⚡ 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 potential acquisition and development of a Battery Energy Storage System (BESS) project at the subject property. The analysis covers key evaluation criteria including site access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives. The final recommendation is based on a quantitative scoring of the site's suitability.

1. Site Access & Topography

Road Access & Equipment Delivery: The provided data lacks specific information on road access. A desktop review using aerial imagery indicates the 12.58-acre parcel has limited or no direct frontage on Millbury Road, a paved, two-lane local road. The parcel appears to be heavily wooded and potentially landlocked behind existing residential properties. Access for construction and delivery of heavy equipment, such as a 150,000 lb transformer or 80,000 lb battery containers, is a critical and unconfirmed risk. Existing residential driveways are unsuitable. A new, dedicated access road would likely be required, potentially traversing neighboring parcels.

Terrain Characteristics: The property is zoned as "Forest Land," consistent with aerial imagery showing dense tree cover. The topography in Worcester County is characterized by rolling hills. Therefore, we anticipate the site is not level and will require significant clearing, grubbing, and grading, increasing site preparation costs substantially. A formal topographic survey is required to quantify the extent of earthwork needed.

Easement Concerns: This is a major red flag. If the parcel is indeed landlocked, securing a permanent, wide (minimum 30-foot) access and utility easement from an adjacent landowner is mandatory. This process can be time-consuming, expensive, and is often unsuccessful. The project's viability is contingent on negotiating and acquiring these rights. This represents a potential fatal flaw.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: Flood zone and wetland status are currently unknown. This is a significant data gap. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act), which mandate significant setbacks (typically 100-foot buffer zones) from any delineated wetland resource areas. Given the undeveloped, forested nature of the site, the presence of wetlands, vernal pools, or intermittent streams is highly probable. Any presence of FEMA Special Flood Hazard Areas (e.g., Zone A, AE) would further restrict buildable acreage and impose costly flood-proofing design requirements. A desktop screening using MassGIS OLIVER and a formal wetlands delineation are immediate next steps.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this must be verified through the official USFWS IPaC (Information for Planning and Consultation) tool and a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present.

Site Contamination: The absence of nearby brownfield or superfund sites is advantageous from a liability and remediation standpoint. However, it eliminates the possibility of qualifying for the 10% IRA brownfield tax credit adder, placing the project at a slight financial disadvantage compared to repurposed industrial sites.

Other Constraints: The site is not within the Chesapeake Bay Critical Area (N/A). The lack of pipelines within a 3-mile radius is a significant safety and layout advantage, removing a common constraint for BESS projects.

3. Grid Infrastructure & Interconnection

Substation & Transmission Proximity: The nearest substation, NORTH OXFORD, is 1.5 miles away and has a 115 kV bus. A 345 kV transmission line is closer at 0.9 miles. For a distribution-scale project (≤5MW), interconnecting at transmission voltage (either 115kV or 345kV) is technically and financially infeasible.

Likely Interconnection Point & Voltage: The most viable Point of Interconnection (POI) would be a local distribution feeder, likely operating at 13.8 kV. Utility poles are visible along Millbury Road, suggesting the presence of such a feeder. The interconnecting utility is Requires Verification but is likely National Grid for this service territory. The key unknown is whether the local feeder has sufficient thermal capacity and fault duty headroom to accommodate a 5MW injection without requiring extensive, and costly, upgrades back to the substation.

Estimated Cost & Timeline: The 1.5-mile distance to the substation is a major concern. Even if a local feeder tap is possible, any required reconductoring or upgrades over that distance could be prohibitively expensive. A rough order-of-magnitude cost for a 1.5-mile line extension and associated upgrades could easily range from $1.5M to $3.0M+. The interconnection process in Massachusetts within ISO-New England is notoriously slow and complex, typically taking 24-36 months from application to Commercial Operation Date (COD).

4. Regulatory & Zoning Analysis