⚡ 40 MILLBURY RD

MEMORANDUM

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 subject property in Oxford, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. The analysis concludes with a suitability score, risk assessment, and recommended next steps.

1. Site Access & Topography

Road Access: The 12.58-acre parcel has frontage on Millbury Road, a two-lane, paved local road. Based on aerial imagery, the road appears to be in fair condition and capable of supporting standard construction traffic. However, a detailed road survey would be required to confirm weight limits and suitability for oversized/overweight loads such as a main power transformer (MPT) or pre-fabricated control houses.

Terrain & Buildability: The property is designated as "Forest Land" and is heavily wooded. Satellite and topographic data for Worcester County suggest the site likely features rolling hills and potentially significant grade changes. This presents a major buildability challenge. Extensive tree clearing, grubbing, and grading will be required to create a level pad for the BESS equipment, significantly increasing site preparation costs. The final buildable area may be substantially less than the total acreage after accounting for slopes and environmental setbacks.

Heavy Equipment Feasibility: Access for heavy equipment is a primary concern. While Millbury Road itself seems adequate, there is no existing entrance or driveway suitable for heavy haul trucks. A new, wide-mouthed construction entrance with appropriate turning radii would need to be engineered and permitted. Furthermore, an access road would need to be constructed from Millbury Road to the buildable portion of the site, traversing the wooded and likely sloped terrain. The feasibility and cost of this internal road are significant unknowns.

Easement Concerns: No immediate access easement concerns are apparent for reaching the property from the public right-of-way. However, easements will be required for the utility interconnection route, which, given the 1.5-mile distance to the substation, could be extensive and complex to acquire if it crosses third-party properties.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone status is unknown. This is a critical data gap. Any designation within a 100-year floodplain (Zone A, AE) would impose severe restrictions, requiring equipment to be elevated above the Base Flood Elevation (BFE) and potentially rendering the project economically unviable. A FEMA FIRMette must be obtained immediately.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable given the forested, undeveloped nature of the site in Massachusetts. A desktop screening using the National Wetlands Inventory (NWI) and state GIS data is the first step. A formal wetland delineation will be necessary. The Massachusetts Wetlands Protection Act imposes strict regulations, including no-build buffer zones (typically 100 feet), which could severely constrain the available buildable area.

Habitat & Species: The site is not within a known critical habitat or protected area, which is a positive. However, we recommend cross-referencing the location with the MA Natural Heritage & Endangered Species Program (NHESP) database to confirm no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The site is not a brownfield. While this eliminates potential environmental liability and remediation costs, it is a disadvantage from a financial perspective, as the project is ineligible for the 10% IRA Brownfield tax credit adder.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and design advantage, eliminating setback requirements and explosion-risk considerations.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is North Oxford, located 1.5 miles away with a maximum voltage of 115 kV. For a ≤5MW project, a 115 kV transmission-level interconnection is financially and technically infeasible. The nearby 345 kV line is similarly not a viable Point of Interconnection (POI).

Recommended Interconnection: The only viable path for a project of this scale is a distribution-level interconnection (e.g., 13.8 kV). Success is entirely dependent on the presence of a suitable 3-phase distribution feeder running along Millbury Road or another nearby road. The interconnecting utility is likely National Grid, but this Requires Verification.

Cost & Timeline Estimate: Assuming a viable distribution feeder is nearby, the 1.5-mile distance to the substation is still a major concern. The feeder may lack capacity, requiring expensive upgrades back at the substation. A conservative estimate for a line extension and necessary upgrades over this distance would be in the $1.5M - $3.0M range. The interconnection process within ISO-New England is notoriously slow and backlogged; a realistic timeline from application to commercial operation could be 36-48 months.

Feeder Configuration: Requires Verification. The existence, phasing (must be 3-phase), and capacity of a distribution feeder along the property frontage is the single most critical unknown for project viability.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): Town of Oxford, Massachusetts.

Zoning Compatibility: The current zoning is R-1 (Residential) and designated as "Private Preserve, Open Space." This is a major, potentially fatal flaw. BESS is an industrial/utility use and is fundamentally incompatible with residential and open space zoning. It is almost certain that BESS is not a by-right