⚡ 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 the property located at 40 Millbury Rd in Oxford, Worcester County, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) or small utility-scale Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Millbury Road. A preliminary desktop review indicates Millbury Road is a two-lane, paved local road. While seemingly adequate for standard construction traffic, a formal logistics and transportation study is required to confirm its suitability for oversized and overweight loads. Key concerns include the road's weight rating, turning radii at intersections, and the potential presence of low-clearance overhead lines or bridges between the site and major state highways. The feasibility of delivering heavy equipment, such as a 100-ton crane for setting a main power transformer (MPT) and multiple 30-ton battery containers, is currently unverified and represents a moderate risk.

Terrain Characteristics: The parcel is designated as "Forest Land," indicating it is currently undeveloped and heavily wooded. This will necessitate significant tree clearing, grubbing, and site grading, adding considerable cost and time to the pre-construction phase. Topographical maps for the region suggest rolling terrain, which could require substantial earthwork to create a level pad for the BESS equipment, further increasing civil engineering costs.

Access Easements: A critical unknown is whether the 12.58-acre parcel has direct, deeded frontage and access rights onto Millbury Road. A title search is immediately required to confirm legal access. If access is dependent on an easement across an adjacent property, negotiations with that landowner would be necessary, introducing significant risk and potential project delays or termination.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are both listed as "Unknown." These are critical-path diligence items. A desktop review using FEMA's Map Service Center and the U.S. Fish and Wildlife Service's National Wetlands Inventory (NWI) must be conducted immediately. If any portion of the buildable area falls within a 100-year floodplain (e.g., Zone A or AE), it would require elevating all equipment above the Base Flood Elevation, adding significant cost, or could render the site unusable. The forested nature of the site in Massachusetts makes the presence of wetlands highly probable. A formal wetland delineation would be required, and development would be subject to significant state (Massachusetts Wetlands Protection Act) and local (Oxford Conservation Commission) setback requirements, typically 100 feet or more, which could severely constrain the buildable envelope.

Habitat & Contamination: The site has no known critical habitat, protected areas, or nearby brownfield/superfund sites. The lack of a brownfield designation means the project is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage. The absence of nearby pipelines or gas wells is a positive, eliminating a key safety and setback concern.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The nearest substation, NORTH OXFORD, is 1.5 miles away and has a maximum voltage of 115 kV. A 345 kV transmission line is closer at 0.9 miles. For our target project size (≤5MW), interconnecting to a 345 kV line is financially and technically infeasible. Interconnection at the 115 kV bus at the North Oxford substation is possible but presents a major challenge. A 1.5-mile line extension at this voltage would be exceptionally expensive, likely in the $2M - $4M range, making a small distribution-scale project economically unviable.

Recommended Interconnection & Feeder Analysis: The only viable path for a ≤5MW project is to interconnect to a local 3-phase distribution feeder (e.g., 13.2 kV). The primary unknown is whether such a feeder exists along the site's frontage on Millbury Road. This is the single most important grid-related question. We must immediately identify the local electric utility (likely National Grid) and procure their distribution maps to verify the presence, voltage, and phase of nearby lines.

Cost, Timeline, and Utility Process: If a suitable distribution feeder is available, interconnection costs could be in the $250k - $1M range, depending on required upgrades. If not, the project is likely a non-starter due to the high cost of a line extension to the substation. The interconnection process in Massachusetts is governed by ISO-New England, which has a notoriously long and complex queue. A typical project timeline from application to commercial operation can easily exceed 36 months.

4. Regulatory & Zoning Analysis

Jurisdiction and Zoning: The Authority Having Jurisdiction (AHJ) is the Town of Oxford. The parcel is zoned R-1 (Residential) and designated as "Private Preserve, Open Space-Vacant Land." This zoning is a major, and potentially fatal, flaw. BESS is an industrial/utility use and is fundamentally incompatible with residential and open space zoning designations.

Permitting Pathway & Risks: A BESS project would not be permitted by-right. The project would require, at a minimum, a Special Permit from