⚡ 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 acquisition and development of a Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis covers key site attributes, constraints, and opportunities to inform a final investment decision.

1. Site Access & Topography

The 12.58-acre parcel has frontage on Millbury Road, which appears to be a two-lane, paved local road. Based on satellite imagery, the road itself seems adequate for standard construction traffic. However, the quality of the direct access point onto the parcel is a critical unknown. There is no existing curb cut or improved driveway visible, meaning a new access point would need to be constructed, requiring a permit from the Oxford Department of Public Works.

The terrain is characteristic of central Massachusetts: heavily wooded with potentially significant topographic relief. The "Forest L" land use code confirms the site is undeveloped and will require substantial clearing and grading, increasing site preparation costs. The feasibility of delivering heavy equipment, such as a 130-ton transformer or 40-foot battery containers, is a concern. A detailed survey is required to confirm that grades are manageable for both road construction and the creation of a level pad for the BESS equipment. No access easements appear necessary given the road frontage, but this must be confirmed with a title search.

2. Environmental Constraints

Environmental factors present a significant, unquantified risk for this site.

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. Any portion of the site within a 100-year floodplain (Zone A/AE) would be largely undevelopable or require costly mitigation, such as elevating all equipment above the Base Flood Elevation. Verification via the FEMA Flood Map Service Center is an immediate next step.
• Wetlands: The presence of wetlands is Unknown. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act), which enforce significant setbacks (typically a 100-foot buffer zone from Bordering Vegetated Wetlands). Given the forested, undeveloped nature of the site, the presence of wetlands, streams, or vernal pools is highly probable. A formal wetlands delineation is essential and could severely constrain the buildable area.
• Critical Habitat / Species: The initial screen shows no critical habitat or protected areas on site, which is a positive. However, a Phase I Environmental Site Assessment (ESA) should be conducted to confirm the absence of state-listed endangered or threatened species.
• Brownfield/Superfund: The site is not a brownfield, meaning it does not qualify for the 10% IRA brownfield tax credit adder. On the positive side, this indicates a low risk of soil contamination and associated cleanup liability.
• Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating setback requirements and third-party approval risks associated with pipeline operators.

3. Grid Infrastructure & Interconnection

The site's proximity to grid infrastructure is a mixed bag. The North Oxford substation (115 kV) is 1.5 miles away, and a 345 kV transmission line is 0.9 miles away. While this indicates a robust local grid, direct interconnection at these transmission voltages for a distribution-scale (≤5MW) project is financially and technically infeasible.

The only viable path is to interconnect to a 3-phase distribution feeder, likely operating at 13.2 kV, originating from the North Oxford substation. The critical unknown is the location, capacity, and voltage of the nearest distribution line. A line may run along Millbury Road, but its capacity to handle a 5 MW injection is not guaranteed. If a suitable feeder is not adjacent to the site, a line extension of up to 1.5 miles could be required. Such an extension could cost between $1.5M - $3.0M and add significant complexity and time to the project. The interconnecting utility is likely National Grid. The Massachusetts interconnection process can be lengthy, and gaining a position in the ISO-New England queue, if required, can take several years. A formal interconnection pre-application is mandatory to determine the Point of Interconnection (POI) and