⚡ 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 subject property in Oxford, Massachusetts, for its potential as a distribution-scale (≤5MW) Battery Energy Storage System (BESS) site. The analysis concludes with a suitability score, risk assessment, and a final recommendation.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has a significant, potentially fatal flaw: it appears to be landlocked with no direct frontage on Millbury Road. Desktop analysis using aerial imagery shows the 12.58-acre parcel is situated behind several single-family residential lots. Millbury Road itself is a paved, two-lane local road, which would otherwise be adequate for construction traffic and component delivery. However, without a deeded right-of-way, access is non-existent.

Terrain Characteristics: Consistent with its location in Worcester County, the site is heavily wooded with what appears to be moderately rolling terrain. Significant tree clearing, stumping, and grading would be required to create a level pad for the BESS compound, switchgear, and transformer. This will add considerable cost and time to the site preparation phase.

Heavy Equipment Feasibility: Access for heavy equipment, including cranes for setting transformers and battery containers, is currently not feasible. A new access road, approximately 500-800 feet long, would need to be constructed from Millbury Road across an adjacent residential parcel. This introduces major project risks.

Easement Concerns: Securing both a permanent access easement and a utility easement from an unwilling or speculative adjacent landowner is a primary obstacle. Negotiations could be protracted, costly, or ultimately unsuccessful, rendering the site unusable. This dependency on a third-party agreement before site control is a critical risk.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as "Unknown." Requires Verification. A preliminary desktop review of the FEMA Flood Map Service Center suggests the area is likely designated as Zone X (Area of Minimal Flood Hazard). However, a formal site-specific determination is required. If any portion is within a Special Flood Hazard Area (e.g., Zone A), development would be severely restricted or require costly elevation and mitigation measures.

Wetlands: The presence of wetlands is "Unknown." Requires Verification. Given the undeveloped, forested nature of the site, the presence of state-jurisdictional wetlands is highly probable. Massachusetts has a stringent Wetlands Protection Act, which mandates significant setbacks (typically 100-foot buffer zones) from any delineated wetland resource areas. A formal wetlands delineation by a certified professional is a critical next step, as the results could substantially reduce the buildable area.

Critical Habitat / Endangered Species: The provided data indicates no known critical habitat on site. This is a positive finding, but a desktop review using the USFWS IPaC tool and MassGIS OLIVER is still recommended to screen for potential impacts to state or federally listed species and obtain formal agency concurrence.

Brownfield/Superfund Status: The site is not a brownfield, which is a double-edged sword. It avoids potential environmental liability and cleanup costs. However, it also means the project is ineligible for the 10% ITC "Brownfield" adder under the Inflation Reduction Act (IRA), a significant economic disadvantage.

Pipeline Proximity: No major gas transmission pipelines are located within three miles, which eliminates a significant safety, setback, and co-location risk.

3. Grid Infrastructure & Interconnection

Nearest Substation: The NORTH OXFORD substation is 1.5 miles away and has a maximum voltage of 115 kV. This is a transmission-class substation. While it is the source of local distribution, a 1.5-mile dedicated line extension for a ≤5MW BESS project would be economically prohibitive, likely costing well over $2 million and triggering extensive permitting.

Transmission Line Proximity: A 345kV transmission line is located 0.9 miles from the site. This is not a viable Point of Interconnection (POI) for a distribution-scale project due to the extreme cost and complexity of a 345kV interconnection.

Recommended Interconnection: The only feasible path is an interconnection to a local 3-phase distribution feeder, likely running along Millbury Road. The interconnecting utility would be National Grid. The voltage is expected to