⚡ 40 MILLBURY RD

BESS Site Diligence Analysis Report

Prepared for: Sunland America Corp. Development Committee
Property: 40 Millbury Rd, Oxford, Worcester County, MA (APN: 16_D03)
Analyst: Senior BESS Site Evaluation Analyst
Date: October 26, 2023

1. Site Access & Topography

The subject property benefits from direct frontage on Millbury Road, a publicly maintained, two-lane paved road. Initial desktop review suggests this road is sufficient for standard construction traffic and preliminary site visits. However, a detailed turn-radius analysis will be required to confirm feasibility for oversized and overweight vehicles, such as a mobile crane, main power transformer (MPT), and battery container delivery trucks. The "Buildability: OK" designation is noted, but requires field verification.

Based on aerial imagery and the "Forest Land" classification, the site is heavily wooded and appears to be undeveloped. The topography near the road seems relatively flat, which is advantageous for minimizing civil work. However, the terrain further into the 12.58-acre parcel is unknown and could feature significant elevation changes or rock outcroppings common in Worcester County, which would increase site preparation costs. The most critical unknown is the number of truly buildable acres, which will be dictated by topography, environmental constraints, and setbacks. While the Point of Interconnection (POI) is listed as "Onsite," its exact location is not specified. If the POI is located deep within the parcel, an access road compliant with emergency vehicle standards will need to be constructed, potentially requiring easements if the optimal path crosses property lines.

2. Environmental Constraints

Environmental diligence presents significant data gaps that must be addressed immediately. The FEMA Flood Zone and presence of wetlands are both marked as "Unknown." Given the undeveloped, forested nature of the site in Massachusetts, the probability of jurisdictional wetlands is high. A desktop screening using the National Wetlands Inventory (NWI) is the immediate first step, to be followed by a formal field delineation by a certified wetland scientist. Any identified wetlands will trigger significant state (Massachusetts Wetlands Protection Act) and local (Oxford Conservation Commission) setback requirements, which could severely constrain the buildable envelope.

On a positive note, the site appears clear of several major environmental risks. There are no identified Brownfield or Superfund sites within a two-mile radius. While this simplifies the environmental permitting process, it also means the project is ineligible for the 10% IRA Brownfield tax credit adder. The site is not within a designated critical habitat area for endangered species, and no pipelines are in the immediate vicinity, reducing safety and setback concerns. As the property is in Massachusetts, the Chesapeake Bay Critical Area regulations are not applicable.

3. Grid Infrastructure & Interconnection

The grid infrastructure is the most compelling attribute of this site. The designation of "POI Onsite" at a distribution voltage of 13.2 kV is ideal for our target project size (≤5MW). This indicates a three-phase distribution feeder, likely owned and operated by National Grid (Requires Verification), runs along the property's road frontage or through an existing utility easement. This configuration dramatically reduces interconnection costs by eliminating the need for an expensive, multi-mile gen-tie line. Estimated interconnection costs could be in the $500,000 to $1.5 million range, primarily for switchgear, protection equipment, and a short line extension, as opposed to the multi-million-dollar cost of a substation tap.

The nearest major substation, North Oxford (2.7 miles), is a 115 kV transmission facility and is not the likely source of the 13.2 kV feeder. The feeder's source substation is likely a smaller, closer distribution-level facility. A formal interconnection pre-application with the utility is essential to identify the specific feeder, confirm its available capacity for a BESS injection, and understand its thermal and voltage limitations. The interconnection process in Massachusetts under National Grid follows the MISO queue, which is known for being lengthy and complex, with timelines often extending 24-36 months from application to commercial operation. Early engagement is critical.

4. Regulatory & Zoning Analysis

The regulatory and zoning profile represents the single greatest risk to this project. The Authority Having Jurisdiction (AHJ) is the Town of Oxford. The property's zoning is listed as "R-1" (Residential) and "Vacant Land - Private Preserve, Open Space-Vacant Land." Battery energy storage is an industrial utility use and is fundamentally incompatible with a residential or conservation-focused zoning district. It is highly unlikely that BESS is a permitted use "by-right."

Therefore, the permitting pathway will be arduous, requiring, at a minimum, a Special Permit from the Oxford Planning Board and likely a Use Variance from the Zoning Board of Appeals. A Use Variance has a very high legal threshold to meet, requiring proof of unique hardship associated with the land itself. This process is costly, time-consuming (12+ months), and has a low probability of success, especially given the high potential for public opposition from residential abutters. A thorough review of the Town of Oxford's Zoning Bylaws is required to see if they have any specific provisions for renewable energy or energy storage systems. Without such a provision, the project's viability is in serious doubt. The risk of a complete moratorium on BESS development, while not currently known, is also a possibility in small New England towns facing development pressure.

5. IRA/ITC Incentive Analysis

The project's financial incentives under the Inflation Reduction Act (IRA) are minimal, which weakens its economic profile. The provided data confirms the site is not located in an Opportunity Zone, an Energy Community (neither statistical area nor coal closure), or a Low-Income Community. Consequently, the project is ineligible for any of the 10% ITC adders.

Assuming the project meets the prevailing wage and apprenticeship requirements, it will qualify for the base 30% Investment Tax Credit (ITC). However, with no available adders, the cumulative potential ITC is limited to this base level.

• Opportunity Zone Adder: 0%
• Energy Community Adder: 0%
• Low-Income Community Adder: 0%
• Potential Cumulative ITC Adder: 0%

This lack of incentive stacking places the project at a competitive disadvantage compared to sites that can achieve a 40% or 50% ITC.

6. BESS Score & Rationale

Overall BESS Suitability Score: 47/100

• Location (10/20): The site is in a decent load pocket within Worcester County, but its specific location in a residential/preserve area is a major drawback for development.
• Grid Access (23/25): Outstanding. An onsite POI at 13.2 kV is nearly perfect for a distribution-scale project and is the site's only truly exceptional feature.
• Environmental (8/15): Scored cautiously due to the high-impact unknowns of wetlands and floodplains. The absence of other major flags prevents a lower score.
• Regulatory (3/15): Extremely poor. The R-1 / Private Preserve zoning is a potential fatal flaw with a very difficult and uncertain permitting path.
• Incentives (2/15): Very poor. The inability to capture any IRA adders significantly weakens project economics.
• Buildability (1/10): Scored very low due to the critical "Buildable Acres" data gap. Without knowing if a 2-3 acre BESS facility can even fit after setbacks, the site's viability is purely speculative.

7. Key Risks & Mitigants