⚡ 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 Road in Oxford, Worcester County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid interconnection, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Initial evaluation of the subject parcel reveals significant challenges related to physical access and site preparation. The 12.58-acre property is heavily wooded and appears to be set back from Millbury Road, with no obvious improved access point. This raises immediate concerns about legal and physical access.

• Road Access Quality: Millbury Road is a two-lane, local road. While paved, its suitability for heavy haul trucks carrying multi-ton battery containers, transformers, and switchgear is questionable without a formal route survey. Potential constraints include narrow shoulders, overhead utility lines, and residential traffic.
• Terrain & Site Prep: As "Forest Land," the site is presumed to have uneven topography and will require extensive tree clearing, grubbing, and grading to create a level pad for the BESS equipment. This will add significant cost and time to the construction process. A full geotechnical and topographical survey is required to determine soil stability and precise grading requirements.
• Heavy Equipment Feasibility: Access for heavy equipment is a major risk. A low-boy trailer carrying a 30-ton transformer or a 40-foot battery container requires wide turning radii and stable roadbeds. The current unimproved access from Millbury Road is insufficient.
• Easement Concerns: This is a critical risk. The parcel appears landlocked or to have limited, undeveloped frontage. It is imperative to conduct a title search immediately to determine if a deeded, insurable access easement exists. Without a legally sound and physically viable access easement, this site is not developable.

2. Environmental Constraints

The site presents several environmental unknowns that must be resolved before committing significant capital. While some data points are favorable, the gaps represent substantial risk.

• FEMA Flood Zone: The flood zone designation is currently unknown. This is a critical data gap. Development within a Special Flood Hazard Area (e.g., Zone AE) would trigger stringent elevation requirements for all equipment pads and control houses, dramatically increasing civil engineering costs and potentially rendering the site unbuildable. Verification via the FEMA Map Service Center is a priority.
• Wetlands: The presence of wetlands is unknown but highly likely on a forested parcel in Massachusetts. The MA Wetlands Protection Act imposes a 100-foot buffer zone around most wetland resources, and federal regulations may also apply. A formal wetlands delineation is essential to determine the net buildable area, which could be substantially smaller than the gross 12.58 acres.
- Critical Habitat / Endangered Species: The initial screening shows no designated critical habitat, which is a positive finding. However, a desktop review using the USFWS IPaC tool and MassGIS is still recommended as standard practice to confirm no sensitive species are present.
• Brownfield/Superfund Status: The site is not a brownfield and is not near any Superfund sites. While this mitigates environmental liability risk, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, a notable economic disadvantage.
• Pipeline Proximity: No gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating concerns for pipeline-related setbacks and explosion risks.

3. Grid Infrastructure & Interconnection

The site's viability is heavily dependent on a cost-effective interconnection to the local distribution grid. The provided data points towards a challenging, but potentially feasible, scenario.

• Nearest Substation: The NORTH OXFORD substation (115 kV) is 1.5 miles away. This distance is manageable for a distribution line extension but makes a direct connection to the substation bus more expensive. The 115 kV voltage class is transmission-level and not a cost-effective target for a ≤5MW BESS.
• Transmission Lines: A 345 kV transmission line is closer (0.9 miles), but tapping a line of this voltage for a small project is technically and economically infeasible.
• Recommended Interconnection: The only viable path is an interconnection to a local 3-phase distribution feeder, likely operating at 13.8 kV. Such a feeder is probably located along Millbury Road. Requires Verification: A formal inquiry must be