⚡ 40 MILLBURY RD

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 (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis covers key evaluation criteria from site access to grid interconnection and regulatory hurdles. The final recommendation is based on a weighted scoring of these factors.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has frontage on Millbury Road, a two-lane, paved local road. Based on aerial imagery, the road appears to be in fair condition and should be sufficient for standard construction traffic, including dump trucks and concrete mixers. However, a formal road survey is required to confirm weight limits and turning radii for heavy-haul deliveries.

Terrain & Heavy Equipment Feasibility: The site is undeveloped, heavily wooded, and exhibits rolling topography characteristic of central Massachusetts. Significant tree clearing and civil work, including grading and compaction, will be required to create a level pad for the BESS equipment. Access for a lowboy trailer carrying a 40-foot battery container (~90,000 lbs) and a crane for offloading the main power transformer is a concern. The primary challenge is the lack of an existing entrance; a new commercial-grade curb cut and access road (approx. 200-400 feet) will need to be constructed from Millbury Road to the planned equipment pad. This will add considerable cost and permitting complexity.

Easement Concerns: A primary concern is that no formal access point currently exists. We must secure an access easement as part of any land lease or purchase agreement. Furthermore, utility easements for the interconnection line will be required, potentially crossing third-party parcels depending on the final Point of Interconnection (POI).

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." This is a critical data gap. A desktop analysis using the FEMA Flood Map Service Center must be conducted immediately. If any portion of the buildable area falls within a Special Flood Hazard Area (e.g., Zone A, AE), it could render the site undevelopable or require costly mitigation, such as elevating all equipment pads and control houses above the Base Flood Elevation (BFE).

Wetlands: The presence of wetlands is "Unknown" but highly likely given the site's undeveloped, forested nature in New England. The Massachusetts Wetlands Protection Act (WPA) and local Oxford conservation bylaws impose strict regulations, typically including a 100-foot buffer zone from delineated wetland boundaries. A formal wetland delineation by a certified professional is an essential and immediate next step. The presence of significant wetlands could severely constrain the buildable acreage and potentially create a fatal flaw.

Critical Habitat / Endangered Species: The initial screening shows no critical habitat on site, which is a positive finding. However, this must be formally verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present, which could trigger lengthy and complex consultations.

Brownfield/Superfund Status: The site is not a brownfield, with no superfund sites within a 2-mile radius. While this simplifies the environmental liability assessment, it is a commercial disadvantage. The project is ineligible for the 10% IRA Brownfield ITC adder, making its economics less competitive compared to repurposed industrial sites.

Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating concerns related to pipeline-specific setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

Substation & Transmission Assets: The nearest substation is North Oxford, located 1.5 miles from the site. Its 115 kV maximum voltage indicates it is primarily a transmission-level asset, but it almost certainly contains a distribution-level bus (e.g., 13.8 kV) which would be our target. A 345 kV transmission line is closer (0.9 miles), but tapping a line of this voltage for a ≤5MW project is technically and economically infeasible.

Interconnection Recommendation & Costs: The recommended interconnection path is via a new distribution feeder line to the North Oxford substation at a standard distribution voltage. The 1.5-mile distance is a major challenge. A new overhead distribution line of this length could cost between $1.5M and $3.0M, including utility make-ready work, materials, and labor. This represents a substantial portion of the project's budget and could threaten its financial viability. An underground line would be significantly more expensive.

Utility & Process: The interconnecting utility is Requires Verification but is likely National Grid. The project would be subject to the ISO New England (ISO-NE) and Massachusetts Department of Public Utilities (DPU) interconnection processes. These queues are notoriously long and complex, with a typical timeline from application to commercial operation often exceeding 24-36 months. A formal interconnection application is required to get a binding cost estimate, but this requires a significant financial deposit and site control.

Feeder Configuration: It is unknown if a suitable three-phase distribution feeder currently runs along Millbury Road. If not, the entire 1.5-mile line back to the substation would need to be constructed. If a feeder does exist, a detailed study would be needed to assess its available hosting capacity. Given the rural setting, existing feeders are likely capacity-constrained.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Oxford, MA, is the primary AHJ for all zoning and building permits.

Zoning Compatibility: The parcel is zoned R-1 (Residential) with potential open space or private preserve overlays. This zoning is highly unfavorable for energy infrastructure. BESS is not a permitted use "by-right" in a residential district. The land use code of "Forest L" further complicates this, suggesting a potential conservation interest.

Permitting Pathway: Development will require a discretionary permit. The most likely pathway is a Special Permit from the Oxford Planning Board, and potentially a Use Variance from the Zoning Board of Appeals (ZBA). This process is lengthy, expensive, and carries significant risk of denial. It requires public hearings and is susceptible to local opposition ("NIMBYism"), which is common for energy projects in residential-adjacent areas.