⚡ 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 concludes that despite favorable grid proximity, the site carries significant, likely fatal, flaws related to zoning, environmental constraints, and a lack of financial incentives. The recommendation is NO GO at this time.

1. Site Access & Topography

Road Access: The subject parcel has frontage on Millbury Road, a two-lane, paved local road. This road appears suitable for standard construction vehicles. However, the delivery of oversized and overweight equipment, such as a main power transformer or multiple BESS container units, requires further analysis. A turning radius study from main thoroughfares onto Millbury Road and into the site entrance would be necessary.

Terrain & Site Conditions: Based on aerial imagery and regional topography, the 12.58-acre parcel is heavily wooded and appears to have gently rolling terrain, which is typical for this part of Massachusetts. Significant site work, including tree clearing, grubbing, and grading, will be required to create a level pad for the BESS equipment. The cost and timeline for this site preparation should be considered a material project expense.

Heavy Equipment Feasibility: While the adjacent road can likely support the loads, direct access into the parcel is currently undeveloped. A new access road, capable of supporting a 100-ton crane and fully loaded tractor-trailers, would need to be constructed from Millbury Road into the project area. The feasibility depends on the grade change from the road to the site and the soil's load-bearing capacity, which requires a geotechnical survey.

Easement Concerns: Requires Verification. The parcel's legal frontage and access rights to Millbury Road must be confirmed via a title search. The current configuration on mapping services is unclear. There is a moderate risk that a formal access easement from an abutting property may be required, which would introduce significant cost, timeline, and negotiation risk.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap. A review of FEMA Flood Insurance Rate Maps (FIRMs) is an immediate next step. If any portion of the planned equipment pad falls within a Special Flood Hazard Area (e.g., Zone A or AE), it would necessitate raising all equipment above the Base Flood Elevation, adding substantial cost and complexity, or could render the site undevelopable.

Wetlands: The presence of wetlands is Unknown but represents a major risk. Undeveloped, wooded parcels in Massachusetts have a high probability of containing state or federally jurisdictional wetlands. Under the Massachusetts Wetlands Protection Act, activities within 100 feet of a wetland (the "Buffer Zone") are heavily regulated, and direct impacts are difficult to permit. A formal wetland delineation is required to determine the net buildable area. The potential for wetlands to severely constrain or eliminate the development envelope is a potential fatal flaw.

Critical Habitat / Species: The data indicates no critical habitat or protected areas on site, which is a positive initial screen. However, a desktop review using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is still a recommended step to confirm no sensitive species are mapped in the vicinity.

Brownfield/Superfund Status: The site is not a brownfield, which avoids potential environmental liability and cleanup costs. However, this also means the project is ineligible for the 10% IRA Brownfield ITC adder, a significant disadvantage compared to competing projects sited on qualifying properties.

Pipeline Proximity: No gas transmission pipelines are located near the site, eliminating risks associated with pipeline safety setbacks and operational constraints.

3. Grid Infrastructure & Interconnection

Substation & POI: The North Oxford substation is located approximately 1.5 miles from the site. This is an excellent distance for a distribution-scale project, minimizing the cost and complexity of a gen-tie line. The substation's 115 kV bus indicates it is a significant node on the grid, increasing the likelihood of available capacity on its distribution feeders.

Transmission Lines: A 345 kV transmission line is located 0.9 miles away. Interconnecting at this voltage is prohibitively expensive for a project of our target size (≤5MW) and is not a viable option.

Recommended Interconnection: The most feasible Point of Interconnection (POI) would be a 3-phase distribution feeder (likely 13.2 kV or similar) originating from the North Oxford substation. Requires Verification: A critical next step is to identify if a suitable 3-phase line runs along Millbury Road adjacent to the property. If not, the project would bear the full cost of a 1.5-mile line extension.

Cost & Timeline Estimate: Assuming a 1.5-mile distribution line build and moderate upgrades at the substation, the estimated