⚡ 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 Battery Energy Storage System (BESS) project at 40 Millbury Rd, Oxford, MA. The analysis evaluates the 12.58-acre parcel across key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives. The findings indicate significant challenges that present a high-risk profile for a distribution-scale BESS project.

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, the road itself appears adequate for standard construction traffic, including flatbed trucks for delivering battery containers and other components. However, the critical unknown is the quality and legality of the specific access point onto the parcel. The parcel is heavily wooded, and no existing curb cut or improved driveway is visible. A new, engineered access road would need to be constructed.

Terrain & Buildability: The site is undeveloped forest land. Topographical analysis using public data suggests moderately rolling to steep terrain, which is characteristic of Worcester County. This presents a significant buildability challenge. Extensive tree clearing and civil work, including cutting, filling, and grading, would be required to create a level pad for the BESS equipment. These activities will substantially increase site development costs and may trigger additional environmental review and stormwater management requirements.

Heavy Equipment Feasibility: While Millbury Road can likely support the transport, the on-site maneuverability is a major concern. The delivery of a large power transformer and multiple 40-foot battery containers requires a well-compacted, wide-radius access road and laydown area. The current state of the site makes this impossible without major civil engineering and construction.

Easement Concerns: Requires Verification. A title search is immediately required to confirm that the property possesses clear, unencumbered, and legal access directly from Millbury Road. We must also verify that no existing utility or conservation easements cross the most logical buildable area, which could sterilize the site.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. Given the site's topography, it is unlikely to be in a major floodplain, but low-lying areas or proximity to small streams could fall within Zone A or AE. Any development within a designated floodplain would require significant mitigation, elevation, and permitting, likely rendering the project non-viable. A formal flood zone determination is a critical next step.

Wetlands: Requires Verification. The presence of state or federally protected wetlands is highly probable on a 12.58-acre forested parcel in Massachusetts. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around most wetland resources, which would significantly reduce the buildable acreage. A formal wetlands delineation by a certified professional is necessary to determine the extent of these constraints.

Critical Habitat / Endangered Species: The initial screen shows no designated critical habitat on the parcel, which is a positive finding. However, a more detailed review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is recommended to confirm no priority habitats for rare species are present.

Brownfield/Superfund Status: The site is not a brownfield and is not near any Superfund sites. While this minimizes environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, a notable economic disadvantage.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating a common setback constraint and risk factor for BESS projects.

3. Grid Infrastructure & Interconnection

Substation & Transmission Assets: The North Oxford substation (115 kV) is located 1.5 miles away. A 345 kV transmission line is 0.9 miles away. For a distribution-scale project (≤5MW), interconnecting at transmission voltage (115kV or 345kV) is economically prohibitive due to the high cost of a dedicated high-voltage line extension and substation bay. These assets are therefore not viable points of interconnection (POI) for our target project size.

Recommended Interconnection: The only feasible interconnection for a distribution-scale project would be to the local distribution feeder running along Millbury Road. Requires Verification. We must identify the interconnecting