⚡ 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 property located at 40 Millbury Road in Oxford, Worcester County, Massachusetts, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key evaluation criteria including site access, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access: The site has frontage on Millbury Road, which is designated as a public road. A preliminary review of satellite imagery indicates Millbury Road is a two-lane, paved local road. While seemingly adequate for standard vehicles, a formal turning radius analysis and road survey would be required to confirm its suitability for lowboy trailers carrying heavy equipment like transformers (50-70 tons) and battery containers (30-40 tons). Potential constraints include narrow shoulders, overhead utility lines, and potential weight limits on local bridges between the site and major highways.

Topography & Site Conditions: The property's land use is described as "Forest Land," which, combined with its location in central Massachusetts, suggests the terrain is likely uneven, with moderate to significant slopes and dense tree cover. This will necessitate substantial civil work, including clearing, grading, and the construction of a stable gravel pad for the BESS equipment. The cost and complexity of this civil work could be significant and will directly impact the project's buildable area and budget.

Equipment Access: The primary access point from Millbury Road to the proposed BESS pad location needs to be established. An access road capable of supporting heavy construction traffic will need to be constructed. The "POI Onsite" designation is a major advantage, as it implies the BESS can be sited relatively close to the public road, minimizing the length and cost of the access road.

Easements: An access easement from Millbury Road onto the parcel will be required as part of any lease or purchase agreement. Additionally, a utility easement will be needed for the interconnection line running from the BESS switchgear to the point of interconnection on the 13.2 kV line. The exact requirements must be negotiated with the landowner and the interconnecting utility.

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 data gaps. Massachusetts has highly restrictive wetland regulations under the Massachusetts Wetlands Protection Act, often requiring 100-foot or greater buffers from delineated wetlands, which could severely limit the buildable acreage. Siting equipment within a designated floodplain would require elevating all pads and control systems above the Base Flood Elevation (BFE), adding substantial cost. Immediate desktop screening and subsequent field delineation are required.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site. This is a positive finding, but should be verified with a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or sensitive areas are present.

Brownfield/Superfund Status: The site is not a brownfield. While this reduces potential environmental liability and cleanup costs, it also means the project is ineligible for the 10% Brownfield Adder under the Inflation Reduction Act (IRA), which is a notable economic disadvantage.

Other Considerations: The absence of nearby pipelines or gas wells is a significant safety and permitting advantage, reducing the complexity of site layout and safety planning.

3. Grid Infrastructure & Interconnection

Interconnection Point: The site's strongest attribute is the "POI Onsite" at a target voltage of 13.2 kV. This indicates a 3-phase distribution feeder is either on or immediately adjacent to the property, likely running along Millbury Road. This configuration is ideal for a distribution-scale (≤5MW) project, as it has the potential to dramatically reduce the cost and timeline of interconnection by avoiding the need for a lengthy and expensive generator lead line.

Substation & Feeder: The nearest substation, North Oxford (2.7 miles), has a 115 kV high side, confirming it supports distribution circuits like the 13.2 kV feeder targeted for this project. While the substation distance is noted, the critical factor is the available capacity and power quality of the specific feeder at the point of interconnection. A formal interconnection application is necessary to determine if the feeder can accommodate a 5MW injection/withdrawal without requiring costly upgrades (e.g., re-conductoring, substation breaker upgrades).

Cost & Timeline Estimate: Assuming the feeder has capacity and the POI is easily accessible, interconnection costs could be in the range of $750,000 to $2,000,000. However, if significant utility system upgrades are required, this cost could escalate dramatically. The interconnection process in Massachusetts with major utilities like National Grid or Eversource is notoriously slow, with queue backlogs common. A realistic timeline from application submission to commercial operation is 24-48 months.

Recommended Voltage: The 13.2 kV distribution-level interconnection is appropriate and cost-effective for a project of this scale.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The Town of Oxford, MA.

Zoning & Permitting Pathway: This is the most significant risk for the project. The parcel is zoned R-1 (Residential) and designated as "Private Preserve, Open Space-Vacant Land." A BESS is an industrial utility use and is fundamentally incompatible with this zoning. It will not be permitted by-right. The project will require, at a minimum, a Special Permit and likely a Use Variance from the Oxford Zoning Board of Appeals. This is a discretionary, quasi-judicial process that is time-consuming (9-18 months), expensive, and has a high risk of denial.