⚡ 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 distribution-scale Battery Energy Storage System (BESS) at the subject property. The analysis concludes with a suitability score, risk assessment, and a final recommendation.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, which is a two-lane, paved local road. A preliminary review of aerial imagery suggests the parcel is a "flag lot," with primary access via a long, narrow strip of land extending to the road. The quality of this access strip is unknown and may be an unpaved track.

Equipment Delivery: While Millbury Road itself appears capable of handling heavy truck traffic, the feasibility of delivering large equipment like battery containers, inverters, and a main power transformer is highly dependent on the condition and geometry of the flag lot's access drive. The width, grade, and turning radii of this access point are critical unknowns and present a significant potential risk. Heavy haul trucks require substantial clearance and a stable road base, which may not exist.

Topography & Site Prep: The current land use is designated as "Forest Land." This indicates the 12.58-acre parcel is likely heavily wooded with potentially varied topography, characteristic of central Massachusetts. Significant tree clearing, stumping, and grading will be required to create a level pad for the BESS compound (typically 1-2 acres for a 5MW system). This will add considerable cost and time to the site preparation phase.

Easement Concerns: A full title search is mandatory to confirm the existence and terms of a legal, recorded access easement for the flag lot stem. We must ensure the easement is sufficient for commercial/industrial use and construction traffic, not just residential access. Any ambiguity could be a fatal flaw.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any portion of the property within a 100-year floodplain (Zone A/AE) would be severely constrained, requiring equipment to be elevated above the Base Flood Elevation, increasing costs and potentially rendering the site uninsurable or un-permittable. A FEMA FIRMette review is an immediate next step.

Wetlands: The presence of wetlands is Unknown. On a forested parcel in this region, the probability of encountering state or federally regulated wetlands is high. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around most wetland resource areas, which could significantly reduce or eliminate the buildable area. A formal wetlands delineation is required early in the diligence process.

Habitat & Species: The site is not located within a designated critical habitat or protected area, which is a positive finding. However, a desktop review against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitats map is recommended to confirm no sensitive species are present.

Brownfield/Superfund Status: The site has no known brownfield or superfund history. While this avoids environmental remediation risks and liabilities, it also means the project is not eligible for the 10% IRA Brownfield ITC adder, a significant disadvantage from a project finance perspective.

Pipeline Proximity: No major gas or hazardous liquid pipelines are located within three miles, eliminating a common safety and setback constraint.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is National Grid's North Oxford Substation, located approximately 1.5 miles from the site. This substation has a maximum voltage of 115 kV, indicating it supports both transmission and distribution infrastructure. A 345 kV transmission line is closer (0.9 miles), but interconnection at this voltage is not financially or technically feasible for a distribution-scale project.

Interconnection Point & Voltage: The logical point of interconnection (POI) would be a local distribution feeder, likely operating at 13.2 kV or a similar voltage, originating from the North Oxford Substation. The interconnecting utility is presumed to be National Grid. Requires Verification.

Cost & Timeline Estimate: The 1.5-mile distance to the substation is a major cost driver. A new three-phase distribution line extension of this length could cost between $1.5 million and $3.0 million. This significant capital expenditure will heavily impact the project's financial viability. The interconnection process with National Grid in Massachusetts is notoriously slow; queue times and study periods can easily extend to 24-36 months from application to commercial operation.

Feeder Configuration: The capacity, existing load profile, and protection scheme of the nearest distribution feeder are unknown. This information is critical and can only be obtained through a formal interconnection application. A feeder with low capacity or requiring significant upgrades would add further