⚡ 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 (≤5MW) Battery Energy Storage System (BESS) project on a 12.58-acre parcel in Oxford, Worcester County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

The subject property is located at 40 Millbury Rd. Initial desktop analysis indicates that Millbury Road is a two-lane, paved local road, which should be sufficient for standard construction traffic. However, a detailed route survey is required to confirm the absence of any low-clearance bridges, sharp turns, or weight-limited infrastructure between major highways and the site that could impede the delivery of oversized/overweight equipment such as transformers or prefabricated battery enclosures.

The parcel's land use is designated as "Forest L," indicating it is heavily wooded. Topographical maps for this region of Worcester County typically show rolling hills. Therefore, we must assume significant site work will be required, including tree clearing, grubbing, and grading to create a level pad for the BESS equipment. These activities will add considerable cost and time to the project budget and schedule.

A critical unknown is the access point from Millbury Road onto the developable portion of the 12.58-acre parcel. There does not appear to be an existing improved driveway. A new access road will need to be constructed, and its path could be constrained by steep slopes, wetlands, or other environmental features. The cost and feasibility of this access road are a primary buildability risk. Furthermore, it is Requires Verification whether the parcel has direct, legal frontage on Millbury Road or if an access easement across an adjacent property would be required. Securing an off-site easement can be a costly and time-consuming negotiation with no guarantee of success.

2. Environmental Constraints

Environmental risks are significant and largely unquantified at this stage.

• FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development will be severely restricted and will require elevating all equipment above the Base Flood Elevation, dramatically increasing foundation costs and potentially making the project financially unviable. A FEMA FIRMette must be obtained immediately.
• Wetlands: The wetlands status is Unknown. For a forested parcel in Massachusetts, the probability of jurisdictional wetlands and associated buffer zones is extremely high. The Massachusetts Wetlands Protection Act imposes strict regulations, often including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A wetlands delineation is mandatory and could reveal that the usable, upland acreage is insufficient for a 5MW BESS footprint.
• Critical Habitat / Species: While initial data shows no federally listed critical habitat, a desktop screening using the USFWS IPaC tool and MassGIS state-level data is necessary to rule out impacts to state-listed threatened or endangered species.
• Brownfield/Superfund: The absence of nearby brownfield or superfund sites is positive from a liability perspective, but it means the project is ineligible for the 10% IRA Brownfield tax credit adder, which is a competitive disadvantage.
• Pipeline Proximity: The lack of major gas pipelines within three miles is a significant safety and design advantage, eliminating concerns about blast radii and associated setbacks.

3. Grid Infrastructure & Interconnection

The grid infrastructure presents a mixed outlook. The North Oxford substation is located a reasonable 1.5 miles from the site. However, its maximum voltage is 115 kV, which is transmission-level. For a ≤5MW distribution-scale project, a direct interconnection at 115 kV would be prohibitively expensive and complex.

The likely interconnection point (POI) would be a 3-phase distribution feeder originating from the North Oxford substation. The interconnecting utility is almost certainly National Grid. We must immediately investigate the route of distribution feeders along Millbury Road or other nearby roads. The key unknowns are:

• The voltage of the local distribution circuit (e.g., 13.2 kV).
• The available hosting capacity of the feeder. Feeders in this area may be capacity-constrained.
• The physical condition and phase of the lines.

Assuming a viable distribution feeder is present along the road, an interconnection line extension of up to 1.5 miles could be required. The cost for such a line, especially through wooded and rolling terrain, could range from $1.5M to $3.0M+. The National Grid interconnection process in Massachusetts is notoriously slow, with queue times often extending 24-36 months from application to commercial operation. A pre-application report is an essential first step to gain clarity on a viable POI and receive a preliminary, non-binding cost estimate. The nearby 345kV transmission line is irrelevant for a project of this scale.

4. Regulatory & Zoning Analysis

The regulatory and zoning landscape represents the most significant barrier to this project. The Authority Having Jurisdiction (AHJ) is the Town of Oxford. The parcel is zoned R-1 (Residential) and designated as "Private Preserve, Open Space."

A BESS is an industrial utility use and is fundamentally incompatible with residential and open space zoning. It is virtually certain that a BESS is not a by-right use in the R-1 zone. The permitting pathway will be arduous and uncertain, likely requiring a Special Use Permit or a Variance from the Oxford Zoning Board of Appeals. This process involves public hearings and is highly susceptible to local opposition ("NIMBYism"), which is common for energy infrastructure in residential areas.