⚡ 40 MILLBURY RD

TO: Sunland America Corp. Investment 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, grid infrastructure, environmental constraints, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Equipment Delivery: The property has frontage on Millbury Road, a publicly maintained, two-lane paved road. A preliminary review of aerial and street-level imagery indicates that the road is in good condition and appears suitable for standard construction traffic, including dump trucks and concrete mixers. However, a detailed route survey is required to confirm feasibility for oversized and overweight loads, specifically the delivery of 40-53 foot battery containers and the main power transformer. The survey must verify the absence of low-clearance bridges, sharp turning radii, or weight-restricted infrastructure between the site and major transportation corridors like I-395 or the Massachusetts Turnpike (I-90).

Terrain & Site Preparation: The parcel is currently undeveloped and heavily wooded, consistent with its "Forest Land" classification. Topographical maps for Worcester County suggest the site likely features rolling terrain. Significant tree clearing and grading will be required to create a level pad for the BESS equipment, switchgear, and access roads. The 12.58-acre parcel size offers some flexibility in siting the project to minimize earthwork, but development costs will be higher than on a flat, cleared site. The "Buildability: OK" designation is noted but considered preliminary until a geotechnical survey is completed to assess soil conditions and rock presence.

Easements: The data indicates "POI Onsite," which strongly suggests an existing utility right-of-way crosses the property. This is a major advantage for interconnection but must be precisely located to ensure it does not conflict with the proposed equipment layout. A new, formal access easement from Millbury Road to the BESS pad will likely be required as part of the site plan approval process.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are both listed as "Unknown." These are critical, potentially fatal-flaw information gaps. Given the site's undeveloped and forested nature in Massachusetts, the presence of state or federally regulated wetlands is highly probable. A wetlands delineation, performed by a certified professional, is an immediate priority. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone ("Riverfront Area") around perennial streams and other resource areas, which would significantly constrain the available buildable area. Similarly, a FEMA Flood Insurance Rate Map (FIRM) analysis is required. If any portion of the planned development area falls within a Special Flood Hazard Area (e.g., Zone A or AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity.

Habitat, Contamination & Other Factors: The site shows no critical habitat, protected areas, or nearby brownfield/superfund sites. The lack of a brownfield designation is a positive from a liability standpoint but eliminates the possibility of capturing the 10% IRA brownfield tax credit adder. The absence of nearby pipelines or gas wells is a significant safety and risk-mitigation positive, simplifying site design and safety planning.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The site's most compelling feature is the "POI Onsite" at a 13.2 kV distribution voltage. This is an ideal scenario for a distribution-scale (≤5MW) project. It indicates a three-phase distribution feeder, likely operated by National Grid (Requires Verification), either crosses the property or runs adjacent along Millbury Road. This eliminates the need for a costly