⚡ 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-scale (≤5MW) Battery Energy Storage System (BESS) on the 12.58-acre parcel at 40 Millbury Rd, Oxford, MA. The analysis concludes with a suitability score, risk assessment, and recommended next steps.

1. Site Access & Topography

Road Access & Equipment Delivery: The property is located on Millbury Road, which appears to be a two-lane, paved local road. While generally sufficient for construction traffic, a detailed turning radius analysis is required to confirm access for oversized vehicles delivering battery containers and the main power transformer. The key concern is the direct access point from the road onto the parcel itself. Requires Verification: A site visit is needed to assess the current state of any curb cut or driveway and determine if a new, heavy-duty access road entrance must be constructed.

Terrain & Buildability: The land use is designated as "Forest L," indicating the site is heavily wooded. This will necessitate significant clearing and grubbing, adding to site preparation costs. Topographical maps of Worcester County suggest the site likely features rolling hills, which may require substantial grading to create a level pad for the BESS equipment. The need for extensive earthwork could increase civil engineering costs and prolong the construction schedule.

Easement Concerns: A preliminary GIS review suggests the parcel may have limited frontage on Millbury Road or could potentially be partially landlocked, relying on a narrow strip for access. This is a critical risk. A full ALTA survey and title report are mandatory to confirm legal, unencumbered access to the public right-of-way. If access is not guaranteed, securing an access easement from an adjacent landowner would be necessary, which is often a costly and uncertain process.

2. Environmental Constraints

Flood Zone & Wetlands: The FEMA Flood Zone and wetlands status are currently unknown. This represents a major information gap and a significant project risk. Given the forested, undeveloped nature of the site in Massachusetts, the presence of state-jurisdictional wetlands is highly probable. Under the Massachusetts Wetlands Protection Act, any work within a 100-foot buffer zone of a wetland requires approval from the local Conservation Commission, and direct impacts are difficult to permit. A full wetland delineation is an immediate priority, as the presence of extensive wetlands could render the site undevelopable.

Habitat & Protected Species: The data indicates no critical federal habitat on site, which is a positive initial finding. However, a desktop review using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database is required to screen for state-listed species and priority habitats, which could impose time-of-year restrictions on construction or other mitigation requirements.

Site Contamination: The absence of nearby brownfield or superfund sites is advantageous from a liability perspective, ensuring a clean site without remediation needs. However, this also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a competitive disadvantage.

Other Constraints: The site is clear of pipeline proximity risks, which simplifies safety planning and layout design. The property is not located within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The nearest substation, NORTH OXFORD, is 1.5 miles away and has a 115 kV bus. While a 345 kV transmission line is closer (0.9 miles), interconnecting a ≤5MW project at transmission voltage is prohibitively expensive. Therefore, the only viable path is interconnection to a distribution feeder from the North Oxford substation. The utility is presumed to be National Grid.

Interconnection Viability & Cost: A 1.5-mile distance to the substation is significant and will require a costly line extension. Estimated costs for a new 13.8 kV (assumed) distribution line of this length could range from $1.5M to $3.0M+, depending on terrain,