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

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, which is designated as a public road. A preliminary review of aerial imagery indicates Millbury Road is a two-lane, paved local road. While generally acceptable for construction traffic, a formal route survey is required to assess its suitability for oversized and overweight vehicles, such as a lowboy trailer carrying a 25-ton transformer or 40-foot battery containers. Key points of concern would be any narrow sections, sharp turns, low-clearance bridges, or seasonal weight restrictions between the site and the nearest major highway (I-395 or I-290).

Topography & Site Conditions: The site is currently undeveloped forest land. Based on regional topography, the terrain is likely to be uneven, with rolling hills and potential rock outcroppings characteristic of Worcester County. The "Buildability: OK" designation is noted but requires significant verification. A detailed topographical survey will be essential to determine the extent of grading and civil work required to create a level pad for the BESS equipment. The cost of earthwork could be substantial if significant cut-and-fill is needed. The current tree cover will require clearing and grubbing, adding to site preparation costs.

Heavy Equipment Feasibility: Access for heavy equipment is feasible but conditional. The primary constraint will be the final few miles on local roads and the entrance to the site itself. A new, robust construction entrance off Millbury Road will need to be engineered and permitted. On-site, the ground conditions must be assessed for stability to support heavy cranes needed for equipment placement.

Easement Concerns: While road access is public, the "POI Onsite" claim requires verification. If the Point of Interconnection is not directly adjacent to the planned equipment pad, a utility easement across the parcel will be necessary. A title search is required to identify any existing easements (e.g., conservation, access for others) that could conflict with development.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. Any designation within a 100-year floodplain (Zone A/AE) would likely render the site undevelopable for critical infrastructure like a BESS or require cost-prohibitive mitigation, such as elevating all equipment pads above the Base Flood Elevation. This must be investigated immediately via the FEMA Flood Map Service Center.

Wetlands: The wetlands status is Unknown. Given the undeveloped, forested nature of the site in Massachusetts, there is a high probability of state- and federally-jurisdictional wetlands, vernal pools, or intermittent streams being present. The Massachusetts Wetlands Protection Act imposes significant buffer zones (typically 100 feet) and stringent performance standards that could severely limit the buildable area. A formal wetland delineation by a certified professional is a mandatory and urgent next step.

Habitat & Species: The data indicates no critical habitat or protected areas. However, this should be verified through a desktop review of the MA Natural Heritage & Endangered Species Program (NHESP) database. The presence of state-listed rare species could trigger extended environmental reviews and time-of-year restrictions on construction.

Brownfield/Superfund Status: The site is not a brownfield, as none are identified within a 2-mile radius. While this indicates a clean site, it is a disadvantage from a financial perspective, as the project is ineligible for the 10% IRA brownfield bonus tax credit.

Pipeline Proximity: The absence of major gas pipelines within 3 miles is a significant safety and design advantage, eliminating risks and setback requirements associated with pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site has a potentially ideal interconnection profile for a distribution-scale project. The data indicates a "POI Onsite" with a target interconnection voltage of 13.2 kV. This suggests a 3-phase distribution feeder, likely operated by National Grid (the primary utility in Oxford, MA), either crosses the property or runs along Millbury Road. This is far more advantageous than interconnecting to the distant North Oxford substation (2.7 miles) or the 345kV transmission line (0.9 miles), both of which would be cost-prohibitive for a ≤5MW project.

Interconnection Feasibility & Cost: The viability of this site hinges on the available capacity of the 13.2 kV feeder.

• Best Case: The feeder has sufficient capacity and requires only a short tap line, reclosers, and metering. Estimated Cost: $750,000 - $1.5 Million.
• Worst Case: The feeder lacks capacity, requiring significant upgrades such as a reconductoring of several miles of line or even work back at the substation. Estimated Cost: $2 Million - $5+ Million.

Utility & Timeline: The interconnecting utility is National Grid, operating