⚡ 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 the potential development of a distribution or utility-scale Battery Energy Storage System (BESS) on the 12.58-acre parcel located at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis concludes that while the parcel size is adequate, significant challenges related to zoning, grid interconnection, and lack of financial incentives present a high-risk profile for development.

1. Site Access & Topography

The subject property has frontage on Millbury Road, which appears to be a two-lane, paved local road. While likely sufficient for initial site visits, a detailed analysis is required to confirm its suitability for heavy haul transport. The delivery of multi-ton transformers and 40-foot battery enclosures requires wide turning radii, no low-clearance bridges, and sufficient roadbed integrity, all of which are currently unverified.

The land use is designated as "Forest Land," indicating the site is heavily wooded. Topography in this region of Worcester County is typically characterized by rolling hills and potentially rocky, glacial till soil. This suggests that significant site preparation costs for clearing, grubbing, and grading will be necessary. A formal topographical survey is required to assess the slope and determine the most suitable location for the BESS pad, which needs to be relatively flat. Access from Millbury Road to a viable project location within the parcel interior will likely require the construction of a new gravel access road, adding to project costs and environmental impact.

• Equipment Access: High Risk. The feasibility of delivering heavy equipment is unknown. The need to construct a new access road through wooded, potentially sloped terrain is a major buildability concern.
• Easement Concerns: A new gen-tie line to either the distant substation or a local distribution line will be required, necessitating off-site easements from adjacent landowners. This process can be time-consuming and costly.

2. Environmental Constraints

The environmental profile of the site presents several critical data gaps that must be resolved. Massachusetts has stringent environmental regulations, particularly regarding wetlands, which can be a fatal flaw for development.

• FEMA Flood Zone: Requires Verification. The flood zone status is unknown. A review of FEMA Flood Insurance Rate Maps (FIRMs) is a priority. Siting within a Special Flood Hazard Area (SFHA) would introduce significant design complexity and cost to elevate equipment, if permitted at all.
• Wetlands: Requires Verification. The presence of wetlands is unknown. Given the undeveloped, forested nature of the site, there is a high probability of state or federally regulated wetlands and associated buffer zones. A desktop screening using MassGIS is an immediate next step, but a formal wetlands delineation by a certified professional will be required to confirm the buildable area. This is a potential fatal flaw.
• Critical Habitat / Species: The initial screen shows no critical habitat, which is a positive. However, this should be verified against the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database for any priority habitats or vernal pools.
• Brownfield/Superfund Status: The site is not a brownfield. This avoids potential remediation liabilities but also means the project is ineligible for the 10% IRA Brownfield tax credit adder, a significant financial disadvantage.
• Pipeline Proximity: No major pipelines are located nearby, which is a positive finding that eliminates setback and safety concerns associated with this risk.

3. Grid Infrastructure & Interconnection

The provided grid data presents a