⚡ 40 MILLBURY RD

TO: Sunland America Corp. Development Team

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) on the 12.58-acre parcel located at 40 Millbury Rd, Oxford, MA. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has frontage on Millbury Road, which appears to be a two-lane, paved local road. A preliminary desktop review suggests the road is sufficient for standard construction traffic. However, the feasibility for oversized and overweight loads, such as a main power transformer on a lowboy trailer or 53-foot battery containers, is a critical unknown. A detailed route survey is required to identify any potential constraints like tight turning radii, low-clearance bridges, or weight-limited infrastructure between the site and the nearest major highway.

Terrain & Site Conditions: The parcel is designated as "Forest Land," indicating it is heavily wooded. Topographical maps of Worcester County show rolling terrain. It is highly probable that significant tree clearing, stumping, and grading will be required to create a level pad for the BESS compound. This will increase site preparation costs and may have permitting implications related to stormwater management and erosion control.

On-Site Access: There is no existing improved access road from Millbury Road onto the parcel. A new access road, likely gravel, will need to be constructed. The length and cost of this road will depend on the final BESS location within the 12.58-acre parcel, which will be dictated by environmental and zoning setbacks.

Easement Concerns: As the entire parcel is under single ownership, an access easement from the public road is not a concern. However, a utility easement will be required for the 1.5-mile interconnection line to the North Oxford substation. The route and acquisition of this easement represent a significant project risk and cost center.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical information gap. Any portion of the site within a 100-year floodplain (e.g., Zone A or AE) would likely be undevelopable or require costly mitigation measures, such as elevating all equipment above the Base Flood Elevation. A FEMA FIRMette review is an immediate next step.

Wetlands: The presence of wetlands is Unknown. Given the forested nature of the site in Massachusetts, the probability of jurisdictional wetlands and/or vernal pools is high. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around most wetland resources, which would severely constrain the buildable area. A desktop screening using MassGIS is required immediately, to be followed by a formal field delineation by a certified wetland scientist if the project proceeds.

Critical Habitat / Endangered Species: The initial screening shows no critical habitat or protected areas on site, which is a positive indicator. However, this must be formally verified through the US Fish and Wildlife Service's IPaC tool and consultation with the MA Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed species or habitats are impacted.

Brownfield/Superfund Status: The site is not a brownfield, and there are no nearby superfund sites. While this avoids environmental remediation risks and liabilities, it also means the project is ineligible for the 10% Brownfield Adder under the Inflation Reduction Act (IRA), a notable financial disadvantage.

Pipeline Proximity: The absence of gas pipelines within a 3-mile radius is a significant safety and design advantage, eliminating risks and setback requirements associated with high-pressure pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Substation & Point of Interconnection (POI): The North Oxford substation is located approximately 1.5 miles from the site. Its 115 kV maximum voltage indicates it is a substantial node on the grid with a high likelihood of available capacity for a ≤5MW project. This is the site's strongest attribute.

Interconnection Recommendation: For a distribution-scale project, the ideal interconnection would be to a 3-phase distribution feeder (likely 13.2 kV or similar) originating from the North Oxford substation. Interconnecting at the transmission level (115 kV at the substation or to the nearby 345 kV line) would be prohibitively expensive and complex for a project of this size.