⚡ 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 – "Oxford North" Prospect (40 Millbury Rd, Oxford, MA)

This report provides a comprehensive due diligence analysis for the property located at 40 Millbury Rd, Oxford, Worcester County, MA (APN: 16_D03). The 12.58-acre parcel presents a compelling grid opportunity but faces significant, potentially fatal flaws in its regulatory and physical characteristics. The following analysis details these factors to inform a go/no-go decision.

1. Site Access & Topography

Road Access & Equipment Delivery: The property's primary frontage is on Millbury Road. Based on aerial imagery, this appears to be a two-lane, local road. While sufficient for standard vehicles, its suitability for heavy-haul trucks carrying multi-ton transformers, switchgear, and 40-foot battery containers is a significant concern. Requires Verification: A formal road study is needed to assess weight limits, turning radii from major highways, and the condition of any bridges or culverts along the delivery route. The road may require temporary reinforcement or widening at the site entrance, increasing construction costs.

Terrain & Buildability: The parcel is designated as "Forest Land." This, combined with its location in central Massachusetts, strongly suggests the terrain is characterized by rolling hills, mature trees, and potential rock outcroppings. Significant site work, including extensive tree clearing, grubbing, and grading, will be required to create a level pad for the BESS equipment. This will add considerable time and expense to the construction budget. The presence of bedrock near the surface could further complicate foundation work.

Equipment Access to Site: Assuming a suitable entrance can be constructed off Millbury Road, an internal access road will need to be built from the public right-of-way to the project area. The length and complexity of this road will depend on the final BESS location within the 12.58-acre parcel, which will be dictated by environmental setbacks and topography.

Easement Concerns: Requires Verification: A title search is necessary to identify any existing access, utility, or conservation easements that could restrict development. Given the "Private Preserve" and "Open Space" land use codes, there is a moderate to high risk of restrictive covenants that could prohibit this type of development entirely.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. If any portion of the planned equipment pad falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment above the Base Flood Elevation (BFE), adding substantial cost and complexity. Any development within a floodway would be prohibited, making this a potential fatal flaw. An immediate desktop review of FEMA's Flood Insurance Rate Maps (FIRMs) is required.

Wetlands: The presence of wetlands is unknown. Given the forested nature of the site in New England, there is a high probability of jurisdictional wetlands, streams, or vernal pools. The Massachusetts Wetlands Protection Act is stringent, imposing significant buffer zones (typically 100 feet) where development is heavily restricted. A wetland delineation by a certified professional will be essential to determine the true buildable area. This is a major risk to the project's viability and layout.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This should be confirmed through a query of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Brownfield/Superfund Status: The site is not a brownfield. While this avoids environmental liability, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant disadvantage from a project finance perspective.

Pipeline Proximity: No major gas pipelines are located nearby, which is a positive factor that simplifies safety planning and permitting by avoiding PHMSA (Pipeline and Hazardous Materials Safety Administration) consultations.

3. Grid Infrastructure & Interconnection

Grid Proximity: This is the site's strongest attribute. The North Oxford substation (115 kV) is only 1.5 miles away, an ideal distance for a gen-tie line. Additionally, a 345 kV transmission line is located just 0.9 miles from the parcel. This provides multiple high-capacity interconnection options.

Recommended Interconnection: For a distribution-scale project (≤5MW), the ideal Point of Interconnection (POI) would be a local 3-phase distribution feeder. Requires Verification: We must identify the utility (likely National Grid or Eversource) and request feeder maps to assess if a suitable 13.8 kV (or similar voltage) line with available capacity runs along Millbury Road. If not, the most viable path would be a direct interconnection at the North Oxford substation. This would involve building a 1.5-mile dedicated gen-tie line and substation upgrades, making it more suitable for a larger utility-scale project where the economics can support the higher cost.

Estimated Cost & Timeline:

• Distribution Tap (if available): $500k