⚡ 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Rd, Oxford, MA. The analysis covers key site attributes, constraints, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access & Equipment Delivery: The subject parcel has frontage on Millbury Road, which appears to be a two-lane, paved local road. While suitable for standard construction traffic, a detailed survey is required to confirm its load-bearing capacity and width for oversized and overweight vehicles, such as a mobile crane, main power transformer (MPT), and prefabricated battery enclosures. The route from major highways (I-395, I-90) to the site must be evaluated for low bridges, tight turns, and any local road restrictions that could impede delivery.

Terrain & Buildability: Based on aerial imagery and the general topography of Worcester County, the 12.58-acre parcel is expected to be moderately to heavily wooded with potentially rolling or sloped terrain. Significant tree clearing and civil work, including grading and soil stabilization, will likely be required to create a level pad for a 5MW BESS, which typically requires 1-2 cleared acres. The costs associated with this site preparation could be substantial.

Heavy Equipment Access: Direct access from Millbury Road onto the site appears feasible, but the exact location and construction of a new access driveway will be critical. The driveway must be designed with a sufficient turning radius and structural base to support a 100-ton crane for setting the transformer and battery containers.

Easement Concerns: The parcel's configuration is irregular. A title search is mandatory to confirm that there are no existing access, utility, or conservation easements that would encumber the proposed development area. Given the proximity to other residential properties, securing an unencumbered access point is a primary concern. Requires Verification.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any location within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable for critical infrastructure like a BESS or require significant and costly mitigation (e.g., elevating all equipment). A desktop review using the FEMA Flood Map Service Center is an immediate next step.

Wetlands: The presence of wetlands is unknown but highly probable given the forested nature of the site in Massachusetts. The Massachusetts Wetlands Protection Act (WPA) and local Oxford Conservation Commission bylaws impose strict regulations, including significant buffer zones (typically 100 feet) from any delineated wetland resource areas. A formal wetland delineation by a certified professional will be required early in the due diligence process, as this could severely constrain the buildable area.

Critical Habitat / Endangered Species: The initial screen shows no designated critical habitat on the parcel, which is a positive finding. However, this should be cross-verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitats map to ensure no state-listed species are impacted, which could trigger a lengthy review process.

Brownfield/Superfund Status: The site is not located near any known brownfield or superfund sites. While this mitigates environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant disadvantage for project economics.

Pipeline Proximity: No major gas pipelines are located within three miles, which eliminates risks associated with pipeline setbacks and potential co-location hazards.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The North Oxford substation is located 1.5 miles from the site and has a 115 kV bus. A 345 kV transmission line is slightly closer at 0.9 miles. For a distribution-scale project (≤5MW), interconnecting at transmission voltage (115 kV or 345 kV) is financially prohibitive. The key is whether a viable distribution feeder exists closer to the site.

Recommended Interconnection: The recommended pathway is a distribution-level interconnection, likely at 13.8 kV. The primary diligence item is to identify the nearest 3-phase distribution feeder owned by the likely interconnecting utility (National Grid). The 1.5-mile distance to the substation represents a potential worst-case scenario for a new feeder extension.

Cost & Timeline Estimate: A 1.5-mile overhead distribution line extension could cost between $1.5M - $3.0M, a very significant portion of a 5MW BESS project budget. If the line must be placed underground, costs would be substantially higher. The interconnection process in ISO-New England, managed by the utility (National Grid), is notoriously slow and complex, with timelines from application to commercial operation often exceeding 24-36 months.

Utility & Feeder Configuration: The interconnecting utility is presumed to be National Grid. Requires Verification. A desktop utility analysis is needed to map the local distribution circuits, determine their voltage, and assess their current loading and hosting capacity. The feeder is likely an overhead, 3-phase line running along a primary local road.

4. Regulatory & Zoning Analysis

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

Zoning Compatibility: The parcel is zoned R-1 (Residential) and is designated as "Private Preserve, Open Space-Vacant Land." This zoning is a major red flag and is fundamentally incompatible with an industrial use like a BESS. Energy storage is not a permitted use by-right in a residential or open