⚡ 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 subject property in Oxford, Massachusetts, for its potential as a distribution-scale or utility-scale Battery Energy Storage System (BESS) project. The analysis identifies several significant challenges that present a high-risk profile for development.

1. Site Access & Topography

Road Access: The property fronts Millbury Road, a two-lane, paved local road. While this road appears suitable for standard construction traffic, a formal road survey is required to confirm its width, turning radii, and the absence of weight-limited bridges or culverts between the site and major state highways. The primary concern is the lack of any existing curb cut, driveway, or access road onto the parcel from Millbury Road.

Terrain & Buildability: Based on aerial imagery and the "Forest Land" use code, the 12.58-acre parcel is heavily wooded with what appears to be moderately rolling terrain, typical for Worcester County. Significant tree clearing, stumping, and grading will be required to create a suitable pad for BESS equipment. This will substantially increase civil engineering and construction costs and may trigger additional environmental review under the Massachusetts Environmental Policy Act (MEPA).

Heavy Equipment Access: The most critical deficiency is the physical and legal access onto the site itself. Without an existing entrance, a new one must be constructed. More importantly, we must confirm legal right-of-access. A full title search is immediately required to determine if any access easements exist. If not, one must be negotiated and purchased from the current owner or an adjacent landowner, introducing significant cost, timeline, and execution risk. Delivering heavy equipment such as a 50-ton transformer or 40-foot battery containers is not feasible under current conditions.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The property's flood zone and wetland status are currently unknown and represent a major project risk. Given the forested, undeveloped nature of the site in this region, the presence of state-jurisdictional wetlands is highly probable. Under the Massachusetts Wetlands Protection Act, any work within a 100-foot buffer zone of a wetland resource area is strictly regulated and often prohibited. A desktop screening using MassGIS and NWI layers is an immediate next step, to be followed by a formal field-delineation by a certified wetland scientist. Any significant presence of wetlands could render the majority of the parcel undevelopable.

Habitat & Protected Species: Initial data shows no critical habitat on site, which is a positive. However, this must be verified through the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no priority habitats of rare species are present, which could trigger a lengthy conservation and management plan process.

Brownfield/Superfund Status: The site is not a brownfield, which is advantageous from a liability and remediation standpoint. However, this also means it is ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage compared to previously developed sites.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and design benefit, eliminating concerns related to pipeline setbacks and potential explosion hazards.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site has excellent proximity to high-capacity grid infrastructure. The North Oxford 115 kV substation is 1.5 miles away, and a 345 kV transmission line is less than a mile away. This provides multiple interconnection options for various project scales.

Recommended Interconnection: For our target distribution-scale (≤5MW) project, the most viable path would be a distribution-level interconnection, likely at 13.8 kV, from a feeder originating at the North Oxford substation. A transmission-level interconnection to the 115 kV or 345 kV lines would be prohibitively expensive (likely $10M+) and complex for a project of this size.

Cost & Timeline: The primary challenge is the 1.5-mile distance to the substation. A new distribution line extension of this length will be costly, estimated in the range of $1.5M - $2.5M, depending on whether it requires new poles or can be run on existing utility poles, and accounting for terrain and road crossings. The interconnecting utility is presumed to be National Grid, but this requires verification. The ISO-New England interconnection queue is notoriously backlogged. Even a distribution-level interconnection process with National Grid can be expected to take 24-36 months from application to commercial operation.

Feeder Configuration: Requires Verification. We must immediately file a pre-application report with the utility to confirm they are the correct entity, identify the specific feeder serving the area, and