⚡ 40 MILLBURY RD

BESS Site Diligence Analysis Report

To: Sunland America Corp. Development Committee
From: Senior BESS Site Evaluation Analyst
Date: October 26, 2023
Subject: Comprehensive Site Diligence for 40 Millbury Rd, Oxford, MA (APN: 16_D03)

1. Site Access & Topography

The subject property is a 12.58-acre parcel located at 40 Millbury Road in Oxford, MA. Initial evaluation of road access presents a mixed picture. Millbury Road appears to be a two-lane, paved local road, which is generally sufficient for construction traffic. However, a detailed review via satellite and street-level imagery is required to identify any potential constraints such as narrow sections, sharp turns, low-clearance bridges, or weight-limited infrastructure between the site and major state highways.

The land use designation of "Forest L" and its location in Worcester County suggest the site likely features rolling terrain with moderate to significant tree cover. A formal topographical survey is essential to determine the precise grade and establish the extent of civil work required. Significant grading and tree clearing will likely be necessary to create a level pad for the BESS containers, switchgear, and transformer, which will add to the overall construction cost.

Feasibility for delivering heavy equipment, such as a 70-ton main power transformer and 30-ton battery containers on lowboy trailers, is a primary concern. Access will likely require the construction of a new, robust gravel access road from Millbury Road onto the property. The viability of this access road is contingent upon topography and any environmental setbacks (e.g., from wetlands). We must also verify that the parcel has direct, legal frontage on Millbury Road. If it is a landlocked or "flag lot" parcel, securing a permanent, recorded access easement from an abutting property owner will be a critical and potentially costly prerequisite.

2. Environmental Constraints

The environmental profile of this site contains significant unknowns that represent major development risks.

• FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. If any portion of the planned equipment area falls within a 100-year floodplain (e.g., Zone AE), it could render the site undevelopable or require costly mitigation, such as elevating all equipment pads above the Base Flood Elevation (BFE), dramatically increasing civil engineering costs. Immediate verification using the FEMA Flood Map Service Center is required.
• Wetlands: The presence of wetlands is Unknown but highly probable on a forested 12.5-acre parcel in this region of Massachusetts. The Massachusetts Wetlands Protection Act imposes stringent regulations, including significant buffer zones (typically 100 feet) where development is restricted. The presence of wetlands could severely constrain the buildable area, potentially making a 5MW BESS layout infeasible. A formal wetland delineation by a certified professional is a mandatory, high-priority due diligence item.
• Critical Habitat / Species: The initial screening indicates no critical habitat, which is a positive finding. However, we recommend a secondary verification through the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present that could trigger extended regulatory review.
• Brownfield/Superfund Status: The site is clear of any nearby brownfield or superfund sites. While this mitigates potential environmental liability, it also means the project is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage.
• Pipeline Proximity: No gas pipelines within a 3-mile radius is a significant safety and design advantage, eliminating setback requirements and potential co-location risks.

3. Grid Infrastructure & Interconnection

The site's proximity to grid infrastructure is its strongest attribute. The North Oxford substation is located approximately 1.5 miles from the parcel. This is a very favorable distance for an interconnection line extension. The substation's maximum voltage of 115 kV indicates it is a substantial node in the grid, likely with both transmission and distribution-level buses.

For a distribution-scale project (≤5MW), the recommended interconnection strategy is to target a 13.8 kV (or similar) distribution feeder originating from the North Oxford substation. A 345 kV transmission line is also nearby (0.9 miles), but tapping into it would be prohibitively expensive and complex for a project of this scale. The primary task is to identify the interconnecting utility (presumed to be National Grid, but requires verification) and the specific 3-phase distribution feeder route