⚡ 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 (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property has frontage on Millbury Road, a two-lane, paved local road. Based on aerial imagery, the road appears to be in fair condition and is likely suitable for standard construction traffic. However, a detailed assessment is required to confirm its load-bearing capacity and suitability for oversized/overweight transport, such as a low-boy trailer carrying a multi-ton transformer or a 53-foot battery container. The key challenge will be creating a new site entrance with an appropriate apron and turning radius to accommodate large delivery vehicles without disrupting traffic or requiring significant road modifications.

Terrain & Buildability: The parcel is heavily wooded and, based on regional topography, is likely to have rolling hills and potential rock outcroppings, which are common in Worcester County. This presents a significant buildability challenge. Extensive tree clearing, grading, and potential blasting would be required, substantially increasing civil engineering and construction costs. The 12.58-acre parcel size is adequate, but the actual buildable area could be severely restricted by steep slopes, wetlands, and required setbacks. A formal topographic survey is essential.

Heavy Equipment Access: While the road itself may be navigable, direct access onto the undeveloped site is non-existent. A new construction entrance rated for heavy loads (AASHTO HS-20 or greater) would need to be permitted and built. The feasibility depends on sight lines along Millbury Road and the grade change from the road to the proposed project pad.

Easement Concerns: Requires Verification. As the property has direct road frontage, a dedicated access easement may not be necessary. However, a title search is required to identify any existing utility easements (for power, water, sewer) or other encumbrances that could cross the property and conflict with the proposed BESS layout.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown and represents a critical data gap. A preliminary check of the FEMA Flood Map Service Center suggests the property is likely in Zone X, an area of minimal flood hazard. However, this must be formally confirmed. Any presence of a Special Flood Hazard Area (e.g., Zone A or AE) would introduce significant design constraints, requiring equipment to be elevated above the Base Flood Elevation and potentially rendering portions of the site undevelopable.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable on a wooded, undeveloped parcel in Massachusetts. This is a primary environmental risk. Under the Massachusetts Wetlands Protection Act, activities within 100 feet of a wetland (the "Buffer Zone") are subject to review by the Oxford Conservation Commission. Development is typically prohibited within the first 25-50 feet of a wetland resource area. A formal wetlands delineation by a certified professional is a critical and immediate next step to determine the net buildable area.

Critical Habitat / Endangered Species: The initial screening shows no designated critical habitat on site, which is a positive finding. However, a more detailed desktop review using the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is recommended to screen for state-listed species whose habitats may be impacted by tree clearing and construction.

Brownfield/Superfund Status: The site has no known brownfield or superfund history. While this reduces liability risk, it also means the project is ineligible for the 10% IRA Brownfield tax credit adder, making it less competitive from an incentive perspective compared to a redeveloped industrial site.

Pipeline Proximity: No major gas transmission pipelines are located within three miles of the site. This eliminates a significant safety risk and avoids the complex setback and permitting requirements associated with co-locating near high-pressure pipelines.

3. Grid Infrastructure & Interconnection

Nearest Substation & Capacity: The nearest substation is National Grid’s NORTH OXFORD, located approximately 1.5 miles from the property. Its 115 kV bus indicates it is a transmission-level substation that also steps down to distribution voltages. The 1.5-mile distance is a major challenge for a distribution-scale project. A dedicated medium-voltage line extension of this length would be prohibitively expensive, likely in the range of $1.5M - $3.0M, and would involve significant easement acquisition and construction complexity.

Transmission & Distribution Lines: A 345 kV transmission line is closer (0.9 miles), but interconnecting a ≤5MW BESS at this voltage is not technically or economically feasible. The primary unknown is the location and capacity of the local distribution feeders (e.g., 13.8 kV) that originate from the North Oxford substation. There may be a three-phase feeder running along Millbury Road or another nearby road that could serve as a more 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). The key diligence item is to obtain distribution system maps from National Grid to identify the nearest three-phase circuit and its available hosting capacity.

Cost, Timeline & Utility Process: Interconnection in Massachusetts is governed by ISO New England (ISO-NE) and the utility, likely National Grid. The ISO-NE queue is notoriously congested and slow-moving. Even for a distribution-level project, the study process and subsequent construction can take 24-48 months. The estimated cost, assuming a POI at the substation 1.5 miles away, would likely kill the project's pro forma. If a suitable feeder is available at the property edge, costs could be reduced to several