The feasibility and cost of this construction are critical unknowns.

Easement Concerns: While the parcel has direct road frontage, utility interconnection may require easements. If the optimal Point of Interconnection (POI) is not directly adjacent to the property frontage, a utility right-of-way across neighboring parcels or along the Millbury Road right-of-way would be necessary. This requires verification during the interconnection process.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Requires Verification. A preliminary desktop review suggests the property is located in Zone X, an area of minimal flood hazard. However, this must be confirmed via a formal site-specific FEMA map review, as any location within a Special Flood Hazard Area (e.g., Zone A, AE) would impose significant design constraints, elevate costs, and potentially render the site unsuitable.

Wetlands: The presence of wetlands is Unknown and represents one of the most significant risks for this site. Massachusetts has stringent wetlands protection regulations (Massachusetts Wetlands Protection Act). Given the parcel's undeveloped, forested nature, the probability of jurisdictional wetlands, vernal pools, or bordering vegetated wetlands is high. A formal wetland delineation by a certified professional is an immediate priority. The discovery of significant wetlands could severely limit the buildable area or trigger extensive and costly mitigation requirements.

Habitat & Species: The site is not located within a designated critical habitat or protected area. A desktop screening using the MA Natural Heritage & Endangered Species Program (NHESP) database is still recommended to ensure no state-listed rare species habitats are present, which could trigger further review.

Brownfield/Superfund Status: No brownfield or superfund sites are located within a two-mile radius. While this reduces potential environmental liability and cleanup costs, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable financial disadvantage.

Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a positive finding that eliminates risks and setback requirements associated with pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Transmission Assets: The site is located 1.5 miles from the NORTH OXFORD 115 kV substation and 0.9 miles from a 345 kV transmission line. This proximity to high-voltage infrastructure is positive for grid stability but presents a challenge for a distribution-scale (≤5MW) project.

Recommended Interconnection Voltage: For a project of 5MW or less, a distribution-level interconnection (e.g., 13.8 kV) is strongly preferred to avoid the prohibitive costs of