⚡ 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 the potential development of a Battery Energy Storage System (BESS) on the 12.58-acre parcel located at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property appears to have frontage on Millbury Road, which is a two-lane, paved local road. The quality of this road seems sufficient for standard construction traffic. However, the specific point of ingress/egress onto the parcel is not defined.

Equipment Delivery: The primary concern is the transition from the paved road to the project site itself. Satellite imagery shows the parcel is heavily wooded. A new access road will need to be constructed from Millbury Road into the parcel, requiring significant tree clearing, grading, and stabilization. The feasibility of delivering oversized and overweight loads, such as a main power transformer (MPT) and containerized BESS units, depends on the turning radii from public roads and the grade of the new access road. A formal logistics and transportation study would be required.

Terrain: Based on regional topography, the site is likely to have moderate elevation changes and potentially rocky soil, characteristic of Central Massachusetts. This could increase site preparation and foundation costs. A geotechnical survey is essential to determine soil composition, bearing capacity, and the extent of any required rock excavation.

Easements: 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 the access road or the BESS facility itself. Given the "Private Preserve" land use designation, a conservation easement is a plausible risk.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown and represents a critical data gap. Any location within a 100-year floodplain (Zone A/AE) would introduce significant design challenges and costs, likely requiring the entire BESS pad and associated equipment to be elevated above the Base Flood Elevation (BFE). Development within a floodway would be prohibitive.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable given the undeveloped, forested nature of the site in this region. Massachusetts has stringent wetland protection regulations under the Massachusetts Wetlands Protection Act. A formal wetland delineation by a certified professional is a mandatory, high-priority step. The presence of jurisdictional wetlands would trigger significant setbacks (typically 100-foot buffer zones) that could severely constrain the buildable area.

Critical Habitat / Species: The initial screen shows no designated critical habitat on the parcel, which is a positive finding. However, we recommend a desktop review using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm there are no mapped habitats for state-listed rare or endangered species that could trigger further consultation and mitigation requirements.

Brownfield/Superfund Status: The site is not located near any known brownfield or superfund sites. While this avoids potential contamination and remediation liabilities, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage.

Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating setback constraints and third-party crossing agreements that often complicate BESS development.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation is North Oxford, located 1.5 miles from the site. This is a considerable distance for a distribution-scale project. The likely Point of Interconnection (POI) would either be a tap on a distribution feeder running closer to the site or a direct connection at the substation. The 115 kV voltage at the substation is transmission-level and would only be suitable for a large utility-scale project, requiring a costly step-up transformer and substation build-out on our site.

Interconnection Voltage & Feeder: Requires Verification. For a ≤5MW project, the target interconnection would be a 3-phase distribution feeder, likely operating at 13.8 kV. The critical unknown is the location, capacity, and voltage of the nearest suitable feeder. A pre-application report from the interconnecting utility (presumed to be National Grid) is required to identify this.

Cost & Timeline Estimate: The interconnection cost is a major risk. If a suitable distribution feeder is not available along the site's road frontage, a new 1.5-mile gen-tie