⚡ 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 APN 16_D03 (40 Millbury Rd, Oxford, MA)

This report provides a comprehensive due diligence analysis for the 12.58-acre property located at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has frontage on Millbury Road, a two-lane, paved local road. Based on aerial imagery review, the road appears to be in fair condition and should be sufficient for standard construction traffic, including dump trucks and concrete mixers. However, its suitability for oversized/overweight loads, such as a main power transformer or fully-loaded BESS containers on a lowboy trailer, is a concern. A formal route survey would be required to confirm bridge weight limits, turning radii, and overhead line clearances from the nearest state highway to the site entrance.

Terrain & Buildability: The parcel is heavily wooded and appears to have moderate topographical variation, which is typical for this region of central Massachusetts. Significant clearing and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. This will increase civil construction costs and may trigger additional stormwater management permitting requirements. The exact buildable area is unknown and will be constrained by topography, environmental setbacks, and zoning setbacks.

Heavy Equipment Access: While the public road is likely adequate, there is no existing improved access point or driveway from Millbury Road onto the parcel. A new commercial-grade curb cut and access road will need to be engineered and constructed. The ability to maneuver heavy equipment, particularly a large crane for setting the transformer and BESS units, will depend entirely on the design of this new access road and the graded project area. The forested nature of the site presents a significant initial hurdle.

Easement Concerns: Requires Verification. The current parcel configuration appears to have direct road frontage, mitigating the need for an off-site access easement. However, a title search is required to confirm no existing easements (e.g., for conservation or private access) encumber the property and restrict development.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. A preliminary desktop review suggests the majority of the parcel is in Zone X (area of minimal flood hazard). However, a small stream or drainage feature may be present on or near the property, which could have an associated floodplain (Zone AE). A formal Flood Hazard Determination is a critical next step. Any development within a designated floodplain would be highly restrictive and likely render the site unsuitable.

Wetlands: Requires Verification. The presence of wetlands is a high risk. The site is undeveloped, forested, and located in Massachusetts, a state with stringent wetland protection regulations under the Massachusetts Wetlands Protection Act (WPA). It is highly probable that state or federally jurisdictional wetlands and/or vernal pools exist on the property. A full wetland delineation by a certified professional is mandatory. The presence of wetlands would introduce significant setbacks (typically 100-foot buffer zones in MA) that could severely limit or eliminate the buildable area.

Critical Habitat / Endangered Species: The initial screen shows no critical habitat. This is a positive finding. However, we recommend a formal desktop review using the Massachusetts 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. This is a low-risk item but a standard part of due diligence.

Brownfield/Superfund Status: The site is not a brownfield, and there are no superfund sites within a two-mile radius. This eliminates the risk of legacy contamination and costly remediation. However, it also means the project is not eligible for the 10% IRA brownfield tax credit adder, which is a minor economic disadvantage.

Pipeline Proximity: No gas transmission pipelines are located within three miles of the site. This is a significant safety and layout advantage, as it removes any potential pipeline-related setback or consultation requirements.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation, North Oxford, is 1.5 miles away and has a maximum voltage of 115 kV. This is a transmission-level substation. The nearest transmission line is a 345 kV line located 0.9 miles away. Interconnecting a ≤5MW BESS project at either of these transmission voltages would be technically complex and financially prohibitive, with costs easily exceeding $5-10 million.

Likely Interconnection Point: The only viable path for this project is a distribution-level interconnection (e.g., 13.8 kV). Requires Verification. We must identify a 3-phase distribution feeder running along Millbury Road with sufficient thermal and fault-duty capacity. The 1.5-mile distance to the substation is a major red flag; the local feeder may be capacity-constrained or single-phase. The interconnecting utility is unknown but is likely National Grid for this service territory.

Estimated Cost & Timeline: If a viable 3-phase feeder exists at the road frontage, interconnection costs would still be substantial, likely in the $750k - $1.5M range for switchgear, protection upgrades, and a short line extension. If the feeder requires significant upgrades or a new dedicated line must be run from the substation, the cost would escalate to $2M - $4M+, rendering the project uneconomical. The ISO-NE interconnection queue is notoriously slow and complex; a timeline of 24-36 months