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

This report provides a comprehensive due diligence analysis for the property located at 40 Millbury Road, Oxford, MA (APN 16_D03) for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project. 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, which appears to be a two-lane, paved local road. This road should be sufficient for the delivery of standard construction vehicles and materials. However, a detailed review of satellite imagery reveals no existing curb cut, driveway, or cleared access point onto the 12.58-acre parcel. A new access point would need to be engineered and permitted by the Oxford Department of Public Works and/or MassDOT, depending on jurisdiction.

Topography & Feasibility: The land use is designated as "Forest Land," which, combined with the typical geography of Worcester County, suggests the site is likely heavily wooded with potentially rolling or uneven terrain. Significant tree clearing and civil work, including grading and soil stabilization, would be required to create a level pad for the BESS equipment. This will increase site preparation costs and may trigger additional environmental review under local or state regulations (e.g., tree removal ordinances).

Heavy Equipment Access: While Millbury Road itself can likely handle the weight of transformers and battery containers, the primary challenge is the "last 100 feet" onto the site. The lack of an existing entrance and the forested, potentially sloped frontage present a significant logistical hurdle. A temporary construction entrance would be needed, and the final site design must accommodate turning radii for lowboy trailers.

Easements: Requires Verification. No easement data was provided. A full title report is a critical next step to identify any existing utility easements (which could be beneficial) or access/conservation easements (which could severely restrict or prohibit development). Given the "Private Preserve" and "Open Space" designation, a conservation easement is a distinct possibility and would likely be a fatal flaw.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. A review of FEMA's Flood Insurance Rate Maps (FIRMs) is an immediate priority. If any portion of the planned equipment pad 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. Any significant flood risk would likely render the site non-viable.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable on a forested parcel of this size in Central Massachusetts. Development would be subject to the Massachusetts Wetlands Protection Act and the local Oxford Wetlands Protection Bylaw, which typically enforce a 100-foot buffer zone around delineated wetland resources. A formal wetlands delineation by a certified professional is required to determine the buildable area, which could be significantly smaller than the total 12.58 acres.

Habitat & Species: The data indicates no critical habitats on site, which is a positive initial finding. However, a desktop review using the MassGIS Natural Heritage & Endangered Species Program (NHESP) database is recommended to confirm there are no mapped priority habitats for rare species that could trigger a state-level review.

Brownfield/Superfund Status: The site is not a brownfield and is not near any Superfund sites. While this eliminates environmental liability concerns, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, placing it at a financial disadvantage compared to qualifying sites.

Pipeline Proximity: No gas pipelines are located within three miles, which is a significant safety and layout advantage, eliminating concerns around pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Substation & POI: The nearest substation is North Oxford, located approximately 1.5 miles from the parcel. This is a considerable distance for a distribution-scale project. A 1.5-mile line extension would be required, representing a major project cost. The substation's max voltage is 115 kV (transmission), but it almost certainly steps down to a distribution voltage (e.g., 13.2 kV or 23 kV). The Point of Interconnection (POI) would be on one of these distribution feeders.

Recommended Interconnection: For a ≤5MW BESS, interconnection must be at the distribution level. The project would require a dedicated 1.5-mile, 3-phase overhead or underground feeder extension from the North Oxford substation to the site.

Cost & Timeline