⚡ 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) at the subject property. The analysis covers key site attributes, constraints, and opportunities to inform a go/no-go decision.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. Initial review via satellite imagery suggests the road is in good condition and suitable for standard construction traffic.

Terrain & Equipment Feasibility: The parcel is currently undeveloped and heavily forested, consistent with its "Forest Land" classification. The topography in this region of Worcester County is characterized by rolling hills. Significant tree clearing, stumping, and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. While access from Millbury Road is feasible, a new crushed-stone or paved access drive will need to be constructed onto the site. The 12.58-acre parcel size provides ample space to design an appropriate internal road layout with sufficient turn radii for lowboy trailers delivering battery containers and the main power transformer.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests a utility distribution line crosses the property. This implies a pre-existing utility easement. A full title search is required to confirm the location, width, and restrictions of this easement. While the presence of an easement is beneficial for interconnection, its specific location could constrain the site layout and usable area. No other access easement concerns are immediately apparent, as the property has direct public road frontage.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. A review of the FEMA Flood Insurance Rate Maps (FIRMs) is an immediate next step. If the proposed development area falls within a Special Flood Hazard Area (e.g., Zone A or AE), it would introduce significant design challenges, increased costs for elevating equipment, and potential permitting hurdles. A location within a floodway would likely be a fatal flaw.

Wetlands: The presence of wetlands is Unknown. Given the undeveloped, forested nature of the site in Massachusetts, there is a high probability of state-jurisdictional wetlands and associated buffer zones. The Massachusetts Wetlands Protection Act imposes a 100-foot buffer zone around delineated wetlands, within which development is heavily restricted. The presence of significant wetlands could severely reduce the Buildable Acres and render the site non-viable. A formal wetlands delineation is a critical and urgent due diligence item.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this should be verified with a desktop review using the USFWS IPaC tool and MassGIS OLIVER to screen for state and federally listed endangered or threatened species whose habitats may be present.

Site Contamination: The site has no known history as a brownfield or superfund site. While this precludes eligibility for the 10% IRA brownfield tax credit adder, it is a net positive, as it significantly reduces the risk of encountering soil or groundwater contamination and associated environmental liability and cleanup costs.

Other Constraints: No pipelines or gas wells are located in the immediate vicinity, eliminating potential safety setback requirements and co-location risks. The site is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Interconnection Point (POI): The most compelling attribute of this site is the "POI Onsite" data point at a 13.2 kV distribution voltage. If a 3-phase, 13.2 kV feeder with sufficient capacity is indeed present on the property, it dramatically simplifies the interconnection and significantly reduces costs. The interconnecting utility (ID: 38cc5e9a...) is presumed to be National Grid, the primary electric utility in Oxford, MA.

Substation & Feeder: The nearest substation, North Oxford, is 2.7 miles away. This distance would typically imply a high cost for a dedicated line extension. Therefore, the viability of this project is almost entirely dependent on the ability to interconnect to the existing onsite or adjacent distribution line. The feeder configuration is likely a standard overhead line running along Millbury Road. A pre-application report must be filed with National Grid to confirm the feeder's available capacity (hosting capacity), its protection scheme, and whether it can support a ≤5MW injection without requiring extensive and costly upstream upgrades at the substation.

Cost & Timeline: Assuming a viable onsite POI, interconnection costs could be in the range of $500,000 - $1,500,000 for switchgear, protection equipment, and a short line tap. If the onsite feeder lacks capacity and upgrades back to the substation are required, costs could easily exceed $3,000,000. The interconnection process in Massachusetts under the Mass DPU is notoriously slow; a realistic timeline from application submission to Permission to Operate (PTO) is 24-36 months.

Transmission: A 345kV transmission line is 0.9 miles away, but interconnection at this voltage level is not feasible or economical for a distribution-scale project.

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