⚡ 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 distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Rd, Oxford, MA. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The subject parcel has frontage on Millbury Road, a two-lane, paved local road. A preliminary review of aerial and street-level imagery indicates the road is in fair condition and appears suitable for standard construction traffic. However, a formal transportation study would be required to confirm its suitability for oversized/overweight loads, such as a main power transformer (MPT) or pre-fabricated battery enclosures. Potential constraints like narrow shoulders, tight turning radii from main thoroughfares, and overhead utility line clearance must be field-verified.

Terrain & Buildability: The property is designated as "Forest L," indicating it is currently undeveloped and heavily wooded. Topographical maps of Worcester County show rolling hills, and this parcel is likely to have moderate slope variations. Significant tree clearing, grubbing, and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. This will increase site preparation costs and may trigger stormwater management requirements under local and state regulations. The presence of bedrock, common in this region of Massachusetts, could further complicate excavation and increase costs.

Heavy Equipment Feasibility: Access for heavy equipment is feasible but presents challenges. The primary concern is the final approach from Millbury Road onto the undeveloped site. A new, robust construction entrance and internal access road capable of supporting crane operations and delivery of 80,000+ lb transformers will need to be engineered and built.

Easement Concerns: The parcel appears to have direct frontage, mitigating the need for a dedicated access easement. However, a utility easement for the interconnection line (gen-tie) will be required, spanning approximately 1.5 miles to the nearest substation. The route for this line will be critical; securing easements from multiple private landowners or routing within the public right-of-way can be time-consuming and expensive.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone status is currently unknown. This is a critical data gap. Any portion of the site within a 100-year floodplain (Zone A/AE) would be severely constrained, requiring all equipment to be elevated above the Base Flood Elevation, significantly increasing costs or rendering the site unusable. A high-priority next step is to review the relevant FEMA Flood Insurance Rate Map (FIRM).

Wetlands: Requires Verification. The wetland status is unknown. Given the forested, undeveloped nature of the 12.58-acre site in Massachusetts, there is a high probability of state- and federally-jurisdictional wetlands, streams, or vernal pools. The Massachusetts Wetlands Protection Act imposes stringent regulations, including significant buffer zones (typically