⚡ 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 – 40 Millbury Rd, Oxford, MA (APN: 16_D03)

This report provides a comprehensive due diligence analysis for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis identifies several significant challenges related to zoning, incentives, and buildability that present a high-risk profile for this site.

1. Site Access & Topography

The 12.58-acre parcel is located at 40 Millbury Road, a two-lane, paved local road. While the road itself appears adequate for standard construction traffic, access for oversized and overweight vehicles, such as a main power transformer (MPT) or pre-fabricated battery enclosures, is a concern that requires a formal route survey. The primary challenge is the lack of an existing entrance or access road onto the parcel from Millbury Road. The property appears to be heavily wooded and undeveloped.

• Equipment Delivery: A new, robust access road would need to be constructed from Millbury Road into the site. This will involve significant tree clearing, grading, and potentially culvert installation if drainage ditches are present. The cost and permitting for this access road must be factored into the project pro forma.
• Terrain Characteristics: Based on aerial imagery and its "Forest Land" designation, the site is presumed to be heavily forested with potentially uneven topography. A detailed topographical survey is required to assess grading requirements. Significant clearing and grading will be necessary, increasing site preparation costs and potentially triggering stormwater management regulations.
• Heavy Equipment Access: The feasibility of getting heavy equipment onto the site is currently low. The new access road must be designed to support crane loads for setting the transformer and battery containers. The turning radius from Millbury Road onto the new access point is a critical design constraint.
• Easement Concerns: Requires Verification. The parcel's frontage along Millbury Road appears limited. We must confirm through a title search and survey that the property has sufficient legal and physical frontage for an access road. If not, an access easement from an abutting property would be required, which introduces significant cost, timeline, and negotiation risk.

2. Environmental Constraints

The site presents a moderate to high environmental risk profile until key unknown factors are investigated. Massachusetts has stringent environmental protection laws, particularly regarding wetlands, which can be a fatal flaw for development.

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. A review of FEMA Flood Insurance Rate Maps (FIRMs) is a critical immediate step. If any portion of the planned development area falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity, or rendering the site undevelopable.
• Wetlands: Requires Verification. The presence of wetlands is unknown but highly likely on a forested, undeveloped parcel in this region. A desktop review using the National Wetlands Inventory (NWI) is the first step, but a formal field wetland delineation by a certified professional will be required. Under the Massachusetts Wetlands Protection Act, any work within 100 feet of a wetland (the "Buffer Zone") requires a permit (Notice of Intent) from the Oxford Conservation Commission, a process that can be lengthy and result in significant site layout constraints or denial.
• Critical Habitat / Endangered Species: The initial screen shows no critical habitat, which is a positive indicator. However, a formal inquiry with the MA Natural Heritage & Endangered Species Program (NHESP) is still required as part of the permitting process to confirm no state-listed species or priority habitats are impacted.
• Brownfield/Superfund Status: The absence of nearby brownfield or superfund sites is positive from a liability perspective. However, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant disadvantage for project economics.
• Pipeline Proximity: No major pipelines are located nearby, eliminating risks associated with pipeline easements, setbacks, and safety protocols.

3. Grid Infrastructure & Interconnection

The site's proximity to grid infrastructure is a mixed bag, with the primary risk being the lack of a clear and cost-effective distribution-level interconnection point.

• Nearest Substation: The NORTH OXFORD substation is 1.5 miles away. Its 115 kV maximum voltage indicates it is a transmission-level substation. While a 1.5-mile distance is manageable, interconnecting a ≤5MW BESS at transmission voltage (e.g., 69kV or 115kV) is financially prohibitive and unnecessarily complex. The project's viability depends on the availability of a distribution feeder from this substation.
• Transmission Line Proximity: A 345kV line is 0.9 miles away, but this is irrelevant for a project of our target size.
• Recommended Interconnection Voltage: The target interconnection must be at a distribution voltage, likely 13