⚡ 40 MILLBURY RD

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 (≤5MW) Battery Energy Storage System (BESS) site. The analysis concludes that the site faces significant, potentially fatal flaws related to zoning, grid access, and lack of financial incentives.

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, access appears physically possible for standard construction vehicles. However, the delivery of oversized and overweight equipment, such as a main power transformer (MPT) or pre-fabricated battery containers on a flatbed truck, presents a moderate risk. A detailed route survey would be required to assess turning radii from main thoroughfares, potential overhead line conflicts, and any weight-limited bridges or culverts. The narrowness of the road could require temporary traffic control during major deliveries.

Terrain Characteristics: The current land use is designated as "Forest Land." This, combined with the general topography of Worcester County, suggests the site is likely wooded with rolling terrain. Significant tree clearing, stumping, and grading will be required to create a level pad for the BESS equipment. A full topographical survey is essential to quantify the required earthwork, which could substantially impact civil construction costs.

Heavy Equipment Accessibility: While equipment can likely reach the property boundary via Millbury Road, on-site accessibility is a major concern. An internal access road will need to be constructed from the public right-of-way to the project pad. The cost and feasibility of this road will depend entirely on the site's slope, soil conditions, and the presence of any wetlands or streams that would require crossings.

Easement Concerns: Requires Verification. While the parcel appears to have direct frontage, the exact width and suitability of this frontage for a commercial-grade entrance needs to be confirmed via a survey and title search. No other access easements are noted, but a title report is necessary to confirm no encumbrances exist that would restrict development.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the buildable area falling within a 100-year floodplain (Zone A or AE) would introduce significant design challenges, requiring equipment to be elevated above the Base Flood Elevation (BFE) or potentially rendering the site undevelopable. A FEMA FIRMette review is an immediate next step.

Wetlands: The presence of wetlands is unknown but considered highly likely given the forested, undeveloped nature of the site in Massachusetts. The Massachusetts Wetlands Protection Act (WPA) and local Oxford bylaws impose strict regulations, typically including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. The potential for wetlands to consume a large portion of the 12.58 acres and dictate the project layout is a primary environmental risk.

Critical Habitat / Endangered Species: The data indicates no known critical habitat on site, which is a positive initial finding. However, this must be verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or priority habitats are present, which could trigger further consultation and mitigation requirements.

Brownfield/Superfund Status: The site is not a brownfield, and no superfund sites are located nearby. While this avoids environmental liability and remediation costs, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, representing a significant missed financial opportunity.

Pipeline Proximity: No major gas or hazardous liquid pipelines are located within three miles. This is a significant safety and design advantage, eliminating risks of explosion and costly setback requirements.

3. Grid Infrastructure & Interconnection

Nearest Substation & Transmission: The nearest substation, NORTH OXFORD, is 1.5 miles away and has a maximum voltage of 115 kV. A 345kV transmission line is closer (0.9 miles). For a ≤5MW project, a 345kV interconnection is financially and technically infeasible. The 1.5-mile distance to the substation is a major challenge for a distribution-level interconnection.

Recommended Interconnection: The only viable path for a ≤5MW BESS is an interconnection to a local distribution feeder, typically at 13.2 kV or 13.8 kV. The key unknown is the availability, capacity, and three-phase configuration of a distribution line along Millbury Road. The viability of this entire project hinges on the presence of a suitable feeder with available thermal and voltage capacity to accommodate a 5MW injection/withdrawal.

Estimated Cost & Timeline: If a new 1.5-mile distribution line must be built to the North Oxford substation,