⚡ 40 MILLBURY RD

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 development of a distribution-scale Battery Energy Storage System (BESS) on the 12.58-acre parcel located at 40 Millbury Rd, Oxford, MA. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, grid access, environmental and regulatory constraints, and financial incentives.

1. Site Access & Topography

• Road Access Quality: The property appears to have frontage on Millbury Road, a two-lane, paved local road. Based on aerial imagery, the road itself seems adequate for standard construction traffic, including dump trucks and concrete mixers. However, the quality and width of the road shoulder and the specific entrance point to the parcel are critical unknowns.
• Terrain Characteristics: The parcel is heavily wooded and, consistent with the topography of Worcester County, likely features rolling hills and potential rock outcroppings. A formal topographical survey is essential, as significant grading and tree clearing will be required, increasing site preparation costs and potentially triggering additional environmental review. Buildable acreage is likely a fraction of the total 12.58 acres.
• Heavy Equipment Feasibility: Access for oversized and overweight loads, such as a main power transformer (MPT) and containerized BESS units, is a concern. While Millbury Road itself may be sufficient, the final turn-in from the road onto the site will require a detailed swept-path analysis. A temporary, reinforced access road from Millbury Road to the project pad will need to be constructed. The feasibility depends heavily on the grade change from the road to the proposed pad location.
• Easement Concerns: Requires Verification. While the parcel appears to front Millbury Rd, the exact legal access point is not confirmed. Title work is required to confirm that there is clear, unencumbered legal access and to identify any existing utility or access easements that may cross the property and constrain the site layout.

2. Environmental Constraints

• FEMA Flood Zone: Requires Verification. The FEMA status is unknown. A desktop review using the FEMA Flood Map Service Center is a critical immediate step. Any designation other than Zone X (minimal risk) would introduce significant design challenges, raise insurance costs, and could render the site undevelopable if the buildable area falls within a high-risk floodway or Zone AE.
• Wetlands Presence: Requires Verification. This is a major risk. Massachusetts has stringent wetlands protection regulations under the Massachusetts Wetlands Protection Act, enforced by the local Conservation Commission. Given the wooded and undeveloped nature of the site, the presence of wetlands, vernal pools, or bordering vegetated wetlands (BVW) is highly probable. A formal wetlands delineation is non-negotiable and will dictate the buildable envelope, as 100-foot buffer zones are standard.
• Critical Habitat / Endangered Species: The initial screen shows no critical habitat. However, we must perform a desktop review using the MA Natural Heritage & Endangered Species Program (NHESP) database and the USFWS IPaC tool to confirm no state or federally listed species or their habitats are present, which could trigger lengthy consultations and mitigation requirements.
• Brownfield/Superfund Status: The absence of nearby brownfield or superfund sites is positive from a liability and remediation cost perspective. However, it is a strategic disadvantage, as the project is ineligible for the 10% ITC "Brownfield" adder under the Inflation Reduction Act (IRA).
• Pipeline Proximity: The lack of pipelines within a 3-mile radius is a significant safety and design advantage, eliminating concerns related to explosion risk, setback requirements, and coordination with pipeline operators.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The North Oxford substation is 1.5 miles away. This is a feasible, but not ideal, distance. Its 115 kV high-side voltage indicates it is a substantial node on the grid, likely with multiple distribution-level feeders (e.g., 13.2 kV) suitable for a ≤5MW project. Available capacity is a critical unknown and must be confirmed via a formal utility inquiry.
• Transmission Line Proximity: A 345 kV transmission line is closer (0.9 mi), but interconnection at this voltage level is financially and technically infeasible for a distribution-scale project. It should be disregarded as a viable Point of Interconnection (POI).
• Recommended Interconnection: The recommended path is a distribution-level interconnection at 13.2 kV (Requires Verification of available voltage) via a new feeder tap from the North Oxford substation.
• Estimated Cost & Timeline: A 1.5-mile, 3-phase overhead distribution line extension is a major cost driver. A preliminary, high-level estimate would be in the $1.5M - $3.0M range. This can vary significantly based on terrain, pole ownership (utility vs. new), rock drilling, and road/wetland crossings. The timeline for such a build, from application submission to commissioning, can easily be 24-48 months through the ISO-New England (ISO-NE) queue process, which is notoriously slow and complex.
• Utility & Process: Requires Verification. The interconnecting utility is likely National Grid. We must confirm this. The project would be subject to the ISO-NE interconnection process, requiring a formal application, feasibility studies, system impact studies, and facilities studies. A pre-application report is a crucial first step to gain preliminary insight from the utility.
• Feeder Configuration: The new line would likely be an overhead radial feeder. Its path from the substation to the site needs to be determined, as it will require securing new pole easements from third-party landowners if it does not follow existing public rights-of-way.

4. Regulatory & Zoning Analysis